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Second Letter to Danish Minister of Development, Mr. Poul Nielson, re: Danish Promotion of Incinerator in Mozambique


July 23, 1998

Development Minister Poul Nielson
Ministry for Foreign Affairs
Asiatisk Plads 2
1448 Copenhagen K
Fax number: +45 3254 0533


Dear Minister Poul Nielson:

We are both saddened and alarmed that our letter has been met by a defensive and intransigent posture on the part of the Danish Ministry of Development. As we have stated from the beginning, we are fully supportive of the objective of ridding Mozambique of its obsolete pesticides burden. Until now we have seen Denmark act as a model for environmental responsibility with respect to toxics in the developing world in international fora. And we are very grateful that countries such as Denmark are willing to make resources available for worthy environmental and development objectives. However your 10 July letter in response to ours of 2 July reveals an unwillingness to change what is clearly revealed to be a poorly researched, mistaken approach to environmental protection and capacity building in Mozambique.

The Ministry of Development continues to admit no mistakes when there are clearly many, continues to recycle incorrect information, and refuses to address serious issues we have raised. Your letter, while appearing thorough, side-steps our primary issues of concern while painting an insulting, false picture of our supposed insensitivity to the environmental threat posed by the poorly stored pesticides. Your letter makes it clear that Danida is intent on ramming the project through, before there is time for the Mozambique or Danish people to become fully aware of the preferable alternatives available.

If one reads first our letter and then your response, the message is clear. Despite our well founded concerns for both the immediate Mozambique environment and the precedent you are setting for this project globally, the Development Ministry remains perfectly willing to:

-- ignore the fact that it has employed a company which are known international waste traffickers and which are under investigation for human rights violations in South Africa;

-- ignore an evaluation by the United States Environmental Protection Agency (USEPA) that reports that dioxins and furans as well as other harmful emissions will increase dramatically when chlorinated pesticides and other hazardous wastes are burned in cement kilns;

-- refuse to conduct a true comparison of all available alternatives including the cost effectiveness and environmental soundness of these;

-- decide, in the absence of any study or waste audit of the Mozambique hazardous waste situation, that Mozambique needs a Danish equipped cement kiln to burn hazardous wastes for many years into the future;

-- ignore the fact that the Mozambique government has been involved in recent proposals to import hazardous wastes into the country for profit and that an existent cement kiln will likely serve as a magnet for international traffickers in hazardous waste;

-- ignore the fact that proliferating hazardous waste combustion technologies which produce dioxins and furans (two of the most dangerous "persistent organic pollutants" or POPs) is in contradiction to the goal of Denmark and the global community to eliminate and reduce such POPs;

-- leave unburnable, contaminated materials and soils in Mozambique, refusing to do a complete clean-up job;

The rush to promote dangerous, polluting, end-of-pipe, waste disposal methods in Mozambique to the primary economic benefit of Danish companies is not the kind of aid that we believe will promote sustainable development in Africa or the world. Rather, it is our firm belief that Danida stands on the precipice of not only engaging in an environmentally unsound plan for the clean-up of obsolete pesticides, but with this project will be setting a very dangerous precedent for the sustainable development of Africa and indeed the world.

Looked at another way, Denmark is missing an opportunity to provide a global model on how the many hundreds of thousands of tonnes of POPs can best be destroyed without generating and releasing new POPs. Mozambique is not the only place where dangerous POPs need to be neutralized. Once the bans and phase-outs envisaged in the POPs negotiations are implemented, the volume of such intractable hazardous wastes will increase dramatically. It is imperative then, that waste prevention rather than waste control practices are adopted now so that the POPs crisis will not be futher exacerbated and we can move toward, rather than away from global goals of preventing hazardous wastes at source.

