1. The International POPs Elimination Project (IPEP) Fostering Active and Effective Civil Society Participation
in Preparations for Implementation of the Stockholm Convention A Study on Waste Incineration Activities in
Nairobi that Release Dioxin and Furan into the Environment Environmental Liaison, Education and Action for
Development (ENVILEAD) Kenya November 2005 Cannon House Annex Building, Haile Selassie Avenue P.O. Box 45585-
00100, Nairobi, KENYA Tel: +254-20-243914, +254-734-940632 E-mail: [email protected] November 2005
• 2. About the International POPs Elimination Project On May 1, 2004, the International POPs Elimination
Network (IPEN http://www.ipen.org ) began a global NGO project called the International POPs Elimination Project
(IPEP) in partnership with the United Nations Industrial Development Organization (UNIDO) and the United Nations
Environment Program (UNEP). The Global Environment Facility (GEF) provided core funding for the project. IPEP
has three principal objectives: • Encourage and enable NGOs in 40 developing and transitional countries to ii
engage in activities that provide concrete and immediate contributions to country efforts in preparing for the
implementation of the Stockholm Convention; • Enhance the skills and knowledge of NGOs to help build their
capacity as effective stakeholders in the Convention implementation process; • Help establish regional and
national NGO coordination and capacity in all regions of the world in support of longer-term efforts to achieve
chemical safety. IPEP will support preparation of reports on country situation, hotspots, policy briefs, and
regional activities. Three principal types of activities will be supported by IPEP: participation in the
National Implementation Plan, training and awareness workshops, and public information and awareness campaigns.
For more information, please see http://www.ipen.org IPEN gratefully acknowledges the financial support of the
Global Environment Facility, Swiss Agency for Development and Cooperation, Swiss Agency for the Environment
Forests and Landscape, the Canada POPs Fund, the Dutch Ministry of Housing, Spatial Planning and the Environment
(VROM), Mitchell Kapor Foundation, Sigrid Rausing Trust, New York Community Trust and others. The views
expressed in this report are those of the authors and not necessarily the views of the institutions providing
management and/or financial support. This report is available in the following languages: English International
POPs Elimination Project – IPEP Website- www.ipen.org
• 3. iii TABLE OF CONTENTS LIST OF
FIGURES…………………………………………………………………………..V LIST OF TABLES
……………………………………………………………………………V ACRONYMS AND
ABBREVIATIONS………………………………………………. VI EXECUTIVE SUMMARY
…………………………………………………………………. 1
INTRODUCTION…………………………………………………………………………….. 2
Background
………………………………………………………………………………………………….
……. 2 Burning and POPs
Generation……………………………………………………………………………. 3 Objectives
of Study
…………………………………………………………………………………………….. 4
Significance of
Study…………………………………………………………………………………………… 5
METHODOLOGY……………………………………………………………………………. 5 Scope of
the
Study……………………………………………………………………………………………..
.. 5 Preparation for the Study
…………………………………………………………………………………… 6 Locations of
Interest
…………………………………………………………………………………………… 6 AREA
OF STUDY…………………………………………………………………………… 6 LITERATURE
REVIEW …………………………………………………………………… 7 Health Effects
………………………………………………………………………………………………….
…. 8 Environmental and Socio-economic Effects
…………………………………………………………. 8 Other Pollutants from Incineration
…………………………………………………………………….. 9 Public Opposition to
Incineration ……………………………………………………………………… 10 Kenya Eggs
Study
…………………………………………………………………………………………….. 10
• 4. STUDY FINDINGS………………………………………………………………………… 11
Basic
Findings…………………………………………………………………………………………..
………. 11 General
Findings…………………………………………………………………………………………..
….. 12 CHALLENGES TO THE STOCKHOLM CONVENTION: RESPONSIBLE PARTIES –
KENYA……………………………………………………………………….. 15 POPs and Scientific
Development ……………………………………………………………………… 15 POPs and Less
Organized Countries …………………………………………………………………. 15 The
Environment and Economy………………………………………………………………………… 17
ALTERNATIVE PRACTICES …………………………………………………………. 17 Alternative
Technologies for Hazardous Waste Treatment ………………………………… 17
RECOMMENDATIONS………………………………………………………………….. 19 CONCLUSION
……………………………………………………………………………… 21 ANNEX 1: MAPS
………………………………………………………………………….. 24 ANNEX 2: PLATES
………………………………………………………………………. 26 iv
• 5. v LIST OF FIGURES Fig. 1: Comparison of U-POPs emissions from different source categories in Kenya
………………………………………………………………………………………………….
…………….. 4 Fig. 2: Mean values (PCDD/Fs) found in Eggs Sampled from Dandora – Kenya, compared with
levels in eggs from other contaminated sites in the world………… 11 LIST OF TABLES Table 1. Worldwide
atmospheric emissions of trace metals from waste incineration
………………………………………………………………………………………………….
