Adapting hazardous waste management to the needs of developing countries—An overview and guide to action

Waste Management & Research (1990) 8, 8 7-97

ADAPTING HAZARDOUS WASTE MANAGEMENT TO THE NEEDS OF DEVELOPING COUNTRIES-AN OVERVIEW AND GUIDE TO ACTION David C . Wilson* and Fritz Balkaut (Received December 1989)

Following the recent Basel Convention, increasing emphasis has been placed on technical co-operation to assist developing countries to put in place effective hazardous waste control measures . ISWA, together with other contributing organizations, held in September 1989 a workshop at which case studies of successful hazardous waste management initiatives were analysed . The workshop indicated that a large number of interrelated measures are needed for effective control of hazardous wastes, and that these are best developed gradually in an evolutionary fashion . Measures used by industrialized countries often need to be further adapted for use in other regions . A number of practical first steps were identified that can be used in all countries to initiate effective control . Some general principles to guide the process of adaptation were also formulated . Key Words-Hazardous waste, management, control, disposal, evaluation, developing countries, case studies .

1 . Introduction Hazardous wastes are produced by all countries, irrespective of their state of development . Examples of such ubiquitous wastes might include oils from transportation, redundant pesticides from agriculture, hospital wastes, wastes from ship cleaning, chemical wastes from commerce, mercury from fluorescent lamps and batteries, acids and lead from recycling of motor batteries etc . As industrial development proceeds, hazardous wastes are produced from industries such as textiles, leather tanning, metals mining and processing, metal working and surface treatment, oil refining, chemicals and pharmaceutical manufacture, electronics etc . Until recently, hazardous wastes have rarely been high on the political agenda in developing countries . Nevertheless, the risks to human health and the environment from the uncontrolled disposal of a country's own hazardous wastes may be considerable . The uncontrolled discharge of toxic wastes into water courses may pollute drinking or irrigation water supplies ; uncontrolled disposal with urban wastes in open dumps may pose a health risk to scavengers who obtain their livelihood from sorting the refuse (case study: Kungskulniti) ; and may also pollute groundwater resources . Much international attention has recently been focused on the export of hazardous wastes from industrialized to developing countries . The Basel Convention, sponsored by UNEP, seeks to limit and control such export . Under the Convention, export may only take place if the necessary facilities for disposal do not exist in the country where the *Environmental Resources Limited, 106 Gloucester Place, London WIH 3DB, U .K . tlndustry and Environment Office, United Nations Environment Programme, Tour Mirabeau, 39-43 Quai Andre Citroen, 75739 Paris, Cedex 15, France . 0734-242X/90/020087 + 11 $03 .00/0

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waste is generated. Prior written approval of the importing country is necessary before export is initiated . Export is prohibited to countries that have banned import, to countries that have not signed the Convention, and where proper treatment or disposal facilities do not exist in the importing country . In addition to addressing issues of transboundary transport, the Basel Convention also stresses the need for all countries to introduce programmes to manage their own hazardous wastes adequately . Developing countries often experience great difficulty in controlling hazardous wastes . Their available resources must be concentrated on the most urgent problems . Interim solutions may be required to bring such problems under immediate control whilst more permanent facilities are developed . Even in the long term, there will be a need for solutions which are compatible with the limited resources available . The focus of the Honolulu workshop was on how to adapt existing successful technologies and administrative control systems to the different needs and circumstances of each developing country . The workshop was based on regional case studies and was intended to be illustrative rather than representative . Care was taken to include examples from countries at different stages of hazardous waste control, ranging from those at the very beginning (e .g . Peru, Indonesia, Philippines) to those with relatively well developed management systems (Victoria, Australia) . The case studies illustrate how the principles and theory of hazardous waste management can be applied, but also the difficulty of actually applying those principles in practical situations. Each case study reinforces or confirms some well known general lessons, while many also contribute unique or particular experiences which are not found everywhere . In this overview, we have attempted to draw out from the case studies, and from the workshop discussion, two sets of guidance points, on : (a) the process of adaptation ; and (b) what practical measures to take first . 2. Adapting hazardous waste management methods 2 .1 What are hazardous waste management methods?