While we will herein answer your letter point-by-point, we observe that you have made no overture to continue a dialogue. We will thus have little alternative but to take our concerns to a different audience in the hope that we can halt this project pending the investigation we seek into more environmentally sound and cost effective alternatives. What follows are point-by-point comments on your 10 July response (found on your Website at to our 2 July letter (found on the Basel Action Network Website at -- library section):

Your Introduction

We find it unacceptable that the Ministry of Development would imply that we are not sensitive to immediate emergency responses to acute pesticide poisoning situations. Indeed Danida has been aware of these horrific types of problems at least since its initial survey in 1994 and the question is begged as to why these stockpiled pesticides have not been dealt with on an emergency basis, ie. by fencing them off and placing warning signs around them at that time. We did not address this question previously in the hopes of being proactive and constructive. Certainly we would hope that Danida has not completed their latest survey without taking immediate action with local authorities to remedy the acute situations you detailed.

As we have said at the outset of our 2 July letter and in all previous contact with your Ministry, we are fully in agreement that the pesticides must be completely cleaned from Mozambique soil. Our concern is that the Danida plan will not accomplish this in a thorough and safe manner. However in your response to us you have made an intentional and misleading effort to mix sensational issues of extreme emergency which should have been and must be dealt with at once, to justify a very narrow and misguided view of the greater part of the program (the non-emergency part) which concerns how thorough the clean-up should be done, what type of disposal should take place, and where it should be done. These latter issues are not of such an emergency basis requiring undo haste, yet nevertheless can have severe consequences for many years to come.

International Trade in Hazardous Wastes

The assurances and signed declarations you have said will be accomplished are interesting documents but they do not have the effect and duration of national or international law. To date we have no evidence that the AMODEL waste importation plans are dead. Likewise, you have cited no national law forbidding the import of all forms of hazardous wastes into the country of Mozambique. We may be mistaken but we have had numerous discussions with Basel Convention delegations from Mozambique and they have never mentioned or provided us with any such law. Neither has such a law been reported to the Basel Convention secretariat as is required by that Convention.

With respect to the Bamako Convention, we are very surprised that you are unaware that Mozambique is not a signatory to the Bamako Convention and continue to assert that it is. Mozambique apparently was not present in Bamako, Mali in 1991 during the adoption ceremony of that Convention, so they did not sign the Bamako Convention. Further, until a valid ratification is deposited with the Secretariat of the Convention and the requisite number of days has passed, Mozambique will not have acceded to the Bamako Convention and cannot be considered a party. Please get your information in this regard direct from the Organization of African Unity which acts as the Bamako Convention secretariat. If however, a 1996 resolution will now be deposited as a ratification as you have stated, we sincerely will applaud this act once it has occurred. As we have noted, according to the Organization of African Unity last month this had not occurred despite numerous Danida citations to the contrary.

Finally, with respect to the Basel Convention, we differ strongly that Decision III/1 of the Basel Convention has little relevance for Mozambique. While decision III/1 is an export ban, it was first proposed, negotiated and agreed by all of the G-77 group of developing countries, yet will not enter into force and provide protections from waste traffickers unless it is ratified not only by OECD countries but by non-OECD countries as well.

Denmark's Commitment to Eliminate and Reduce the Generation of POPs

You state that it is the policy of the Danish government that all POPs must be disposed of in an environmentally friendly manner, you further state that returning obsolete pesticides to the original producers is a good example of this and if this is not possible then incineration is advisable.

First, is it not clearly preferable to apply a preventative approach and choose to avoid producing yet more POPs via combustion processes? Combustion of organochlorines, such as some of the pesticides in question in cement kilns is known to lead to the formation of dioxins and furans, two of the most dangerous POPs ever to be generated on the planet. It is also well known that these emissions increase with increases in chlorinated feedstocks.

Second, returning obsolete pesticides to their original producers is not a guarantee of environmentally friendly disposal. Rather returning pesticides to original producers has frequently been recommended for two reasons: (a) To place responsibility, liability and costs in the hands of those who have produced the problem; and (b) To return pesticides to rich, heavily industrialized countries (ie. OECD countries) which are likely to have more wealth, infrastructure and options to safely manage the great risks involved in handling the pesticides and their disposal. While not all pesticides have been produced in OECD countries, this has traditionally been, and is still most often the case.