…… 10 Table 2. Waste disposal methods for various major companies in Nairobi ………. 14 Table 3. Non-
Incineration technologies for hazardous waste treatment…………… 18
• 6. vi ACRONYMS AND ABBREVIATIONS AFD: Agence Francaise de Développement APCD: Air Pollution Control Devices
BAT: Best Available Techniques BEP: Best Environmental Practices CBO: Community Based Organization CBS: Central
Bureau of Statistics EMCA: Environment Management and Coordination Act EPR: Extended Producer Responsibility
GAIA: Global Anti-Incinerator Alliance/ Global Alliance for Incinerator Alternatives GoK: Government of Kenya
GPCR: Gas Phase Chemical Reduction HCB: Hexachlorobenzene IARC: International Agency for Research on Cancer
IPEN: International POPs Elimination Network IPEP: International POPs Elimination Project ITDG: Intermediate
Technology Group JICA: Japan International Cooperation Agency KAM: Kenya Association of Manufacturers KEBS:
Kenya Bureau of Standards KEPI: Kenya Expanded Programme on Immunization KIPPRA: Kenya Institute for Public
Policy Research and Analysis KNH: Kenyatta National Hospital LOCs: Less Organized Countries NIP: National
Implementation Plan NCT: Non Combustion Technology NGO: Non Governmental Organization PCBs: Polychlorinated
Biphenyls PCDD: Polychlorinated dibenzo-p-dioxins PCDF: Polychlorinated dibenzofurans POPs: Persistent Organic
Pollutants PVC: Polyvinyl Chloride SANE: South Africa New Economics (network) SCWO: Super-Critical Water
Oxidation TCDD: 2,3,7,8 – tetrachlorodibenzodioxin TEQ: Toxic Equivalency Quotient TNT: Trinitrotoluene UNEP:
United Nations Environmental Program U-POPs: Unintentional Persistent Organic Pollutants USEPA: United States
Environmental Protection Agency WHO: World Health Organization
• 7. EXECUTIVE SUMMARY This report outlines the findings of a study carried out in and around the city of
Nairobi, Kenya by ENVILEAD. The study was carried out between the months of January and March 2005, about the
patterns of practice that are likely to release persistent organic pollutants (POPs) into the environment as
part of the International POPs Elimination Project (IPEP’s) initiatives. The focus of the study was the
practice of medical and municipal waste burning, which research has shown to be a potential source of
unintentional POPs (U-POPs). The study’s objective was to investigate the anatomy of this practice, identify
the key issues involved and make recommendations for the way forward. It was established that burning is the
dominant method of waste disposal in the city, and this is done through industrial incinerators and in the open
air. The main reason for this preferred method of disposal is its convenience in the absence of a functioning
system of waste management (by the City Council) and in the absence of adequate legal guidelines on the disposal
of solid waste by the government. This practice is however also associated with several other factors such as
lack of awareness on the part of the public, economic pressures and the general paucity of administrative
capacity in Less Organized Countries (LOCs). The study was able to establish that the area around the Dandora
dumpsite, the city’s biggest waste burning site, is highly contaminated with POPs. This was established from
the results of U-POPs levels in eggs sampled from the site in a different study. There is also a high likelihood
of other sites, such as the Kenyatta National Hospital (KNH) incinerator, whose maximum temperatures range
between 600°C and 700°C and has no Air Pollution control Devices (APCD), and open-air burning site and
Kitengela open burning site being U-POPs hotspots. The study came up with the following key recommendations for
the way forward: ¾ Additional research needs to be undertaken in order to gather more detailed information
regarding this pattern of practice. Among the additional research required is in the area of relationship
between the socio-economic dynamics and the practice, quantification of the levels of dioxin (as well as other
organic pollutants and heavy metals) emissions from the identified sites, and establishment of the impacts of
the same on public health; ¾ The legal framework for the safe disposal of solid waste, based on Best Available
Techniques (BAT) and Best Environmental Practices (BEP), should to be addressed; ¾ The plastics industry, as a
major contributor of difficult-to-manage waste, needs to be fully engaged in the search for solutions in the
city’s waste management programme; ¾ Greater effort should be placed in the development of alternative
technologies 1 for safe waste disposal, which should be affordable and sustainable;
• 8. ¾ A popular appreciation of the science of ecology needs to be created in the country, as a means of
ensuring sustained grassroots support for environmental conservation efforts. INTRODUCTION Background Just as
the generation of waste involves a complex interplay of social, cultural, economic and technological processes,
the proper management of waste cannot be divorced from the same processes. While it is necessary, for conceptual
purposes, to view waste management as a clear and distinct category of activity in society, in practice any
successful waste management strategy has to address such diverse issues as patterns of consumption, incentive
systems (the economics of waste management), waste handling technology, and legal frameworks. In its broadest
sense, the issue of waste management is an aspect of the search for sustainable development strategies. This
report seeks to provide an overview of the critical issues regarding the management of municipal and medical
waste in Nairobi, especially in respect of the potential danger of generating unintentional POPs (U-POPs) in the
process of burning such waste. The study’s broader objective is to assist in the development of a comprehensive
waste management strategy for the city and other urban areas in the country, in the context of the provisions of
the Stockholm Convention on Persistent Organic Pollutants (POPs). Annex C of the Stockholm Convention,
identifies waste incinerators, including co-incinerators of municipal, hazardous or medical waste or of sewage
sludge, as source categories with high potential to release U-POPs into the environment. Municipal and medical
waste was selected for study because of its large quantity as a percentage of the total waste generated1, and
the complex nature of issues involved in the proper management of these two types of waste. Nairobi City Council
(2002) admits that it is unable to manage waste effectively in the city, and of particular concern was the
proliferation of informal medical facilities, some of which are located within residential areas. The
Environmental Management and Coordination Act (1999), is well placed to manage waste, including POPs-
contaminated waste, it gives provisions for setting of standards, licensing of waste disposal sites and control
of hazardous waste. However, lack of enforcement mechanism is the biggest challenge facing waste management in
Kenya (Nairobi City Council, 2002). 2 1 A report by NEMA reveals that Nairobi generates approximately 2000
tonnes of waste per day. Of this, 68% is municipal waste generated from households (East Standard 2004)
• 9. Kenya as a country is in the process of developing a National Health Care Waste Management Plan. The
National AIDS Control Council has just received funds from the World Bank toward the cost of Kenya’s HIV/AIDS
Disaster Response Project, part of the funds are to be used in the development of a National Health Care Waste
Management Plan (Daily Nation, 2005). The lack of enforcement of the relevant environmental law, among other key
factors, has led to a chaotic situation in which almost anything goes as far as the handling of waste is
concerned. A recent report by KIPPRA on solid waste management in Kenya shows that only 25% of the solid waste
generated daily in the city of Nairobi is currently collected (UNEP 2005). The focus of the study was waste
burning, which any casual observation reveals to be the preferred waste disposal option for the Nairobi
residents, which is a consequence of failure on the part of the City Council, and Government, to institute
organized systems waste handling. The study looked at open air burning types and industrial incinerators.