These are a mixture of actions and technologies that result in improvements in safety and environmental quality . When such a mixture of actions takes place according to a systematic plan, one talks of a waste management strategy . Table 1 illustrates the most common elements of such a strategy, grouped into three major themes . Management of hazardous wastes is also assisted by complementary arrangements in toxic chemicals control, pesticide policy, hazardous materials transport, marine pollution prevention, and water air pollution control and solid waste management . Where these areas are already subject to separate controls, hazardous waste management will often have to fit in with existing arrangements . 2.2 The evolution of hazardous waste management in industrialized countries

The history of hazardous waste controls in industrialized countries stretches back barely 25 years . In general, controls have evolved as the hazardous waste disposal problem was progressively revealed through the gradual tightening up of water pollution and solid waste control and the discovery of serious pollution from previously uncontrolled disposal sites . In making their initial response to such problems, countries built on what they already had . The greater the initial launching pad, the faster they were able to advance their system of waste control, rather than having to concentrate first on building infrastruc-

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TABLE 1 Hazardous waste management strategy elements* Administrative and legal

Technology

Infrastructure and support services

Standards-environment -waste Discharge limits Disposal permits Waste manifest Transport safety Liability for damage Compensation for damage Export-import controls Dumping offences Enforcement personnel

Cleaner production Recycling Treatment plants Incinerators Landfills Site clean-up Monitoring Specialized transport

Sewers Storage facilities Waste collection Transport services Disposal sites Laboratories and analytical equipment Waste exchange Operator training facilities Consultancy services Chemical emergency services Technical information Public information

table is representative rather than comprehensive and items are not listed in order Other elements may also apply .

* This

of importance .

Lure . Once a number of essential first measures were in place, the process of systematization began . Existing incompatible laws were linked, more comprehensive facility planning began, tracking systems were implemented, and waste minimization initiatives were intensified . Among the examples presented at the workshop, the State of Victoria, Australia (Robinson) reported that the environmental risk from unsafe disposal and transport had been significantly reduced through the development of a systematic industrial waste strategy . The size of the waste stream, particularly liquid wastes, has diminished significantly as a result of tighter controls on discharges and on landfills . Following such controls, better disposal methods are now available for all parts of the waste stream, although high temperature incineration still relies on commercial services in Europe . Services and infrastructure exist to support to an adequate level the technical and regulatory actions required . Control legislation is comprehensive, and sufficiently well enforced to ensure a high level of compliance by industry . The control agency has been restructured along more integrated lines to be better able to carry out surveillance and enforcement . Considerable recent emphasis has also been placed on a formal, enforceable programme of waste minimization . In several European countries, the different political and legal systems have resulted in strategies that differ in some important details . Some countries have emphasized the establishment of treatment facilities, but have so far been less interventionist on waste minimization . Transboundary waste movement to neighbouring countries has been common . In all cases, properly enforced water pollution and waste disposal legislation, backed by good technical and service infrastructures, has enabled countries to make good progress . The evolutionary nature of hazardous waste control is shown schematically by the example in Fig . 1 . This illustrates how a number of initial measures serve as a base for additional initiatives . The sequence of steps will vary from country to country, the one illustrated being based on the experience in Victoria, Australia .



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Integrated system

Chemical controls Waste minimisation "Polluter pays

Waste exchange Waste survey Hazardous waste legislation Transport controls

Dedicated incineration

Household and medical waste controls

Ban liquid landfilling

Physico chemical treatment

Cement kiln incineration

Stabilisation of hazardous wastes

Co-disposal in clay cells 1

Landfills legislation

Co-disposal of hazardous wastes I

Scavenger controls at tips

Trade waste controls

Solvent recycling Water pollution control Nil Sewerage or other provision for sewage

Fig . 1 . Notional steps showing the evolution of a hazardous waste management system . Note that the sequence of steps will vary from country to country .

From experience in Europe, the U .S .A ., Japan and Australia, it is possible to formulate a number of common considerations that are generally found in successful implementations of hazardous waste controls, and which may be useful to developing countries or others in preparing a control programme . These include : • effective hazardous waste management at national level relies on a combination (or "package") of actions and measures, not on a single technical or regulatory initiative ; • the building of support for waste control measures among the public and Government officials is critical to success . However, mere "public relations" initiatives have not succeeded in producing support anywhere so far ; • successful hazardous waste management is a co-operative as well as a coercive exercise which ultimately relies on contributions from a range of Government ministries, industrial bodies and individual companies . There are too many waste sources and too many potential disposal routes to allow effective control by a single body in an uncooperative administration ; • implementation and enforcement programmes must be practical within the limits of resources and skills available, or likely to be available ; • gradually building up successive measures is easier than immediately implementing grandiose master plans . A waste management strategy therefore should include short term actions for immediate implementation and a phased approach to implementing longer term actions .