For precisely these reasons Danida should in accordance with point (a) above, repatriate all pesticides of known origin to their original producers, and in accordance with point (b) above, export the remaining pesticides found in Mozambique (regardless of knowing their origins) to a country with a greater infrastructure and range of disposal and storage options than are found in Mozambique.

Inadequate Analysis of Alternatives

Your only comment here is that you have followed the letter of standard Danida procedures and that you have produced a comprehensive EA. We must respectfully but vehemently disagree with your characterization of the Environmental Assessment (EA) as "comprehensive." Indeed we have never seen such a thin EA document produced for such an important and potentially environmentally dangerous undertaking.

With respect to looking at alternative disposal options, we find it extremely hard to believe that Danida allows such undertakings as this project without a full exploration (beyond the few and very small paragraphs provided in the EA) into various disposal options besides combustion in a cement kiln in Mozambique. Indeed, the only document that we have seen that speaks in any way (and very abbreviated) of other options is the EA. No doubt some mention of alternatives must have been required by the Danish EA guidelines.

However, the Project Document of November 1997 produced a month before the EA makes no mention of possible alternatives. It is clear then, that prior to the EA, any option other than burning in a cement kiln had already been ruled out. Danida has yet to cite or produce a document which shows that all options have really been fully assessed and compared. This is a fundamental flaw in the planning of the entire project.

It gives us no comfort that you have also mentioned that the project was approved by the Finance Committee of the Danish Parliament. While this body should have certainly inquired about more cost effective alternatives, we cannot expect a Finance Committee to be competent or inclined to address the greater environmental concerns we have raised in our previous letter and in this one.

You further claim that the EA was produced by an independent consultant. It is our understanding that this consultant is Mr. Henning Nohr. Although he may have been independent at one time, Mr. Nohr now promotes the Danida Mozambique pesticide burning project and is attached as an advisor to the Danida Africa Department. Mr. Nohr has admitted to us that he is not a hazardous waste expert.

We remind you that our letter pointed out that the statements made in the EA which so quickly dismissed the export option were erroneous. The Basel and Bamako Conventions have extensive procedures on how states might export hazardous wastes and can hardly be said to prohibit such exports, particularly from non-OECD to OECD countries that are being exported for environmental reasons and not economic ones. Again, Mozambique is not a party to the Bamako Convention. We would ask that before repeating this false statement again that you simply check with the Organization of African Unity in Addis Ababa, Ethiopia.

Even if the reasons cited for dismissing the export option were factually correct, which they are not, there has been no analysis of the greater implications with respect to POPs production, risks of accidents and pollution in running cement kilns, international waste trade, cost analysis, ability to deal with contaminated soils etc. that a proper options assessment should have covered. One small paragraph on the export option is indicative of the very poor and incomplete nature of this EA.

The Unjustified Objective: Long-Term Burning of Hazardous Waste in Mozambique

You claim that we are blind in ignoring realities that Mozambique will not generate hazardous waste. In fact we never stated this. What concerns us is that Danida appears to be blind to the fact that such wastes can be prevented and/or dealt with by more appropriate methods and less risky methods than burning them in a cement kiln. The fact that you have not cited the amounts and nature of the hazardous wastes generated in Mozambique clearly shows that you are putting the "cart well before the horse" in a rush to promote Danish waste combustion technology before doing a proper audit and assessment of alternative means of preventing and managing hazardous wastes besides the dangerous end-of-pipe, POPs producing method proposed.

You cite the example of medical wastes already being produced in Mozambique. We would be very happy to help advise Danida or Mozambique of means to reduce and prevent hazardous medical waste and of the alternative, non-combustion methods of medical waste neutralization using autoclaves for example for those biological wastes which might be unpreventable. Extensive research has been done on this issue which is available to those willing to avoid rushing to judgments about "preferable" disposal methods. Indeed USEPA has recently acknowledged "the development of less expensive medical waste treatment technologies such as autoclaving" in the reduction of dioxin outputs from medical waste treatment in the United States.(1) This is just one example of how an assessment of the actual hazardous waste situation in Mozambique and what to do about it, might and should lead to a far different approach than burning hazardous wastes.

