The Trade Policy Framework recently unveiled by the government has finally proposed measures to control dumping of hazardous plastic scrap in the country. Though the Ministry of Commerce has done good work by proposing some important measures to control this menace of hazardous plastic scrap dumping in the country, stakeholders believe that ambiguities need also to be removed to ensure tangible results.
The draft, they pointed out, stated that in order to regulate import of plastic scrap more efficiently, it proposed that plastic scrap/waste, other than the categories proposed to be banned in the policy, might be allowed to be imported by industrial consumer as raw material for their industry subject to the following conditions: (i) Certification confirming appropriate facility and determination of import quota from concerned federal/provincial environmental protection agency. (ii) Inspection from technically qualified designated pre-shipment inspection companies that the imported consignment does not contain any hazardous waste, as defined in the Basel Convention.
The current policy like previous policy limits, the import of non-hazardous plastic scrap to manufacturers only, however, making it more regulated by assigning manufacturer quota for import. As previously observed that most of plastic scrap in Pakistan is imported by traders for resale therefore the efficacy of newly proposed measures could only be to ascertain its implementation in letter and spirit.
In last three years Pakistan has imported more than 110,000 tons of plastic scrap, out of which most of the imported plastic scrap is used in manufacturing of pipes which are then used for supply of water thus putting millions of lives at risk and also in violation of Pakistani pipe manufacturing standards PS 3051/1991.
Further, the policy suggests that inspection of plastic scrap consignments should be carried out by technically qualified pre-shipment inspection companies to verify that goods are non-hazardous as per Basel Convention. Stakeholders said that it should be made mandatory that all importers would furnish a pre-shipment inspection certificate by the relevant authorities of exporting countries checking all 45 items mentioned in Basel Convention, to declare the plastic scrap consignments non hazardous.
They said that historically most of the scrap is released based on certification from Pakistani office of an international recognised inspection company by mere inspection of material in Pakistan instead of the actual exporting country. They confirmed that those pre-shipment inspection companies only carried out visual inspection and drew conclusion based on Gama readings, which are inadequate to determine whether product is hazardous or non-hazardous on the parameters identified by the Basel Convention (The said testing techniques are incapable of identifying levels of biological toxicity, heavy metals, chemical toxins and other sources of toxicity).
The policy document further states that in order to ensure that such consignments of plastic scrap do not contain any hazardous scrap, complete ban should be imposed on the import of following categories of plastic scrap: Hospital waste of all kinds used sewerage pipes and used chemical containers.
Stakeholders said that imported plastic scrap included all kind of hazardous scrap such as medical & clinical waste, sewerage & drainage pipes, cable insulation, bottles, food containers, packaging film etc containing contaminants and hazardous traces of pesticides, pest excrement, chemicals, sewerage, infectious diseases, food particles, unknown composition polymers which are toxic and eco toxic. Therefore imposition of ban on sewerage pipes, medical waste and chemical containers is likely to limit hazardous plastic scrap import if implemented religiously.
They said the government should also consider benchmarking practices and legislations with other developing countries in the region including China, Sri Lanka etc. Most of the currently imported plastic scrap is used in manufacturing of pipes (which are used for supply of water), despite the fact that it's not allowed as per Pakistani pipe manufacturing standards.
Therefore, as specified in the new draft policy, Pakistan Standards and Quality Control Authority (PSQCA) standard should be implemented in import policy order which should then prohibit issuance of import licenses to all such manufacturers, producing product from scrap which is not allowed as per PSQCA standard. To sum up, the draft policy was a step in right direction, however the efficacy of that remained to be tested via implementation, they said.