The workshop also highlighted a number of common constraints and difficulties which may also be relevant to the situation in other countries . These include : • inadequate early identification and quantification of waste arisings and of the extent of environmental problems; • insufficient enforcement of existing pollution and solid waste laws, so that much of the hazardous waste problem remains hidden ;



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the inevitable long delay between recognizing the need for facilities and actually providing them, along with competent personnel. This tends to encourage dumping and waste export ; loss of public confidence in technical solutions due to poor performance of earlier disposal facilities. This loss of confidence leads to opposition to the establishment of new facilities; the complexity of the administrative response needed to control all parts of the waste cycle . Frequently, resources for enforcement are inadequate and administrative responsibilities are fragmented .

2 .3 Implementing and adapting hazardous waste management in developing countries Some developing and newly industrialized countries have already started along the path of implementing and adapting hazardous waste management controls to their own particular circumstances . The case studies serve to illustrate a number of different approaches, of which the following are two examples . (i) In Malaysia (Goh), hazardous waste management has been under an investigation for nearly 10 years . Three major studies have been undertaken by overseas consultants paid for by bilateral aid programmes . A set of national hazardous waste regulations was introduced in May 1989 . Current efforts are focusing on the selection of sites for centralized landfill and treatment facilities . These facilities will be paid for entirely by the private sector . (ii) A rather different approach has been taken in Thailand (Lohwongwatana) . Again, the problem has been under investigation for about 10 years, and there have been three overseas funded studies . At an early stage, attention was focused on effluents produced by the metal finishing and textile dyeing industries as a priority . The Government provided a centralized treatment facility for these wastes as a pilot project, and contracted out the operation of the plant to the private sector . It is hoped that further plants will be built, as well as operated, by the private sector . No governing regulations on hazardous waste control have yet been put in place . Looking at the variety of legislative approaches in developed countries, one may conclude that there is rarely one "right" answer to any one problem, rather several different combinations of measures could be equally effective if they were properly implemented . This implies that a combination of measures that are easily adapted could be considered as an initial useful set, and then be complemented later by other actions . Hazardous waste management methods from developed countries will always need to be adapted to specific local needs and circumstances . This need is highlighted by a number of significant differences between industrialized and developing countries, drawn from the case studies .

•

In industrialized countries, it is normal to expect effluents such as those from the metal finishing industry to be pretreated on site, with the sludges going to a centralized treatment facility for further processing . In many south east Asian countries, at least, this is considered to be impracticable, because the majority of generators are both small and operating in cramped conditions Small generators are the norm . rather than the exception in some countries . For example, in Hong Kong an exemption for generators producing less than 100 kg of hazardous waste per month (as is now the case in the U .S .A.) could possibly exclude more than half the wastes from control .



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D. C . Wilson & F. Balkau • The lack of space for small generators, as in Hong Kong, means that most industries are co-located in multi-user high-rise factory buildings . One response to this situation is illustrated by Chiu, who describes a collaborative approach to providing joint waste treatment facilities by neighbouring tanning factories . Similar but less dramatic problems also exist in Singapore and in export trade zones now being increasingly established in developing countries . • Non-industrial sources of hazardous waste may be important in some developing countries which are at an early stage of industrialization . Examples of ubiquitous problems illustrated in the case studies include stocks of unusable agricultural chemicals accumulated over many years (Marcil), hospital wastes (Pateado Castro), and laboratory wastes . • The nature of the environmental and health impacts of hazardous wastes may be very different between industrialized and developing countries . For example, increasing attention in Europe and the U .S .A . is being given to small generators and to hazardous components in normal household waste, due to concerns over groundwater pollution by landfill leaching . In some developing countries, the priority problem is rather a health risk to scavengers who make a living on open dump sites . Simply sending the scavengers away is not a solution, unless accompanied by other measures to provide them with an alternative source of income (Kungskulniti). • Climatic differences may require changes in waste handling, and in the design or location of facilities . For example, air drying of sludges is difficult in wet tropical climates (Soponkanaporn) . The siting and design of landfill sites in a dry region may require less strict standards to achieve the same objectives as in wetter climates . • Transport network inadequacies may mean that national solutions are not feasible in some countries, with a greater emphasis being required on local or regional solutions . This again reinforces the need for appropriate small scale solutions (Makarim) . • Unsophisticated Government bureaucracy may also mean complex "cradle to grave" control systems ae difficult to implement . Makarim (Indonesia) considered as a major priority that of finding simpler and more implementable control systems.