You mention that Danida and Danced are currently assessing waste management throughout Southern Africa. We have seen the initial terms of reference of this investigation and found once again that there was little to no mention of waste prevention, rather the focus was on waste management by end-of-pipe treatment. Further, we wonder why civil society, including international NGOs such as the Environmental Justice Networking Forum, EJNF, Greenpeace or BAN have not been asked to participate in at least the scoping of this new project.

Finally, you claim that Danida has assisted Mozambique in establishing legislation to better manage pesticides. While this is no-doubt well intended, we wonder why Danida has not mentioned any effort to reduce pesticide dependence in Mozambique to avoid a repetition of this obsolete pesticide crisis.

Intractable Waste -- Modern Destruction Methods

We are pleased by your interest in modern, non-combustion destruction technologies. We find it surprising, however, that you are not aware that such alternatives are already at operating commercial scale. A few examples are as follows (2):

1. Three commercial-scale facilities are using base catalyzed de-chlorination (BCD) which was developed in the United States to detoxify PCBs and halogenated pesticides in Australia.

2. These same substances are being destroyed by the hydrogenation process at a commercial-scale facility in Western Australia as well as in Ontario, Canada.

3. A commercial Plascon plasma arc system has been in operation in Australia since 1992 for the destruction of pesticides, dioxins and similar substances.

We will be pleased to assist you in obtaining further information on these and other available technologies for the destruction of POPs stockpiles.

No Cost Analysis of Alternatives

You claim "a serious attempt was made to establish the transport and incineration costs in Denmark of the obsolete pesticides." And, you go on to state that the prices obtained "were not particularly attractive." It is obvious though, from the lack of any real budgets provided with this statement, that a proper costing has not been done and no documentation is available to indicate comparable costs. Further, the figures you have provided simply do not add up.

Even if we use the figure which you claim FAO uses as a rough estimate for shipping and incineration of $3,000 US dollars per tonne, a huge savings would, by our estimation be provided, as the total costs of burning the 150 tonnes (which is now by the latest assessment the amount of pesticides that Danida intends to burn in the cement kiln) would be $450,000 dollars or about 3.06 million Dkr. instead of our previously estimated 1.65 million Dkr. This is still cheaper than the amount you cite of 3.3 million Dkr. in your latest budget and when one remembers the fact that a waste station will not need to be constructed, and thus the costs of that ambitious undertaking as well as the jobs of the Turn Key consultant, Task force, supervisor etc. being vastly reduced, we still estimate that export might likely result in a total savings to the project of 13,274,500 Dkr. (See our last estimate).

We note however that you have changed your position with respect to the necessity of the Waste Station. In your response to our last letter it is stated that "neither local incineration nor the export ësolution' in themselves necessitate the permanent kind of waste station to be established under the project. The waste station is a long term investment in the creation of hazardous waste handling capacity in Mozambique." But this statement is in direct contradiction to the statement found on page 9 of the EA regarding the export option -- "there will be no need for a waste station and incineration facilities at Cimentos de Moçambique."

We find this latest statement (claiming the waste station is not linked to the cement kiln) from you to be insupportable. Not only does your statement contradict the Environmental Assessment, but if the statement is true, it indicates that Denmark is much more interested in establishing a high-volume hazardous waste handling facility in Mozambique than they are in properly cleaning up the country from obsolete pesticides. We come to this conclusion, because as we have noted and as has been asserted in our conversation with Mr. Nohr, that with respect to this project there is no intention of completely cleaning up all of the contamination -- due to a lack of funds.

