31 Jan

Just what is Zero Waste all about?

what is Zero WasteWell the name is self explanatory. Zero waste is just what you think it is.  It’s simply all about  Designing, Producing, Consuming, Re-Using and Recycling products without throwing anything away at the end of life.

This simplicity requires a major effort up front , at the Design. Because products must be designed for a continuous life or use and re-use. This will require re-manufacturing to be built into the design. Getting to a waste free world will require a total makeover of the global economy and the way we design stuff.  This will lead to the Next Industrial Revolution.

By copying how nature works,  where one species’ excrement is another’s food we will get to a multiple use/re-use mode of living. We’re not talking here about just cutting down on waste. We need to eliminate the entire concept of waste from cradle to grave. This old linear thinking of the past  gives way to a circular economy, where nothing has an end of life as we currently think of it.

This  vision is not a long way off in the future. The culmination of changing economics, of  materials science evolution, waste disposal charges, technical advances, and consumer power – along with the growing desire to be green through Corporate Responsibility programmes – will make this a reality much sooner than you might think.

24 Jan

5 Questions for Dublin City Manager on Poolbeg Incinerator plans

With the Dail’s public accounts Committee putting some difficult questions to the Dublin City Council’s representatives on Jan 22nd 2014 we feel there is more to be probed than simply the gigantic overspend of taxpayers money on the planning phase.


incinerator stack

We think that Dublin City Council has serious questions to answer on the Poolbeg incinerator farce. We already know that they illegally extended a contract with RPS, and the High Court found that they had illegally attempted to prop up the collapsing incinerator project by forcing private waste collectors to use it. The Dail’s Public Accounts Committee needs to investigate deeply why they agreed to take on Covanta as a private partner without re-opening the tender process. They also need to ask why they signed the agreement with Covanta during the 2007 general election campaign when 

no government was in place.

As the committee convenes to scrutinize the City Council’s spending frenzy we have some pertinent questions to pose ourselves:


Present safety measures are designed to avoid acute toxic effects in the immediate neighbourhood, but ignore the fact that many of the pollutants bioaccumulate, can enter the food chain and can cause chronic illnesses over time and over a much wider geographical area. No official attempts have been made to assess the effects of emissions on long-term health.

Is there a baseline health study planned for residents in the downwind locations? Will there be a health monitoring programme over the lifetime of this facility? Who will conduct this?

Q2. Fly Ash disposal.

Incinerators produce bottom and fly ash which represent 30-50% by volume of the original waste (if compacted), requiring transportation to landfill sites. Abatement equipment in modern incinerators merely transfers the toxic load, notably that of dioxins and heavy metals, from airborne emissions to the fly ash. This fly ash is light, readily windborne and mostly of low particle size. It represents a considerable and poorly understood health hazard. This is a hazardous material and must be disposed of in a class 1 landfill site.

What are the arrangements in place to deal with the bottom ash and fly ash? Where will it be stored and how will it be transported and through what areas and in what conditions?

Q3.Air Pollution monitoring.

Monitoring of incinerators has been unsatisfactory in the lack of rigor, the infrequency of monitoring, the small number of compounds measured, the levels deemed acceptable, and the absence of biological monitoring. Approval of new installations has depended on modelling data, supposed to be scientific measures of safety, even though the method used has no more than a 30% accuracy and ignores the important problem of secondary particulates.

Can you outline the monitoring regime that will be in place and the measures planned to deal with excessive emissions or those found to be above the safe limits for Dioxins and Furans bearing in mind the length of time to test the samples taken and provide results?

What community alert system will be in place to warn residents of breaches in real time?

 Q4. Pops and Ireland’s Stockholm commitments.

The Stockholm Convention came into force 17th May 2004 –
Ireland ratified the Stockholm Convention on 5th August 2010 –
The Stockholm Convention entered us into force in Ireland on 3rd November 2010 .

There are a few elements of the treaty that are worth bearing in mind…..

Article 1 of Stockholm Convention
Mindful of the precautionary approach as set forth in Principle 15 of the Rio Declaration on Environment and Development, the objective of this Convention is to protect human health and the environment from persistent organic pollutants.
Article 5 of Stockholm Convention Measures to reduce or eliminate releases from unintentional production
Each Party shall at a minimum take the following measures to reduce the total releases derived from anthropogenic sources (such as Incinerators) of each of the chemicals listed in Annex C (Dioxins and Furans), with the goal of their continuing minimization and, where
feasible, ultimate elimination:
(c) Promote the development and, where it deems appropriate, require the use of
substitute or modified materials, products and processes to prevent the formation and
release of the chemicals listed in
Annex C (Dioxins and Furans form Incinerators), taking into consideration the general
guidance on prevention and release reduction measures in Annex C (Dioxins and Furans
form Incinerators) .