Overall, the challenge is to select locally appropriate control methods and technologies, while at the same time still profiting from the long-term experiences and sometimes costly mistakes of industrialized countries . 3 . What practical measures to take first In considering what practical measures to take first, the workshop has enabled us to set out both some guiding principles and some practical first steps, which are now discussed in turn . 3 .1 Some guiding principles

(a) It is better to do something than to investigate for too long Two particular examples are highlighted in the case studies . The first concerns the level of detail and accuracy required from an initial estimate of waste types and quantities (Barnard, Monahan) . The point is made by Soponkanaporn, who runs the waste treatment facility in Bangkok, that no matter how well you do the initial survey, an accurate picture of the quantities and types of wastes will only be achieved once you have an operating facility . On the other hand, action cannot be taken if absolutely no information is available .



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A related point is that it is necessary to develop facilities simultaneously with the regulations . Examples are provided by Lohwongwatana, de Bruin and Razzell of (interim) facilities which allow wastes to be treated and the generators to be identified, while a legal framework is being developed .

(b) It is necessary to provide some money up front if actions are to take place The sums of money required are not necessarily large, but they have to be strategically applied so as to get the best results . The initial expenditure should perhaps be to identify and publicize the problem so as to build support in principle for some type of action . The second stage involves spending money on training staff and on studying the options for action (see below) .

(c) It will in most cases be necessary to use both "carrot" and "stick" A combination of punitive and supportive actions is more likely to be effective than either method on its own . Legislation will prescribe (and proscribe) certain actions, providing a "stick" . However, at least initially, it is advisable also to show support for industry by providing a "carrot" . This could be by subsidizing treatment costs (Lohwongwatana), or financially supporting waste minimization by, for example, providing free technical advisory services, operating a waste exchange and/or publishing a technical handbook (Robinson) .

3 .2 Useful first steps The need to learn what your problem is must not become an excuse for taking no action . A number of practical steps should, in total, achieve an early improvement in the hazardous waste situation, at a relatively modest effort and cost . It is emphasized that these steps should be pursued in parallel rather than in any particular sequence . In particular, while it is necessary to have an appreciation of waste quantities and their environmental impact, care must also be taken to ensure that the first steps lay the foundations for a more systematic approach to hazardous waste management in the long-term .

3.2 .1 Learn as much as you can about your local situation Useful elements to learn about include :

• as much information as possible on actual environmental damage caused by poor hazardous waste management, for example, poisoning, fires, fish kills, damage to sewers and so on. Results of environmental quality monitoring, and indirect indicators such as unsafe storage and transport, leachate escape, missing wastes . This information is essential in order to convince politicians and others of the urgent need for action to control hazardous wastes ; • an estimate of hazardous waste quantities, based on actual measurement, on analogy, or on predictive methods; • the nature of wastes which are likely to occur . It is necessary to understand industrial processes, and it is very useful to go into industry in order to get a feel for their problems and wastes . A complementary approach is to compile a rough inventory of chemicals used, manufactured or imported . Several of the case studies focus on the question of how to estimate waste quantities . Barnard discusses a rapid assessment technique, while Monahan compares and contrasts the results from rapid assessment, a survey of generators and a survey of the existing



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disposal outlets . Benavides reports on the difficulties of carrying out an industry survey, while both she and Goh emphasize the need for personal visits rather than relying solely on a postal or telephone questionnaire approach . The overall conclusion from the workshop discussion has already been summarized in Section 3 .1, that is it is better to do something (establish facilities) than to investigate for too long . It is only when wastes are being delivered to a facility that it is possible to be relatively precise regarding both quantities and qualities . The above information could usefully be compiled as a series of short reports for easy reference . It is important however not to make report preparation the primary exercise . 3.2 .2 Designate the responsible persons for investigating and resolving hazardous waste problems . Commence a programme of staff training A comprehensive training process is important in building up expertise and contacts . A particularly important factor is the ability to guide and supervise consultants, both foreign and local . While it is tempting to hire consultants at an early stage to overcome staff shortages, this is not always successful if local decision-makers are unable to assess their recommendations . Excessive reliance on donations of "expert" studies or equipment, both of which may turn out to be inappropriate for local conditions, should be avoided .