This then appears to be the real agenda of this -- a large-scale, permanent, hazardous waste handling and burning facility, justified by fears of leaking drums and broken bags of pesticides. Yet, as we have stated in our last letter and above, this objective of so called "capacity building" via hazardous waste burning in Mozambique is not justified by any assessments or studies on your part.

We request that you provide us with the accurate costs of doing only what the title of this project -- "Disposal of Obsolete Pesticides -- Mozambique" calls for and no more. I think many want to know what the operation will cost if the cement kiln is not retrofitted and the wastes are exported and dealt with in Europe. These estimates should include various forms of intractable hazardous waste management including modern non-thermal methods.

Problems Associated with Burning Hazardous Wastes in Cement Kilns

As we have noted earlier, we find that the EA is remarkable in its lack of pertinent and factual information. It exhibits either a marked lack of concern in its preparation and/or a troubling lack of knowledge on the part of its preparers. The literature on the subject of cement kilns is extensive and we suggest your staff review it completely and cease relying on merely one source (Lamb) continually cited in your Environmental Assessment. As an overview of the problems associated with cement kilns, we have taken the time below to include referenced information of which Danida, the Danish Parliament, and all stakeholders and affected parties should be well aware.

General Cement Kiln Problems

The EA summary, that portion of the EA most likely to be read, makes no mention of many of the threats to the environment, workers and the surrounding communities that are well-known to be associated, in general, with the operation of cement kilns and, in particular, with the operation of cement kilns that burn pesticides and other hazardous materials. Among the well-known threats that are not addressed in the EA summary are the following:

1. Stack emissions of dioxins, other toxic contaminants and particulates that are known to pose threats to surrounding populations, workers and the environment;

2. Fugitive emissions of both pesticides and cement kiln dust during routine transfers and operations at the cement kiln, all of which are readily identifiable threats to workers, surrounding populations and the environment;

3. Cement kiln dust (CKD) handling, transport and final disposal, all of which present threats to workers, surrounding populations and the environment;

4. Upsets are well-known, relatively frequent occurrences at cement kilns during which emissions of unburned pesticides and products of incomplete combustion, such as dioxins, are increased.

It is most important to note that the EA makes no mention of the fact that, irrespective of the materials burned for heat energy, cement kilns pose threats to the health of workers, surrounding populations, and the environment, primarily through the impacts of cement kiln dust (CKD). For example, a study of workers at cement plants in the United Arab Emirates found them to suffer from chronic cough, chronic bronchitis, burning, itching and runny eyes, headache and fatigue.(3) Cement plant workers in another study exhibited a higher prevalence of chronic respiratory symptoms and reduced ventilatory capacity.(4)

In addition, the USEPA has found evidence of groundwater contamination at all U.S. cement plants for which groundwater monitoring data were available as well as 36 cases of documented damage to air from CKD. The Agency summarized as follows:

[O]ther evidence (i.e., damage cases) indicates that fugitive CKD emissions are a substantial contributor to environmental damages in the form of air quality degradation...EPA has concluded that additional control of CKD is warranted in order to protect the public from human health risks and to prevent environmental damage resulting from current disposal of this waste. The primary environmental concerns to be addressed through additional controls are documented damages to ground water and potable water supplies, and potential human health risks from inhalation of airborne CKD and ingestion via food chain pathways...Significantly, releases to ground water were observed at all sites for which EPA has received ground water monitoring data...[T]he Agency's risk assessment studies also indicated potentials for adverse aquatic ecological effects due to possible chemical releases to streams and lakes adjacent to some cement plants.(5)

Burning Hazardous Wastes in Cement Kilns

While you continue to maintain that "incineration of pesticides, even chlorinated ones, does not alter dioxin emissions from cement kilns using conventional fuel such as coal or petroleum," this is simply untrue. This statement is contrary to numerous studies that have found increased chlorine input leads to higher dioxin output from incinerators and other combustion systems. Positive correlations between chlorine input and dioxin output or specific fractions thereof have been demonstrated in laboratory- and pilot-scale systems (6), as well as in full-scale combustors.(7) Indeed, the Danish government has reported that "the reduction of the chlorine content in the waste can contribute to the reduction of the dioxin formation". (8)