Burning and POPs Generation Polychlorinated dibenzo-p-dioxins (PCDD) and Polychlorinated dibenzofurans (PCDF),
Hexachlorobenzene (HCB) and Polychlorinated Biphenyls (PCBs) are unintentional persistent organic pollutants
(U-POPs), formed and released from thermal processes involving organic matter and chlorine as a result of
incomplete combustion or chemical reactions. These U-POPs are commonly known as dioxins because of their similar
structure and health effects (Tangri 2003). These U-POPs are both of natural and anthropogenic origin. They
resist photolytic, biological and chemical degradation. They are bio-accumulative, widespread geographically and
are toxic to life. The concentration of U-POPs of anthropogenic origin has greatly increased over the years.
Toxics Link Report (2000) identifies several potential sources of these U-POPs, among them being medical waste
incineration and open burning of domestic waste. According to USEPA estimates, municipal solid waste
incineration and medical waste incineration are among the top sources of dioxins released into the air. They
make up for 1,100gm TEQ/year and 477gm TEQ/year respectively (USEPA 1998). Of all source categories, combustion
sources account for nearly 80% of air emissions. 3
• 10. 4 AIR LAND Waste Incineration Ferrous and Non-Ferrous Metal Production Production of Chemicals and
Consumer Goods* Waste Incineration Uncontrolled Combustion Processes Source: Kenya POPs Inventory Fig. 1:
Comparison of U-POPs emissions from different source categories in Kenya Luscombe and Costner (2003) show how
incinerators endanger public health and the environment in general. They identify the toxic pollutants in
incinerator gases and residues, and enumerate the human health and environmental damage of the various chemicals
in the incinerator releases. Connett (1998) shows how municipal waste incineration is a poor solution to the
waste management problem. He lists the toxic emissions of incineration and shows how dioxins, furans and other
by-products of combustion impact human health and the environment. Objectives of Study The overall goal of the
study was to understand the (social, economic and technological) dynamics of the practice of waste burning in
the city and to find out how this might contribute to the release of U-POPs into the environment. Other critical
issues, such as the public health impact of the pattern of practice, were left for the next phase of the study.
The specific objectives of the study were: i. to assess the extent of waste burning/incineration within Nairobi
ii. to establish the City Council of Nairobi’s role in the prevalence of open burning and incineration as the
preferred methods of waste disposal iii. to identify the location of waste burning/ incineration sites in the
city iv. to find out how chlorine-containing waste (such as PVC plastics) is disposed v. to assess the level of
awareness of the general public about the adverse consequences of waste incineration
• 11. vi. to examine Government regulatory mechanisms for disposal of chlorine-containing 5 waste vii. to
explore suitable BAT and BEP for waste management in Kenya. Significance of Study Article 5 of the Stockholm
Convention requires parties, Kenya included2, taking measures to reduce or eliminate releases from unintentional
production of POPs. These measures include: i. reduction of annual total releases derived from anthropogenic
sources of U-POPs, with the goal of their continuing minimization and where feasible, ultimate elimination; ii.
the development of an action plan (NIP) by parties. Kenya’s NIP should be ready by 25th December, 2006; and
iii. to promote BEP and incorporate BAT in the NIP. The study’s findings will be incorporated in Kenya’s NIP
of the Stockholm Convention with a view to assisting in the realization of the above measures. METHODOLOGY To
achieve the objectives of this study, both primary and secondary data was used. Primary data comprised local
views, perceptions and opinions related to the waste disposal sites among local community members. Various
Government and other resource persons also provided valuable primary data for the study. The state of the
incinerators and dumpsites as well as the disposal methods were studied through observation by the researchers.
Additional data was gathered through taking photographs of the sites and interviewing workers (where applicable)
at the different sites visited. Secondary data was obtained from both published and unpublished information on
waste burning in Kenya and elsewhere in the world. Previous studies carried out on medical and municipal waste
disposal at the global, regional, national and local levels were reviewed. Descriptive analysis was used to
summarize the collected data. Scope of the Study The study was a preliminary investigation, intended to open the
way for further detailed investigations of the same sites and other similar sites in the country. 2 The
convention came into force on 17th May 2004. Kenya became a party to the convention on 23rd December 2004
• 12. Preparation for the Study Staff recruitment and training: Two research assistants were recruited and
trained for fieldwork. Stakeholders’ identification: Various stakeholders were identified and approached for
their views on the issue under investigation. These stakeholders included: i. Members of public within Nairobi
ii. Health care professionals iii. The Occupational Health Officer, Ministry of Health iv. National
Environmental Management Authority (NEMA) v. Kenya Association of Manufacturers vi. Major Supermarkets in town
vii. Private waste handlers viii. City Council of Nairobi Locations of Interest For the study of medical waste
management, researchers chose to visit a few health care institutions based in Nairobi. These were: Kenyatta
National Hospital (KNH), Nairobi Hospital, Mater Hospital and Forces Memorial Hospital. For the study of
municipal waste management, the researchers visited the Nairobi City Council’s dump site at Dandora as well as
several residential estates in Nairobi including: Jericho, Kariobangi, Huruma, Ngomongo, Baba dogo, Muthurwa,
Shauri moyo, Kimathi, Buruburu, Lucky Summer and Korogocho all in Eastlands; Westlands, Kangemi, Uthiru and
Kikuyu along Waiyaki Way in the West side of Nairobi, and Kitengela to the south of the city. AREA OF STUDY
Nairobi is the largest town in Kenya and also the country’s capital city. It covers an area of 696 km² and
currently has a population of 2,143,254 and population density 3,079 per square kilometre (GoK, 2000). At 1.5 0
south of the equator, Nairobi is a tropical city. Its altitude of 5,000 to 6,000 feet means that the climate is
temperate. Rainfall is divided between two rainy seasons: the short rains fall in November and early December,
and the long rains between April and mid-June. Because it is virtually on the equator, Nairobi has a constant
twelve hours of daylight per day all year round. The sun rises at 6.30 – 7.00a.m and sets again at 6.30 – 7.00
p.m. 6
• 13. The average day-time temperature varies only slightly throughout the year, ranging from 85°F (29°C) in
the dry season to 75°F (24°C) during the rest of the year. At night, however, temperatures can drop to as low
as 48°F (9°C), though rarely lower. Founded as a last halt before the Highlands for railway engineers in the
early 1900s, Nairobi, which was then just a few shacks and tracks, now covers 696 square kilometres. This figure
includes 120 square kilometres of the Nairobi Game Park and all of Jomo Kenyatta International Airport. Central
Nairobi barely makes up five square kilometres. LITERATURE REVIEW Tangri (2003), notes that despite intensive
scrutiny over many years, much remains unknown about the releases of pollutants from waste-burning activities.