3 .2 .3 Put into place, or improve and implement controls over water pollution and solid waste disposal In the absence of controls, it is likely that many hazardous wastes will be disposed of to water courses or to open dumps without being observed . Effective control over hazardous waste must therefore proceed simultaneously with the implementation of controls over water pollution and solid waste disposal . It is only when such controls are implemented that the true nature of the hazardous waste problem will be revealed . Merely introducing controls is not enough . Those controls need to be properly enforced, and there must also be some legal disposal option available to companies for disposal (see next Section on interim arrangements) . It is at this stage that the control authority's inspectors will rapidly gain expertise and experience in solving individual industry problems . The true size of the hazardous waste stream will also be more easily estimated .

3 .2 .4 Interim measures of waste disposal The considerable immediate relief that interim arrangements for hazardous waste treatment or disposal can give should not be underestimated . In many of the case studies cited here, such arrangements have allowed a real reduction in immediate risk . Options include : • co-disposal in municipal waste landfill sites of, for example, asbestos waste

(suitably packaged and handled), treatment plant sludges, or organic chemicals of only moderate toxicity (de Bruin, Nash) . It must be emphasized that it is only possible to carry out co-disposal safely at a controlled landfill site, not on an open dump ; • solidification of selected hazardous wastes prior to landfill (Razzell) ; • chemical treatment off site of electroplating and textile effluents (Lohwongwatana) ; • co-incineration of combustible oily wastes, pesticides or similar materials in cement kilns (Ravishankar, Marcil) ;



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• export to approved overseas facilities of difficult wastes such as PCBs for incineration (Robinson, Nash, Goh) ; and

• concrete entombment of non-treatable toxic wastes (de Bruin, Razzell) . The point was made earlier that, while some basic estimates of waste quantities must be made before even interim facilities can be established, it is not recommended to study the problem to the point of exhaustion before taking action . In this respect, advice of experienced local and perhaps international personnel may be useful in deriving first estimates . Interim solutions allow early measurements to be made of the waste stream . They also help to reveal the identity of waste generators, who, once known, will inevitably be within the catchment of future permanent facilities . A better knowledge of the size and nature of the waste stream allows a more accurate prediction of the types and size of such future facilities . Interim facilities are also a useful way for management and operational staff to gain experience in waste handling, with public relations and with industry liaison . Despite the immediate relief given by interim solutions, it is important that they should be seen as a first step, leading on to more permanent measures . Suggested guidelines for ensuring that interim arrangements play a useful temporary role, but do not come to dominate the programme, are :

• keep interim solutions as short term measures with a firm deadline ; • allow for later recovery of (landfilled) wastes by keeping them segregated if possible, and maintaining a record of their location (de Bruin) ;

• ensure that there are effective limitations on after-use and re-development of the site . Assign responsibility and resources for perpetual care of landfill sites until such time as their permanent security can be guaranteed ; and • ensure a level of operational control as strict as that which would apply to permanent facilities . Insist on proper record-keeping of waste quantities and operating conditions . Most of the above arrangements concern treatment or disposal operations . Interim arrangements for regulatory and administrative arrangements are less common . They are also less desirable as such procedures are less easily able to be terminated once their usefulness has passed . Temporary regulations can cause considerable uncertainty and confusion . 3 .2 .5 Early measures of waste minimization It is important to establish some early initiatives to reduce the waste stream . This will do much to attract support from disparate interest groups, and will clearly indicate the long-term goals to industrialists (Robinson) . There are definite benefits to control agencies in familiarizing staff with such programmes . Some possible early actions include :

• establishing, free of charge, an industry liaison officer to advise individual small companies on their problems . Advice can then be given on possible process changes, as well as opportunities for recycling and re-use . This is also a means by which the authorities can begin to understand the real problems and needs of industry ; • establishing a waste exchange, preferably as a co-operative venture with a suitable industry body or association ; • sponsoring, again jointly with industry bodies, an award scheme for waste abatement, clean technologies and products, and environmental management (one such a scheme is operated by the European Community) ; and • providing an incentive scheme whereby the retrofitting of older industrial equipment attracts a subsidy .



