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Liz Anderson

Responsible Container Management Association of Southern Africa

Sustainable Use & Re-use of Industrial Packaging, through implementation of SANS 10406 -

Reprocessing of previously certified packaging

Responsible Container Management Association of Southern AfricaThe RCMASA is :

A S 21 Co and registered Non-Profit Organisation formed in 2001 to promote the International Responsible Packaging and Container Management Principles & Codes to protect people & the environment

It promotes Partnerships along the Value Chain for ALL involved in the Life Cycle of industrial reusable containers up to 1000 litres & encompasses manufacturers, fillers, users, emptiers, reprocessors, service providers & final waste disposal sites

It encourages sustainable practices appropriate to Developing Countries, where the challenges &dynamics are different to the developed world.

Sustainable use of Industrial PackagingGlobal requirements for doing business today includeCompliance with:

Legislation, regulations & conventionsInternational Standards & best practiceCorporate Governance - Environmental, Social, Ethical and Financial responsibility to stakeholdersCustomers & suppliers requirementsSustainable use of resources Reduce, reuse and recycle wasteMinimum environmental footprint

Sustainable use of Industrial Packaging

Legislation, regulations & conventions includeISO Standards & Best Industry Practice Framework Convention on Climate ChangeBasel Convention on Hazardous WasteEU Directive 2004/12/EC on Packaging and Packaging Waste + member states regulationsDEAT - NEMA Act 107 of 1998DEAT & Provincial draft Waste Management Bills

which embody various Principles including the Duty of Care & Polluter Pays

Sustainable use of Industrial Packaging

The RCMASA aims are to promote & encourage:Safe Packaging solutions for safe use & transportExtended Producer ResponsibilityProtection of the Health & Safety of People and our Environment

Sustainable use of Resources throughProviding information, awareness raising & workshops Partnering with Government, our International & National Network of Contacts as well as

Creating value for used Industrial Packaging by Implementation of the Registration of Reprocessors to collect & reuse, or recycle used packaging to stop it becoming part of the waste stream

Road Traffic Act 93 of 1996

Chapter VIII embodies several Standards for Transport of Dangerous Goods:

SANS 10228 - classificationSANS 10229 - packagingSANS 10230 & 1 inspection & operational vehicle reqs.SANS 10232 parts 1-4 emergency requirementsSANS 10232 - transport of DGSANS 10233 - IBC’s

and by incorporation through SANS 10229 and 10233 -SANS 10406: Reprocessing of Previously Certified Packaging

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SANS 10406 – Purpose:

To set globally accepted practices for Reprocessing of previously certified packaging to ensure:

• reprocessed packaging meets agreed quality standards

• safe transport of dangerous goods in such reprocessed packaging is not compromised

• prevention of incidents, accidents or harm to people or the environment

Upliftment & Improvement of Reprocessors Practices

SANS 10406: Reprocessing of Previously Certified PackagingApplicable to Steel & plastic drums and IBC’s

(SANS 10233) Reprocessing includes:• Washing / cleaning for re-use• Reconditioning• Refurbishment• Routine maintenance• RepairWhether carried out by original manufacturers, product fillers, recyclers or reconditioners who offer for re-use

SANS 10406:2004 Requires:

• Compliance with ISO 9001 QMS i.e. a documented management system

• Compliance with requirements of ISO14001• Compliance with legislation – see annex A• A nominally empty certificate – legal record• Inspection of use packaging for safe

reprocess or scrap• Performance testing for safe reuse• Minimum equipment to reprocess & test• Records of incoming & dispatch

Currently under revision to update references

SANS 10406 RequiresISO14001 legal & other Compliance

Annex A :Acts, regulations & other publications

Atmospheric Pollution Prevention Act 45 of 1965Environment Conservation Act 73 of 1989Explosives Act 26 of 1956Fire Brigade Services Act 99 of 1987Hazardous Substances Act 15 of 1973National Environmental Management Act 107 of 1998National Road Traffic Act 93 of 1996 National Water Act 36 of 1998Nuclear Energy Act 46 of 1999Occupational Health & Safety Act 85 of 1993DWAF Min Requirements for waste - 1998