Waste burning produces hundreds of distinct hazardous by-products of which only a handful of them have been
studied thoroughly. Hundreds remain unidentified. Connett (1998) identifies some of the toxic emissions of
incineration. These include: hydrogen chloride, nitric oxide, heavy metals, dioxins, furans and other U-POPs,
fly ash, bottom ash, stack gas, fugitive emissions plus other residues. Polythene bags and plastics, including
PVC items, make up approximately 225 tonnes out of the 2000 tonnes of solid waste generated daily in Nairobi
(KAM, 2003). This represents about 11% of total waste generated daily, while 75% comprises biodegradable waste
that can be composted. The remaining percentage is made up of other recyclable materials such as textiles, metal
and glass making up 2.7%, 2.6% and 2.3% respectively. Open burning of municipal waste is widely used by the
residents of Nairobi, as a means of disposing solid waste. 7 The following facts regarding plastics were
identified from literature: • According to KAM, consumers and end users are the ones who cause environmental
pollution from plastics; • Not all plastics emanate from the local industry, some is imported; • The plastics
sector currently constitutes approximately 150 industries, and has an annual growth rate of 6%; • Currently,
there are about 70 firms that recycle plastics locally; and • Plastics contribute 28% of all cadmium found in
municipal solid waste and approximately 32% of all lead; substances that are highly toxic to humans and the
environment in general.
• 14. Health Effects Because of the persistent and bio-accumulative nature of dioxins and furans, these
chemicals exist throughout the environment. Human exposure is mainly through consumption of fatty foods, such as
milk. USEPA (2000) in Tangri (2003) notes that 90-95% of human exposure to dioxins is from food, particularly
meat and dairy products. This is because dioxins accumulate in fats and oils3. Their health effects depend on a
variety of factors, including the level of exposure, duration of exposure and stage of life during exposure.
Some of the probable health effects of dioxins and furans include the development of cancer, immune system
suppression, reproductive and developmental complications, endocrine disruption (GAIA, 2003; Connett, 1998;
Luscombe and Costner, 2003). The International Agency for Research on Cancer (IARC) has identified 2,3,7,8 –
TCDD as the most toxic of all dioxin compounds. Environmental and Socio-economic Effects The accumulation of
dioxins and furans in the environment owing to waste incineration activities can reach levels that render
resources unfit for human consumption. Connett (1989), cited in Connett (2003), reports of an incident in
Netherlands where 16 dairy farmers downwind of a huge incinerator in Rotterdam could not sell their milk because
it contained three times higher dioxin levels than anywhere else in Netherlands. Even low doses of dioxins are
very toxic. In 1998, the WHO lowered its recommended Tolerable Daily Intake (TDI) of dioxins from 10 picograms
TEQ per kilogram of bodyweight per day (pg/kg/day) to a range of 1-4 pg/kg/day (Van Leeuwen and Younes 1998).
According to studies conducted in Netherlands, prenatal exposure to typical daily intake of dioxins and PCBs has
effects on neurodevelopment and thyroid hormones. Deficits of up to four points in IQ and increased
susceptibility to infections in 42 month old children exposed to typical daily intakes of dioxins/PCBs were
observed (Patandin 1999). Incineration produces residues that require treatment and/or disposal, most often in a
landfill. Incinerator ash – either as bottom ash or fly ash – is highly toxic. Tangri (2003) observes that
handling of this ash raises serious concerns because workers are often exposed to the ash, sometimes with little
or no protective gear. In India just like in Kenya, Toxic Link (2000), notes that incineration is rudimentary
and most incinerators are single chambered with a smoke stack. Major reasons for dioxin emissions from such
waste incinerators are: 8 3 WHO (1999) points out that dioxins are highly persistent for they breakdown very
slowly and have a half-life in human body of about 7 years.
• 15. • almost all of them burn mixed waste; • due to lack of enforcement and monitoring, most of the hospitals
are incinerating their plastic waste and also waste treated with chlorinated disinfectant; • many of the
incinerators still have single chambers, in spite of the fact that the installation of double (secondary)
chambers is needed to eliminate volatile substances by better combustion; and • most of the incinerators do not
operate under stipulated temperature. Under the regulations, primary chambers should operate at 850º C and
secondary chambers should operate at 1000º C or more. Tangri (2003) has enumerated several problems particular
to transferring incineration technology to the developing countries. These problems include: • lack of
monitoring – no ability to regularly monitor stack emissions or 9 incinerator ash toxicity; • lack of technical
capacity to test releases – not able to conduct tests for dioxins and other pollutants; • lack of secure
landfills for ash – toxic incinerator ash dumped in, at best, an unlined pit, where it runs the risk of
contaminating groundwater. Access to the ash land not controlled; • corruption4; • shortage of trained personnel
– necessary number of trained Manpower to manage incinerator operations; • budgetary constraints – hinder
maintenance and replacement of key incinerator functions; and • differing physical conditions and lack of
robustness of technology – where incinerator technology imported from the west is not appropriate to the
Southern conditions. Other Pollutants from Incineration In addition to dioxins, polychlorinated biphenyls (PCBs)
and Hexachlorobenzene (HCB), incinerators are sources of other halogenated organic compounds, toxic metals and
greenhouse gases to name but a few5. Toxic metals released from incineration activities include: Mercury, Lead,
Cadmium, Arsenic, Chromium, Beryllium, Antimony, and Manganese. Stanners and Bourdeau (1995), cited in Tangri
(2003), give a worldwide atmospheric emissions estimate of trace metals from waste incineration; this is
summarized in the Table 1 below: 4 Where there is corruption the likelihood of installing substandard equipment
for kickbacks is high. 5 [Blumenstock et al (2000) in Tangri, (2003)].