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These measures can usefully form part of a more general initiative o improve pollution control in industry . 3.2 .6 Commence very early with public and decision maker awareness and education

Initial public education should centre on explaining the situation to journalists, politicians, and NGOs . A major role is also to brief other Government departments who may need to support waste management measures . One important group are major Government controlled industries, including military installations which will soon need to change their operations . It is almost certain that several joint studies will be needed to document the extent of their problems and the options available . A series of "fact sheets" has been successfully used (Canada, Australia) to present important issues in a simple way . Topics include "why control is necessary", "where wastes come from", "why they are hazardous", "what are the issues", "technical measures", "regulatory measures", "waste minimization", "export-import aspects", "public consultation procedures", and so on . Consultation with industrial associations (and ministries) should be approached with care . In particular, the impact of waste controls, and the national consequences of not imposing them, need to be carefully summarized . Industry is afraid of uneven enforcement of regulations as well as the direct consequences of the regulations themselves . It is important to avoid any discussion on specific sites until a good dialogue on the more strategic aspects of waste control has occurred . 3.2 .7 Obtain independent, outside advice regarding both the problems and the treatment options

Independent review and advice by experienced outside practitioners can assist local authorities in coming to a decision about what initiatives are needed . Particularly valuable is "horizontal cooperation", whereby personnel from one developing country help those from another . An example is the Peruvian case study (Benavides), which was aided by an official from CETESB, the environmental agency in Sao Paulo, Brazil . In view of the difficulty of transferring experience in the early stages of a country's learning cycle, it is preferable initially to have a series of short-term consultancies on specific well defined topics, rather than a single massive study . Training needs to be integrated with advice, as it is essential to have at least a core of staff already trained to be able to negotiate with the consultant . 4. Conclusions The diverse experiences of the countries represented at the workshop reflect their different conditions and contexts . It is not possible to discern a single formula for success that other countries can follow . Nevertheless, several clear conclusions can be noted . First, the hazardous waste situation in many countries shows marked differences to those experienced in industrialized nations . Even where problems appear to be similar, the lack of resources and infrastructure to deal with them may require a departure from the solutions now being advocated in the West . In this sense, the evolutionary process that has occurred in most countries may be a more useful and achievable model to follow for many developing countries, than to aim for an instant transplant of technically and administratively sophisticated controls that are not even standard in many OECD countries . Once infrastructure, resources and public awareness have grown more



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favourable (perhaps as a result of the first interim measures), the progression to more complex control systems becomes easier . Second, the case studies show that, even under adverse circumstances, several countries have been able to resolve certain critical problems . It has required will, and a preparedness to adapt solutions to local needs . Often, the lack of adequate knowledge of what the problem is, is a greater handicap than the lack of resources . This last point brings out a fundamental dichotomy between the need to learn what your problem is and the need to take early action . It should be noted though, that without a reasonable idea of what the dimensions of the problem are, any action is a shot in the dark . Thirdly, an unresolved, and perhaps unresolvable issue, is what standards to accept . Interim solutions are rapid but leave much unaddressed . More comprehensive solutions achieve better results but take time, resources and expertise, and are less able to evolve as circumstances change. In this regard, it may be more appropriate to assist but not to advise those who need to make the decisions . In the final instance, outside technical expertise is no substitute for good awareness and clear objectives at a local level . Acknowledgements This article is based on the case studies presented at the Honolulu workshop in September 1989 (edited versions of which appear later in this issue), and in particular on the workshop discussions . The views expressed are thus not necessarily those of the authors' organizations . The authors wish to thank the individual case study authors, the members of the ISWA Working Group on Hazardous Wastes and all other workshop participants for their contributions, both prior to, during and since the Workshop . Particular thanks are due to our co-rapporteurs, Dr James E . Smith Jr, of the USEPA and WHO, and Michael J . Stokoe of the Hong Kong Environmental Protection Department ; and to Richard A . Carpenter of the East-West Center in Honolulu, Chair of the Pacific Basin Consortium on Hazardous Waste Research .