A critical review of the challenges with classifying sludge within the South African petroleum industry
Goosen, Gareth Zayne David
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In South Africa, The Waste Classification and Management Regulations (2013) stipulate that applicable waste streams need to be classified according to SANS 10234; the South African National Standard for the Globally Harmonised System of Classification and Labelling of Chemicals (GHS). One of these waste streams is petroleum sludge, which exists as a complex mixture of petroleum hydrocarbons, water, salts and solid particles. The primary focus of the GHS however is first and foremost on chemicals, secondly the consistent classification and labelling of petroleum substances in line with the GHS is not straightforward due to their complex nature and chemistry. The aim of this research is to critically identify what the challenges are related to the classification of sludge within the South African petroleum industry. The research methodology included a legislative review, a literature review and the conducting of semi-structured interviews. 21 interviews were conducted in total with various role-players including waste generators, waste management consultants and waste related government authorities. The results from the semi-structured interviews indicated that the challenges related to the classification of sludge within the South African petroleum industry include the lack of data from the waste generator, no standardisation when conducting the classification process, limited analytical resources, high expenditure, the variable composition of the sludge, an absence of regulatory guidance and an inefficiency with regards to SANS 10234. Recommendations were also identified including a revision of the current waste classification system, more capacity building, further published guidelines related to the classification process, more guidance from regulators and lastly standardisation with regards to the classification of industry related waste streams including petroleum sludge. The identified challenges and recommendations can allow future measures to be put in place to ensure the effective management and compliance of petroleum sludge.