• 16. 10 Table 1. Worldwide atmospheric emissions of trace metals from waste incineration Atmospheric emissions
from waste incineration Metal 1000 tons/year % of total emission Antimony 0.67 19.0 Arsenic 0.31 3.0 Cadmium
0.75 9.0 Chromium 0.84 2.0 Copper 1.58 4.0 Lead 2.37 20.7 Manganese 8.26 21.0 Mercury 1.16 32.0 Nickel 0.35 0.6
Selenium 0.11 11.0 Tin 0.81 15.0 Vanadium 1.15 1.0 Zinc 5.90 4.0 Source: Stanners and Bourdeau (1995), in Tangri
(2003), page 17 Public Opposition to Incineration Waste incineration is unpopular in many countries. In the USA,
for example, since 1985, over 300 trash incinerator proposals have been defeated or put on hold due to public
opposition, and several large engineering firms have pulled out of the incinerator business altogether (Connett
1998). In Michigan, all but one of the 290 medical waste incinerators in the state closed down rather than
attempt to meet federal emissions limits imposed in 1997 (Tangri 2003). Tangri (2003) reports that in 2001
alone, major incinerator proposals were defeated by public opposition in France, Haiti, Ireland, Poland, South
Africa, Thailand, UK, Venezuela. Even in poor countries such as Bangladesh, public opposition to incinerators
has yielded changes. A proposal by an American company to build a power station which would burn trash shipped-
in from New York City to Khulna in Bangladesh was defeated by public opposition (Connett 1998). In 2000, GAIA
was launched. GAIA members work both against incineration and for the implementation of alternatives Tangri
(2003). Kenya Eggs Study A study in early 2005 on egg-sampling by ENVILEAD and Arnika (under the Dioxin, PCBs
and Waste Working Group of IPEN) found eggs collected around the Dandora dumpsite in Nairobi, Kenya, to have
dioxin levels over 6 times higher than the EU dioxins limits for eggs. In addition, the sampled eggs
• 17. exceeded the proposed WHO limits for PCBs by more than 4-fold (Fig. 2). It is estimated that the Dandora
open dumpsite handles 803,000 tons of waste per year (National inventory of POPs, 2004). Fig. 2: Mean values
(PCDD/Fs) found in Eggs Sampled from Dandora – Kenya, compared with levels in eggs from other contaminated
sites in the world Source: The Egg sampling report by ENVILEAD and ARNIKA (2005) STUDY FINDINGS Basic Findings
The study made several basic findings that will be important in the search for waste management solutions in
Nairobi and elsewhere in the country. Among these are: a. The nature of consumer demand: In the Kenyan market,
where more than half the nation’s population lives below the poverty line, plastic constitutes a very
attractive option as the material of choice for numerous domestic, medical and industrial products. The business
organizations that researchers were able to visit, such as supermarkets and plastics’ manufacturers, confirmed
cost attractiveness of plastic to local consumers. There is therefore a basic market-based challenge to the
problem of waste management, 11
• 18. comprising rational economic action linking consumers, manufacturers and traders. b. Legal framework and
administrative capacity: Waste is a necessary outcome of any production and consumption process. But in the real
world, the quantity of waste a society produces has implications on the resources the society requires for
managing the same. It is therefore necessary, especially where resources for waste management are very limited,
to institute measures that reduce the overall quantity of waste generated, with a special focus on products such
as plastics that are especially problematic in safe disposal. Proper waste management requires enforcement of
the existing legal provisions. The study established that Kenya has a sound legal framework (EMCA, 1999) for
guiding the utilization of BEP and BAP in waste management. However, the law is not enforced to the letter. It
was established that most health institutions, including KNH, do only rudimentary segregation of waste. Of the
hospitals visited, only Nairobi Hospital and Mater Hospital had a thorough waste segregation system. The
existence of suitable legal guidelines is however only one part of the requirements for a proper system of waste
management. The other part has to do with administrative capacity to enforce such law. The study established
that the City Council, which has the legal responsibility for managing solid waste in the city, has an alarming
lack of administrative capacity for this role. For example, the Dandora dumpsite, which is supposed to be under
the management of the Council, is a veritable health and ecological time-bomb for Nairobi and its environs. 12
General Findings The following were the study’s general findings: I. The level of public awareness on the
adverse effects of waste burning activities and U-POPs among the residents is pathetically low. A majority of
the study’s respondents could not link any ill-health to incineration activities and U-POPs as a major health
threat; II. All the main health institutions in Nairobi such as KNH, Nairobi Hospital, Mater Hospital, and
Forces Memorial Hospital either have their own incinerators or hire the services of one. In addition however
some of the institutions are involved in open air burning. For instance, the biggest hospital in Kenya (KNH)
burns some of its waste mostly consisting paper, plastics, clothing etc – usually considered to be of low risk
– in an open pit in front of the incinerator;
• 19. III. Open burning of municipal waste is widely used by the residents of Nairobi, as a means of disposing
solid waste. In a survey of two blocks’ area around Pumwani in Eastlands, Nairobi, eight small open air waste
burning sites were counted, all of which had assorted plastics; IV. The incinerator at Kenyatta National
Hospital, which is situated just a few metres upwind from the residential homes of low cadre staff of the
hospital and medical students’ hostels, operates at temperatures between 350°C and 650°C and has no APCD. The
incinerator emits noxious fumes that are carried to the homes and hostels, causing considerable distress to the
residents; 13 Plate: Kenyatta National Hospital open dumpsite: At the background are hospital staff quarters V.