As our Government Commitment and policy since 2010 is to implement the Stockholm Convention and reduce POPs how does Dublin City Council’s plan to commit to 600,000 tonne per annum of waste to the Incinerator Company and hence cause extra POPs to be produced align with our obligations under the Stockholm Convention to give primary consideration to alternative process to deal with waste such as recycling and waste reduction which will not produce new POP sources?

What consideration of alternative methods has been taken?
Is this contract to supply 600,000 tonnes of waste to the incinerator not a failure to give primary consideration to substitute processes such as recycling that would avoid the release of POP’s from incinerators?
How can Dublin City Council’s plan to commit to waste incineration and hence produce new sources of POPs be compatible with our commitments under Stockholm?


Incinerators presently contravene basic human rights as stated by the United Nations Commission on Human Rights, in particular the Right to Life under the European Human Rights Convention, but also the Stockholm Convention and the Environmental Protection Act of 1990. The foetus, infant and child are most at risk from incinerator emissions: their rights are therefore being ignored and violated, which is not in keeping with the concept of a just society. Nor is the present policy of locating incinerators in deprived areas where their health effects will be maximal.

How can Dublin City Council comply with our obligations under the European Human Rights Convention?

10 Jan

EPA reveal Ireland’s 2012 Dioxin levels

Ireland must be vigilant to maintain our low environmental Dioxin levels.

Dioxins have, in recent years, continued to generate environmental concerns that capture public attention. In order to maintain surveillance of dioxins, furans and other related pollutants, the Environmental Protection Agency (EPA) carries out a number of almost identical surveys based on levels found in cows’ milk.

The latesincinerator stackt report on dioxin levels in the Irish environment shows that dioxin levels in all of the samples taken in a 2012 survey were well below the relevant EU limits. The report is based on dioxin levels measured in cows’ milk in a 2012 survey. The report also shows that dioxin levels measured in this survey compare favourably with those taken from similar surveys in the EU and other countries.

This is the tenth such survey undertaken by the EPA since 1995 and the results are in line with the earlier studies.  A total of 38 samples were taken and, at an average of 10 per cent of the EU limit, concentrations of dioxins were low by international standards and comparisons.

How was the survey done?

The principal mechanism for the entry of dioxins into the environment in Ireland is by low-level emissions from multiple combustion sources to the atmosphere, with subsequent deposition onto vegetation such as grass.  Any dioxins on grass ingested by cows tend to concentrate in the milk fat. Hence, sampling for dioxin levels in the milk of grazing cows is the approach adopted.

The survey was carried out between June and early August 2012, during the peak outdoor grazing season, by taking a series of milk samples mainly from representative regional dairies.  Additional samples were also taken from localities that might be seen as areas of potential risk of raised dioxin levels.

While Zero Waste Ireland welcome’s the results we are concerned that testing in areas downwind of the operating waste incinerators is not done. It is by testing in the vulnerable areas that the real situation is seen. This must become a routine operation in areas where Waste Incinerators are planned or operational. For example only one sample is taken from the Carranstown area of Meath, the site of a large Commercial Waste Incinerator, which has recently received the ok to expand its capacity.

Main findings:

  • There was a slight decrease in average dioxin levels in 2012.  The levels found in the survey are well below the EU limit in milk and milk products.
  • Dioxin-like polychlorinated biphenyls (PCB) levels were also found to be lower in 2012 samples than those in 2011, by 25 per cent on average.
  • These differences – in average dioxin levels and dioxin-like PCB levels – are not significant either in environmental or analytical terms and can partly be explained by a downward revision of the International World Health Organization (WHO) toxicity factors for some of the dioxin compounds.
  • The results of this survey are in line with the dioxin results from the latest report from the Cork County Council animal health surveillance programme (published in December 2013) which has been operating in the Cork Harbour Region since 1991.
  • The data are also consistent with an FSAI breast milk study (2010) which confirmed low levels of exposure of the Irish population to dioxins and other micropollutants.
  • In view of the increased international awareness of the presence in the environment of brominated flame retardants (BFRs) and brominated dioxins (PBDD/PBDF), a broad range of these substances was also tested in the survey.  Only Polybrominated diphenyl ethers (PBDEs) were found in any appreciable quantities in the survey and are consistent with international norms.
  • Non-Dioxin PCBs were also measured for the first time. The levels found were not of concern.

The report Dioxin Levels in the Irish Environment – Tenth Assessment is available on the EPA website.

How do we measure Dioxins?

The WHO Toxic Equivalent is the current internationally recognised system for comparing dioxin toxicities of different samples.  Results are expressed in picograms of WHO Toxic Equivalent per gram of fat: 1 pg is 10-12 of a gram.