Contrary to the statement cited in the EA by the company selling the incinerator equipment in the project, F.L. Smidth and Co. A/S, that claims that cement kilns are superior to hazardous waste incinerators, according to USEPA, the "conditions inherent in the cement kiln mimic conditions of hazardous waste incineration." (9) As such, some of the general limitations of hazardous waste incinerators are equally applicable to cement kilns that burn hazardous wastes. The impacts of hazardous waste burning cement kilns can be compared to those of cement kilns that burn conventional fuels, as follows:

1. Dioxins are emitted from cement kiln stacks, whether the kiln is fired with conventional fuels or with hazardous waste. However, according to USEPA, cement kilns that burn hazardous waste emit dioxins in their stack gases at rates more than 80 times higher than those of cement kilns that burn conventional fuels. In the U.S., cement kilns burning hazardous waste are listed as the fifth largest source of dioxin emissions to the air, while those that do not burn hazardous wastes are the tenth largest source. (10)

2. Similarly, dioxins are found in cement kiln dust (CKD) from cement kilns that burn conventional fuels as well as those burning hazardous waste. But USEPA recently reported that CKD from cement kilns burning hazardous waste carries dioxins at concentrations about 100 times higher than CKD from kilns burning only conventional fuels.(11) According to the Agency, one cement plant reported "a total dioxins concentration in CKD as high as 16 ppb [parts per billion]." (12)

3. Cement kilns that burn hazardous waste produce more CKD, as documented by the USEPA:

    "...the Agency also found that the burning of hazardous waste is correlated with the volume of dust that is actually disposed. Kilns that burn hazardous waste remove from the kiln system an average of 75 to 104 percent more dust per ton of clinker than kilns that do not burn hazardous waste." (13)

4. From 15 to 90 percent of CKD has a diameter below 10 microns (mm), which is within the respirable range for humans.(14) As these fine particles are carried to the stack, the portion that is not captured by pollution control devices is released directly to the air. Some fraction of the captured CKD also escapes during transfer and disposal. One cement kiln burning 90 tons of hazardous waste per day was found to produce CKD at the rate of 200 tons per day. (15)

5. The smaller CKD particles are those most likely to escape capture by pollution control devices or to be resuspended or washed from CKD stored in piles or pits. These particles are also the most likely to lodge deeply in the lungs. Airborne particles smaller than 2 mm have been linked to high rates of pneumonia, pleurisy, bronchitis, and asthma.(16) In their briefing paper on burning hazardous waste in cement kilns, the American Lung Association drew attention to the issue of CKD as follows:

    Particulate matter is a health concern because inhaling even relatively low airborne concentrations of dust can cause or aggravate lung diseases such as asthma or emphysema, and is associated with premature death...Since CKD collected in air pollution control devices typically has a small particle size, poorly managed cement kiln dust handling, transport and disposal has been shown to cause severe fugitive dust and air pollution problems." (17)

6. Dioxins have also been found in the clinker from both hazardous and non-hazardous waste facilities. (18)

7. Emissions of airborne particulates increased by 66 percent when hazardous wastes were burned in cement and aggregate kilns, and by 203 percent when the hazardous wastes also contained chlorine sources. (19)

8. When hazardous wastes containing both chlorinated chemicals and metals were burned, metals emissions from cement kilns increased. (20)

9. Burning chlorinated chemicals in cement kilns increases the likelihood of upsets, since the presence of additional chlorine encourages the formation of "rings" in the kilns. When the rings detach or break, the sudden release of solids in the kilns can result in upsets which are accompanied by increased emissions of unburned wastes and products of incomplete combustion, or even more severe consequences:

    In a very severe upset, the flame at the firing end of the kiln can be extinguished. Upsets are not uncommon. The kiln we studied averaged three upsets a month..." (21)