The dioxin-rich bottom ash from incinerators around Nairobi is normally deposited at the Dandora dumpsite; VI.
The Dandora dumpsite constitutes the most prominent, and challenging, manifestation of problems arising out of
the waste-burning pattern of practice in Nairobi; VII. The level of waste recovery, reuse and recycling is
grossly inadequate. For example, only 1% of plastics are recycled (KAM, 2003); VIII. The legal framework
regulating waste burning activities is sound. However, the enforcement of the law is weak; and IX. The Nairobi
City Council lacks the capacity to manage the waste generated in the city effectively; Table 2 below shows a
number of major companies in Nairobi that dump their mixed waste in Dandora dumpsite. It is therefore necessary
for the private sector to be involved in the search for waste management solutions as they are major
contributors of waste.
• 20. 14 Table 2. Waste disposal methods for various major companies in Nairobi Company/organization Contents
of waste Estimated weight in tons/month Method of disposal Jomo Kenyatta International Airport (JKIA) Mixed
aircraft waste 300 Waste dumped in Dandora dumpsite Kenya Revenue Authority staff quarters Household/domestic
waste 285 Waste dumped in Dandora dumpsite Kenya Shell Company (Shell & B.P. House) Commercial waste 60 Waste
dumped in Dandora dumpsite Kenya breweries Household and commercial 200 Waste dumped in Dandora dumpsite NAS
Airport Services Food & food packaging 350 Waste dumped in Dandora dumpsite Swan Industries Commercial &
industrial waste 350 Waste dumped in Dandora dumpsite Kenya Shell aviation Stations Commercial & food waste 72
Waste dumped in Dandora dumpsite Orbit Chemicals Polythene sheet cuttings & plastic drums – • Plastics recycled
• Paper & drum sold • Other waste dumped near Athi River. Source: Kenya National Inventory of POPs (2004)
Findings on Health Effects and Exposure Pathways The study was not able to carry out a comprehensive
investigation into the health consequences of the incinerators and open air burning sites visited. There were
however complaints about chest complications and serious smoke irritation for those living downwind from the KNH
incinerator, as well as from those living around the Dandora dumpsite. The main exposure pathways for any
contamination from the sites visited in the study are: • Inhalation of the pollutants-infested smoke and fly ash
carried across by the wind; • Consumption of animal products such as meat, milk and eggs from animals feeding
within and around the sites; • River water from a river flowing next to the Dandora dumpsite and serving
numerous people downstream on its way to the Indian ocean; and • Ground water reserves affected by leachate from
the Dandora dumpsite. It is worth noting that some categories of people are at higher risks of exposure to
dioxins than others. These include children, infants, some workers, people
• 21. who eat fish as a main staple of their diet and people who live near dioxin release sites. CHEJ (1999)
observes that these groups are likely to be exposed to at least 10 times as much dioxin as the general
population. CHALLENGES TO THE STOCKHOLM CONVENTION: RESPONSIBLE PARTIES – KENYA POPs and Scientific Development
The existence of POPs worldwide is one of the best illustrations of the Frankenstein nature of scientific and
technological development. While progress in science and technology has greatly increased humanity’s power to
modify its environment for its benefit in ways previously unimagined, the same progress has created threats of
similar magnitude to humanity and the planet as a whole. The last century has been called an “era of chemicals
”, where more than 18 million chemicals were synthesized and about 100,000 of them came into commercial use
(Toxics Link 2000). It was not until the publication of Rachel Carson’s book, “The Silent Spring”, that the
general public’s attention was drawn to the dark side of the chemical revolution. The Stockholm Convention is
in many respects an effort to interpret Carson’s thesis into social action. The broader framework of the
Stockholm Convention’s objectives should be viewed as completing the loop of knowledge in chemistry, through
developing the institutional capacity to control the real and potential danger of chemicals. The realization of
the Stockholm Convention’s mandate would be the coming of age of the chemical revolution. As Isaac Asimov put
it, “The saddest aspect of life right now is that science gathers knowledge faster than society gathers wisdom.