2012 Dioxin Levels: 

Average dioxin levels in 2012 slightly decreased from 0.261 pg WHO-TEQ/g in 2011 to 0.196 pg WHO-TEQ/g. The levels are well below the EU limit in milk and milk products. The revised EU limits are 2.5 pg WHO-TEQ/g for dioxins only, and 5.5 pg WHO-TEQ/g for dioxins and polychlorinated biphenyls (PCBs) combined.

What are Dioxins? 
Dioxins form a group of some 210 closely related, complex organic compounds, the vast majority of which are considered to have little environmental significance at the levels normally encountered. However, 17 of these substances have been shown to possess a very high toxicity, particularly in animal tests. The toxic responses include dermal effects, immunotoxicity and carcinogenicity, as well as reproductive and developmental toxicity. Dioxins arise mainly as unintentional by-products of incomplete combustion and from certain chemical processes. Similar effects are caused by some of the dioxin-like polychlorinated biphenyls (PCBs) and in order to conform to current practice, testing for these compounds was also included in this programme.

Sources of Dioxins
Although PCDDs and PCDFs are not produced intentionally except for research and analysis purposes their formation is often a by-product of many activities.  Some significant sources internationally are:

  • Incinerators and thermal treatment plants
  • Residential combustion
  • Open burning of waste (backyard burning, bonfires)
  • Wood preservation (~15%)
  • Iron and steel industry
  • Power production, non-ferrous metals, chemical industry
  • Traffic

Other Micropollutants
An emerging category of pollutants, brominated flame retardants (BFRs) and brominated dioxins (PBDD/PBDF) were measured as part of the main survey.  Brominated dioxins (PBDDs and PBDFs) are also formed unintentionally, mainly through incineration of wastes or accidental fires that include consumer products containing brominated flame retardants (BFRs). Many of the BFRs have been banned for future use because of their toxicity and environmental persistence but they continue to be found in many consumer products such as furniture, fabrics and electronic products.

Persistent Organic Pollutants (POPs) & the Stockholm Convention

Dioxins, PCBs and PBDEs (See Chapter 5) are among the substances listed as POPs in the Stockholm Convention. In keeping with its obligations under the Convention, the Environmental Protection Agency is designated as Ireland’s competent authority under the national POPs regulations. It  has prepared a National Implementation Plan on POPs which details the measures to be put in place to protect human health and the environment from the POPs that are
listed under the Convention, such as  dioxins, PCBs and PBDEs.
Read the plan herehttp://www.epa.ie/pubs/reports/other/dioxinresults/dioxinlevelsintheirishenvironment2012.html#.Us_pAPRdW8B

The plan ,to whch ZWAI contributed,  which was very late in being delivered, sets out further priority actions to support the control of POPs showing how it plans to limit and control POPs.

Sampling Strategy

Two types of sampling stations were chosen:

Type A background stations covering the entire country (24 samples)
Type B potential impact stations in areas of perceived potential risk (14 samples)
Type A samples were normally taken from full milk silos (30,000 to 50,000 gallons) in regional dairies. However there were a number of instances where sampling from silos was  not possible and the samples were taken instead from road tankers representative of the area to be covered.

Type B samples were taken from road tankers representing the
“potential impact” areas.

Test Sample locations.

An appendix to the Report shows the list of locations, however these are not very specific and we would welcome a detailed map of these test locations.
A1 Mitchelstown Area
A2 Co. Waterford
A3 Dublin South.Co./North Wicklow Area
A4 North Co. Wexford
A5 Charleville, Co Cork Area
A6 Ballyragget, Co Kilkenny Area
A7 Renmore, Co Galway Area
A8 Moate, Co Westmeath Area
A9 Tipperary Town/Thurles Areas
A10 Nenagh, Co. Tipperary Area
A11 Cavan/Longford/Leitrim
A12 Drinagh, Co Cork
A13 Bandon Area
A14 North Kerry Area
A15 Co Sligo
A16 Roscommon/East Galway
A18 Roscommon/Leitrim
A19 Co Monaghan
A20 Co Louth
A21 North Kildare/West Dublin
A22 So Kerry (Cahirciveen area)
A23 South Wexford
A24 SE Co. Mayo
A25 Co. Donegal
The potential impact samples B1 – B 18 were taken at 
B1 Carrigtwohill/Cobh/Great Island
B2 Aghada/East Cork Harbour
B3 Askeaton area
B4 Tarbert Co. Kerry
B5 Clarecastle, Co.Clare
B6 Cooraclare Co.Clare
B7 Ballydine, So. Tipperary
B8 Swords/Mulhuddart. Co.Dublin
B9 Grannagh, So.Kilkenny
B13 Kinsale (Dunderow) Co.Cork
B14 Ringaskiddy area. Co.Cork
B15 Crossakiel (nr Kells) Co.Meath
B17 Carranstown, Co.Meath
B18 Kinnegad, Co Westmeath