10. Fugitive emissions are substances that volatilize or, if adsorbed to particulates, such as CKD, blow or wash into the surrounding environment during waste transfer and storage. At one cement kiln burning hazardous waste, fugitive emissions were reported to total 20,074 pounds per year. (22)

11. Spills, both on-site and off-site, are also a concern at cement plants where hazardous materials are burned. A report commissioned by the New York State Legislature on waste-burning in cement kilns assessed the likelihood of repeated spills:

    "[I]t is virtually impossible to completely prevent small spills of hazardous waste during unloading and pumping of waste fuels. These spills may be caused by equipment failures, maintenance operations, or operator error." (23)

Regarding the FAO Position

To be more explicit on FAO's position, FAO cautions that disposal of hazardous materials, such as obsolete pesticides, by burning in cement kilns is "often not applicable in a safe and/or cost-effective manner." (24)

Collection and Remediation Phase

Your explanations of the areas that cannot be considered "no-risk zones" still provides us little confidence. Throughout the planning document there is plenty of reference to burning of contaminated pallets, and land disposal in Mozambique of unburnable contaminated materials such as contaminated soils. There is little explanation in the planning documents of how those sites that remain contaminated will be maintained as "no entry" sites in perpetuity. Again we find it inexcusable that there is any contemplation of leaving behind contamination.

Mr. Nohr admitted to us that the standard of clean-up to be performed in Mozambique is not to the standard of norms found elsewhere in the world. He cited costs as being the limiting factor. As mentioned in our last letter, but not commented on by you, we find this double-standard to be unacceptable and unjustifiable.

We remain horrified that the company that will do this very sensitive work Waste-Tech, is currently under investigation for human rights abuses in South Africa and whose parent company (EnviroServe is actively pursuing international waste trade schemes in violation of international law (Lome IV Convention, Basel Convention and Bamako Conventions). Again you try to reassure us with statements that this has all been approved by the Danish Parliament Finance Committee!

We will not dignify the remark about our supposed wish to halt acute emergency clean-up operations.

Lack of Public Participation

We are amazed that you are claiming that there has been adequate public participation due to the fact that we, at our own initiative, have been trying to establish a dialogue with Danida in order to reform this misguided project. Where was the public participation prior to the final decisions? And where is there any indication that you are willing to listen and alter your plans based on our concerns now that we have gotten your attention? Public participation does not simply mean answering questions and giving copies of documentation after the project is a fait accompli.

Furthermore, as your staff well knows, the representative of the Environmental Justice Networking Forum in South Africa was not given the EA and other documentation but rather was allowed to read it in your offices in Pretoria without being able to make a copy. What is the justification for this type of secrecy?

Waste-Tech's Record

Your claim that Waste-Tech has a "limited role" in the project is misleading in the extreme. The Waste-Tech role is the biggest line item in the budget by far at 14.5 million Dkr. It is also the job where the most potential harm can be done to the greater environment of Mozambique and certainly the job which will entail the greatest potential contact with the people of Mozambique. To employ a company for such a socially and environmentally sensitive job, that is currently governed by international waste traffickers (EnviroServe, parent company) and is under investigation in South Africa for human rights abuses is completely irresponsible and negligent.

It is clear from our exchanges that Danida did not even know of Waste-Tech's record in this regard. This ignorance is further indication of the hasty and incomplete nature of the planning process of this entire project. Yet what we find even more inexecusable is the fact, that once made aware, the Minister of Development refuses to drop Waste-Tech from the project.


In conclusion, we believe that stocks of banned and phased-out substances must not be allowed, under any circumstances, to be dispersed into the environment through continued use, direct dumping, or the use of inadequate destruction technologies. In this regard, we want to see Denmark as part of the solution and not part of the problem. We continue to believe that export of the obsolete pesticides to European or other OECD countries with the most available infrastructure and options for managing the wastes is the most cost effective and least environmentally risky of all options.