” POPs and Less Organized Countries The above-outlined problems are relevant to Kenya and other Less Organized
Countries (LOCs). In addition though, LOCs face several challenges that are unique to their special
circumstances. Among these is the sheer pressure of survival priorities. The immediacy of hunger, debilitating
disease, social and economic dislocation, and other such concerns that affect large sections of society in LOCs
is such that an issue like that of POPs is unlikely to find a place at the fore of the national agenda. The
psychological environment of desperate social and economic circumstances has a tendency to promote fatalism and
other behavioural tendencies that are not conducive to organized long term action based on people’s faith in
their ability to 15
• 22. influence the course of their destiny. A good illustration of this is the challenge that the behaviour-
change message in the HIV/Aids campaign in Africa has faced, despite the powerful and very public nature of the
AIDS pandemic. Galvanizing community action for the POPs eradication campaign shall require very well thought-
out strategies, and competent leadership. In addition to the problem of priorities, LOCs face a big challenge of
organizational capacity in the campaign against POPs. The low levels of organizational capacity in LOCs
translate to challenges in administrative competence, financial resources, technological resources, monitoring
ability and other such key requirements for an effective POPs eradication campaign. With sufficient support
there are specific organizations within LOCs that can make a real and positive difference in such a campaign. In
the long run, in order for any major campaign such as that of the Stockholm Convention to be truly successful,
the campaign has to be done in the context of an overall sustainable development strategy. Such a campaign would
have implications going beyond specific issue of POPs. For example, a successful POPs elimination campaign may
need to involve fundamental changes in the agricultural sector, waste management approaches and legislation (as
well as enforcement mechanisms) dealing with chemical safety in general. Such an agenda requires very
considerable organizational capacity both within the public sector and civil society, which is the big challenge
for LOCs. 16 The crippling nature of incinerator debt. Capital costs of incinerator projects for instance, drain
the resources of LOCs and increase their indebtedness through the need for foreign financing to build and
maintain such facilities not forgetting continued reliance on manufactured products from other nations. Instead
of allowing nations to develop new industries and reduce foreign imports, incinerators transform these resources
into smoke and ash. Analysis by a local environmental group in Miljoteknik Zychlin, Poland revealed that the
debt for the US$5million proposed incineration facility would have taken the community of 14,000 residents over
100 years to repay! – Brenda Platt (2004)
• 23. The Environment and Economy While the growth of science and technology has an important bearing on the
dangers to the environment that the Stockholm Convention and similar other Conventions seek to counter, it is
the market economy that provides the framework within which the power of science and technology can be projected
into the world. As is the case with science, measuring economic development in a one-dimensional manner, purely
in terms of (monetary) returns on investment and not the overall impact of the concerned economic activity on
society and the natural environment, is unsatisfactory. In economics, problems arising from the undesirable
consequences of economic activity that are not captured in the pricing structure of products are called negative
externalities. Negative externalities are those situations arising from economic activity that create costs to
the society that are not reflected in the balance sheets of the concerned businesses. For example, in pricing
its products, a given organization may include the cost of labour, energy, marketing, finance and other such
inputs but leave out the cost (borne by the society) of medical and other costs directly attributable to harmful
effects of the organization’s products. POPs ought to be treated as an aspect of the problem of externalities
in economic theory, and solutions sought within the framework of approaches developed in the discipline of
economics to deal with this problem. ALTERNATIVE PRACTICES Other than incineration, landfilling and composting
are alternative methods of waste disposal used in the country, although to a minimal extent. More often than
not, individuals and community-based organizations (CBOs) are the ones involved in composting biodegradable
waste mostly on a commercial basis. Landfilling is commonly practiced in the smaller health facilities such as
District hospitals, health centers and clinics, but most of these landfills are not built to standard. Other
landfills in the country are situated in Mombasa and Nakuru for municipal waste disposal, built through the
assistance of Agence Francaise de Développement (AFD), a French operation that works through the government.
Alternative Technologies for Hazardous Waste Treatment In developed countries, non-incineration technologies for
hazardous waste treatment are available; these include several processes summarized by Crowe and Schade (2002)
in Tangri (2003) in Table 3. 17
• 24. 18 Table 3. Non-Incineration technologies for hazardous waste treatment Technology Process description
Potential Advantages Current Uses Base Catalyzed Dechlorination Wastes reacted with alkali metal hydroxide,
hydrogen and catalyst material. Results in salts, water and carbon. Reportedly high destruction efficiencies. No
dioxin formation. Licensed in the United States, Australia, Mexico, Japan, and Spain. Potential demonstration
for PCBs through United Nations project. Biodegradation (in enclosed vessel) Microorganisms destroy organic
compounds in liquid solutions. Requires high oxygen/nitrogen input. Low temperature, low pressure. No dioxin
formation. Contained process. Chosen for destruction of chemical weapons neutralent in the United States.
Potential use on other military explosive wastes typically used for commercial wastewater treatment. Chemical
Neutralization Waste is mixed with water and caustic solution. Typically requires secondary treatment. Low
temperature, low pressure. Contained and controlled process. No dioxin formation. Chosen for treatment of
chemical agents in the United State. Electrochemical Oxidation (Silver II) Wastes are exposed to nitric acid and
silver nitrate treated in an electrochemical cell. Low temperature, low pressure. High destruction efficiency.
Ability to reuse/ recycle process input materials. Contained process. No dioxin formation. Under consideration
for chemical weapons disposal in the United States. Assessed for treatment of radioactive wastes.
Electrochemical Oxidation (CerOx) Similar to above, but using cerium rather than silver nitrate. Same as above;
cerium is less hazardous than silver nitrate. Demonstration unit at the University of Nevada, USA. Under
consideration for destruction of chemical agent neutralent waste. Gas Phase Chemical Reduction Waste is exposed
to hydrogen and high heat, resulting in methane and hydrogen chloride. Contained, controlled system. Potential
for reprocessing by-products. High destruction efficiency Used commercially in Australia and Japan for PCBs and
other hazardous waste contaminated materials. Currently under consideration for chemical weapons destruction in
the United States. Potential demonstration for PCB destruction through United Nations project. Solvated Electron
Technology Sodium metal and ammonia used to reduce hazardous wastes to salts and hydrocarbon compounds. Reported
high destruction efficiencies. Commercially available in the United States for treatment of PCBs. Supercritical
Water Oxidation Waste is dissolved at high temperature and pressure and treated with oxygen or hydrogen
peroxide. Contained, controlled system. Potential for reprocessing by-products. High destruction efficiencies.