SANS 10406 - Annex BExample - Nominally empty packaging certificateshall state words to the effect:I hereby certify that these containers are nominally empty &

have been prepared for transport in compliance with legislation:

Name of company ………………………………….Number & type of containers ……………………..Previous contents ………………………………….Name of haulier …………………………………….Destination ………………………………………….Signature ……………………………………………Name & designation ……………………………….Date …………………………………………………

Registration of Reprocessors with the SABS

ALL Reprocessors of Previously Certified Packaging will be required to register with the appointed competent body as required in terms of SANS 10229 and Chapter VIII of the Road Traffic Act 93 of 1996The Process will be similar to that for new packaging except an audit report on capability & compliance of the reprocessor will replace testing of packaging

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Registration - ApplicationReprocessors will apply to the competent authority on the prescribed form together with:Application fee (to be determined)

Copy of RCMASA Audit report to verify % operational and % total compliance with SANS 10406 + auditee improvement plan to address non compliances

Audit Protocol for Registration

Developed to assess & audit reprocessors against the National Standard SANS 10406 for Registration purposes, process sponsored by KZN DAEA

The Protocol was compiled through a transparent process with a panel of over 70 experts & interested parties

Audit Protocol for RegistrationStructure of the Audit Protocol:• Section A - Auditee details• Section B - Assessment & Audit Questionaire:

☺ B1 Management System - Quality☺ B2 Management Responsibility & Corporate Governance☺ B3 Management of Resources☺ B4 Operational Controls☺ B5 Measurement and Monitoring☺ B6 Information, Analysis and Improvement☺ B7 Occupational Health and Safety Specific Issues☺ B8 Environmental Specific Issues☺ B9 Security☺ B10 Site Inspection

• Section C☺ Operational Compliance and Total Compliance scores☺ Auditors Comments & Auditee’s Improvement Plan



Completion of questionnaire & scoringThe Questionnaire is very comprehensive as designed to assess compliance with SANS 10406, ISO 9001 & 14001 Standards & the Law.

It could be used by any organization to assess compliance.Questions are rated as either Quality - Q, Health - H, Safety - S or Environmental - E ,

Also either Statutory - S or ISO requirements, best practice / desirable – D

ALL questions must be answered Y = 1, N = 0,N/A questions will be omitted from the final scoreNB if any question is not completely addressed it will score 0

and be noted for follow-up

Registration & training of Auditors

Purpose:To ensure Impartiality and Integrity of AuditThe SA Auditor Training & Certification body is the

National body for registration of Auditors & Training bodies, Auditor registration schemes include:

ISO 9001 QMS ISO 14001 EMSFood Safety MS - HACCPOccupational Health & Safety – OHSASInformation Technology Management Hospitality Management

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Auditor Registration

Three complete audits for a total of at least 10 days of audit experience acting in the role of an audit team leader under the direction & guidance of a lead auditor in the last two years.

Same as Auditor

Same as Auditor

Three complete audits for a total of at least 10 days of audit experience as an auditor-in-training under the direction and guidance of a competent lead auditor completed within the last three consecutive years.

Minimum 5 years in Q, H, S & E in related Industry

Completion of secondary education

Auditing experience

Work experience

Education

Same as AuditorAt least 24 h of audit training to gain the necessary competence to be able to audit a facility to the requirements of the RCMASA audit protocol.