Under consideration for chemical weapons destruction in the United States. Assessed for use on radioactive
wastes in the United States. Wet Air Oxidation Liquid waste is oxidized and hydrolyzed in water at moderate
temperature Contained, controlled system. No dioxin formation. Vendor claims 300 systems worldwide, for
treatment of hazardous sludges and wastewater Source: Crowe and Schade (2002) in Tangri 2003, page 62
• 25. From the study, we found out that none of the above stated technologies is used in Kenya. RECOMMENDATIONS
The study proposes the following measures: I. Additional studies should be undertaken to acquire additional and
more detailed information about the waste burning and incineration and its consequences in Kenya. This includes
analysis and quantification of U-POPs 19 in biotic and abiotic systems and their impact on public health; II. In
line with Article 10 of the Stockholm Convention, Public information, awareness and education on U-POPs should
be carried out, for a well informed citizenry will make a big contribution on efforts geared towards
elimination/ and reduction of the U-POPs. Proper education and training in waste management must be offered to
all stakeholders in a way best suites their respective circumstances and builds their understanding and changes
their behaviour accordingly; III. Subsidiary legislation addressing waste incineration should be enacted under
the Environmental Management and Coordination Act (1999). This should guard against indiscriminate burning of
waste; IV. A buy-back scheme for used plastics should be instituted. This should not be difficult to do because
the plastics industry is willing to manage waste sites in all major population areas where the manufacturers
will buy plastic waste from the general public. Such collection centres would be set up and fully funded by the
same manufacturers (KAM, 2003); V. A national campaign, financed by the plastics industry should be launched,
giving the public exact details of where to take their plastic waste for recycling. Supermarket chains should
also be encouraged to allocate bins in their branches where customers can bring back plastic carrier bags and
other items for recycling; VI. A zero waste program should be introduced immediately and eventually developed
into policy. It has been tried and tested in other countries and it is rapidly gaining acceptance the world
over. Within the zero waste program, there should be a rigorous national campaign lobbying for an end to open
burning and incineration of waste and in particular waste that contains PVC; VII. Waste segregation at source
should be the standard practice in all households and medical facilities. The current waste management practice
in which waste materials are all mixed together as they are generated, collected, transported and finally
disposed of should be stopped. If proper segregation is achieved through training, clear standards, and tough
enforcement, then resources can be turned to the
• 26. management of the small portion of the waste stream needing special treatment6; VIII. A policy of
Extended Producer Responsibility (EPR) should be put in place. The basic concept of EPR is that firms must take
responsibility for their products over their entire life cycles (Tangri 2003). This is in harmony with the
“Polluter Pays” principle of the Stockholm Convention; IX. Statutory regulations to force manufacturers to use
at least 15% recycled plastics in their non-food products should be imposed. In this way demand for plastic
waste will be created therefore leaving little if anything for disposal. Since to install capacity for recycling
is expensive however, the plastics’ industry should be given tax incentives for the exercise; X. Cleaner
production based on a circular vision of the economy should be encouraged. Cleaner production aims at
eliminating toxic wastes and inputs by designing products and manufacturing processes in harmony with natural
ecological cycles (Tangri 2003); XI. Product bans ought to be made for certain categories of manufactures.
Products and packaging that create waste problems (non-recyclable or hazardous- such as polyvinyl chloride –
PVC) for the society should not be allowed to enter into the economy. Bans are appropriate for materials that
are problematic at every stage of their lifecycles (Ryder 2000 in Tangri 2003); XII. Infrastructure for the safe
disposal and recycling of hazardous materials and municipal solid waste should be developed. Approximately 50%
of all waste is organic, and can therefore be composted. Another large segment of the remainder can be recycled,
leaving only a small portion to be disposed. The remaining portion can then be disposed through sanitary
landfills, sewage treatment plants, and other technologies. To ensure continuity and clarity in the proposed
recommendations, clear plans and policies on management and disposal of waste should be developed. This should
be followed by integrating them into routine workers’ training, continuing education and evaluation processes
for systems and personnel. Involvement of all stakeholders including public interest NGOs and other civil
society in developing and implementing a waste management scheme is necessary for successful implementation of
the Stockholm Convention. 20 6 Platt and Seldman (2000), show how comprehensive waste composting, reuse and
recycling programmes generate ten times as many jobs per tonne of municipal waste as do incinerators.
• 27. CONCLUSION The burning of waste as a method of waste disposal in Nairobi clearly constitutes a pattern of
practice which contributes to the release of U-POPs into the environment. As suggested by the term “pattern”,
this practice is a complex process involving economic factors, people’s attitudes, governance issues and other
such components. It is a matter requiring detailed study and much creative effort to address satisfactorily. In
its broader context, the issue of waste management is an aspect of the challenge of sustainable development.
Inability to deal with waste in such a way as it does not harm people or the environment is an indication of an
ecologically unsustainable system of social organization. The challenge of sustainable development is to design
an economic and technological system that is in harmony with ecological principles. The current dominant system
of economic and technological organization in the world is powerful and in many respects very successful. It is
however not a sustainable system and in fact constitutes a veritable danger to the survival of life in the
planet. There is need to review some of the system’s most basic organizational principles, as a way out of the
dangerous trajectory it has set for humanity. The poorly formed social structures and systems in LOCs,
especially in sub- Saharan Africa, may ironically make the best hope for the development of fresh, ecologically
sustainable development approaches. LOCs have the opportunity to build their houses with the special benefit of
a wealth of knowledge of the successes, and follies, of the past. LOCs should proceed to build their societies
with energy and enthusiasm, but with the clear understanding that humanity cannot stand outside, or above, the
ecological order that sustains all other life in the planet. 21
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• 30. 24 ANNEX 1: MAPS 1. Map of Kenya Note Nairobi’s position and the other major towns (the red dots) which
could have similar environmental challenges.
• 31. 25 2. Map of Nairobi The brown patch at the center of White square is the heart of Nairobi. Note the
Nairobi River, which joins the Athi River on the way to the Indian Ocean.
• 32. 26 ANNEX 2: PLATES 1. Dandora dumpsite This is the Western edge of the Dandora dumpsite. The houses in
the foreground are part of the Korogocho slums. In the background is lucky-summer estate. The dumpsite is
surrounded by densely populated residential quarters. 2. Kitengela Town Dump Notice the persons in the way of
the smoke. These are scavengers at the site who work in this environment on a daily basis.
• 33. 27 3. Waste content of the dumpsites Typical contents of dumpsites around Nairobi. Notice the high
proportion of plastics. 4. Medical Waste awaiting incineration (KNH) The maximum temperature of the hospital’s
incinerator on the right is 700ºC
• 34. 28 5. The Nairobi river (foreground) flowing past the Dandora Dumpsite Note the mountain of burnt ashes
in the background
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