Auditor Training

Audit Team LeaderAuditorParameter

Auditor Training-Wynleigh InternationalCourses held in Gauteng & DurbanThe 3 Day course includes:

The role of the key players in the protocolIntroduction to ISO 9001, 14001 & OHSAS 18001Principles of auditing – ISO 19011Auditor criteria Auditor registration processCode of conduct as an auditorEquipment & operational processes specific to

reprocessingApplicable standardsApplicable legislation

Several exercises, continual assessment & a written test

Auditor Training-Wynleigh InternationalCourses held in Gauteng & Durban

Doing the right things for the right reasons makes good business sense

Did you know that….Recycling one ton of steel cans/drums saves • 1.5 tons of iron ore,• 0.5 tons of coal, 40% water usage, 75% energy &• 80% of the CO2 emissions.This is equivalent to recycle of 65 x 210 litre drums !

EU Directive 2004/12/EC requires reporting of % packaging recycled at all stages of the value chain

• from 1 January 2006 all imported transit packaging is also obligated i.e. outer packaging unless proof of export.

The draft Waste Bill includes re-use or recycle of PackagingNB importance of accurate records!Join our efforts to be part of the solution

Sustainable reuse of Industrial Packaging - National Network of Collectors

The Registration process for Reprocessors is in place Next Step is to co-ordinate :

A National network for collectors, reprocessors, recyclers and converters

For this to work and give the users peace of mind we need to put in place a register of these service providers with criteria to measure them against.

Join our focus groups to prepare appropriate criteria for assessment and registration

Responsible Container Management Association of Southern AfricaRCMASA Focus Groups – Your input is vitalA. IBC – Intermediate Bulk ContainersB. Plastic & Steel drumsC. Criteria for Registration of collectors, recyclers

& converters of used industrial packagingD. Industry Solution for sustainable collection on

a National basisE. Social ResponsibilityUN Sub Committees of Experts for: Transport of Dangerous Goods & Global Harmonised System for Classification& labelling

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Main IssuesE. Social Responsibility

Legal obligations & pending new legislationClean, Empty - certificates & recordsExtended Producer ResponsibilityDuty of Care“Umgqomo Ophephile” – clean safe drums projectsEducation & awareness raising of the risks of

contaminated packaging to informal traders &the poor

Social ResponsibilityWhat risks does contaminated packaging pose to informal traders & the poor when sold & used for drinking water & domestic purposes??

Social Responsibility

What are the risks of contaminated packaging to informal traders & the poor when used for drinking water and domestic purposes??

Chemicals permeate the plastic to leach out & contaminate water, food and beverages stored in themPlastic drums are most popular for water and food storageSteel - lower demand for cooking & building materialWashing prior contents from used drums & containers can cause serious pollution and heath risks

Way forward ???Partnership Municipal depts, Industry & street tradersEducation - public & street traders by municipal authoritiesIndustry support & sponsorship to help provide new drums for domestic use - Priority area 20/25, 100 and 210l plastic

eThekwini project - new drums instead of used for the informal traders + education on risks


RCMASA initiative Industry Sponsorship of new drums


National Register of Collectors, Reprocessors and RecyclersAll interested in participating in a focus group to

prepare appropriate criteria for evaluation and registration of:

• collectors • recyclers• converters• scrap merchants - who deal in used

packaging with residues of dangerous goodsPlease advise us your name, contact details and

interest group

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Compliance with SANS 10406 & Registration of ReprocessorsWill ensure sustainable and safe reusable

packaging for transport of industrial products + promote sustainable use of resources, less energy & environmental footprint

JOIN the RCMASA and ensure that YOURproduct suppliers and reprocessors comply and become registered to protect people & the [email protected] www.rcmasa.org.za032 9428050

Focal Point for Value Chain & Industry Sectors:• Information, Networking & Interest Groups• Informed about new and pending Legislation• Voice To Government & Participation in Legislation • Cleaner Production, Waste Minimisation & Savings• Life Cycle approach to Control & Accountability • Best International Practice• Reduced Risk & Exposure• Competitive Advantage

For more info & to join www.rcmasa.org.za032 942 8256 [email protected]

RCMASA – BENEFITS of Membership


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