Yet it appears certain, based on your recent letter, that Danida and the Ministry of Development are committed to ignoring our concerns and embarking on a dangerous, irresponsible and unnecessarily misguided program for ridding Mozambique of pesticide contamination. We are therefore more determined than ever to do all we can to inform the Danish, Mozambique and Southern African public of the dangers of the Danida program, and of Danida's unwillingness to consider preferable alternatives. It is still our sincere hope that this project will be reconsidered in time to avoid the unnecessary proliferation of dangerous technologies and further contamination of African soil. It is still our sincere hope that Denmark will see fit to do this job the right way, and thereby set a precedent on how to end our planet's sad toxic legacy and not further perpetuate it.

Jim Puckett (on behalf of the following organizations)

Basel Action Network (BAN) Secretariat
c/o Asia Pacific Environmental Exchange
1827 39th Ave. E.
Seattle, Washington 98112 USA
Phone/fax: +1 2067206426

Chris Albertyn
Environmental Justice Networking Forum (EJNF), Pietermaritzburg, South Africa
Phone: +27 331949073
Fax: +27 331455841

Marcelo Furtado
Greenpeace International, Sao Paolo, Brazil
Phone: +55 1130612934
Fax: +55 112825500

Jacob Hartmann
Greenpeace Denmark, Copenhagen, Denmark
Phone: +45 33935344, +45 33938660
Fax: +45 33935399


Steen Gade, Chairman
The Parliament's Committee on Environment and Planning, Denmark

Joergen Estrup, Chairman
The Parliament's Foreign Affairs Committee, Denmark

Mr. Svend Auken
Minister of Environment, Denmark

Minister Bernardo P. Ferraz
Ministry for the Coordination and Environmental Affairs, Mozambique

Mr. Francisco Mabjaia, Permanent Secretary
Ministry for the Coordination of Environmental Affairs, Mozambique

End Notes:

(1) U.S. Environmental Protection Agency, 1998. The Inventory of Sources of Dioxin in the United States. External Review Draft, EPA/600/P-98/002Aa, Washinton, D.C. April 1998.

(2) Environment Australia, 1997. Appropriate Technologies for the Treatment of Scheduled Wastes, Review, Report Number 4 - November 1997, Canberra, Australia.

(3) Abou-Taleb, A., Musaiger, A., and Abdelmoneim, R., 1995. Health status of cement workers in the United Arab Emirates. J. R. Soc. Health 115:378-381.

(4) Yang C., Huang, C., Chiu, H., Chiu, J., Lan, S., and Ko, Y., 1996. Effects of occupational dust exposure on the respiratory health of Portland cement workers. J. Toxicol. Environ. Health 49:581-588.

(5) U.S. Environmental Protection Agency, 1995. Regulatory Determination on Cement Kiln Dust. 40 CFR Part 261, Federal Register: February 7, 1995.

(6) Kanters, M.J., Van Nispen, R., Louw, R., and Mulder, P. 1996. Chlorine input and chlorophenol emission in the lab-scale combustion of municipal solid waste. Environ.Sci.Technol. 30(7): 21121-2126; Wikstrom E., Lofvenius, G., Rappe, C., Marklund, S. 1996 Influence of level and form of chlorine on the formation of chlorinated dioxins, dibenzofurans, and benzenes during combustion of an artificial fuel in a laboratory reactor. Environ. Sci. Technol. 30(5): 1637-1644; Halonen, I., Tarhanen, J., Ruikojarvi, P., Tuppurainen, K., Ruuskanen, J. 1995. Effect of catalysts and chlorine source on the formation of organic chlorinated compounds. Chemosphere 30(7): 1261-1273; Burns, D.B. 1993. "Final Report Consolidated Incineration Facility Metals Partitioning Test (U)," WSRC-TR-93-623, Savannah River Technology Center, Aiken, SC, August 31, 1993; Halonen, I., Tarhanen, J., Oksanen, J., Vilokki, H., Vartianinen, T., Ruuskanen, J. 1993. Formation of organic chlorinated compounds in incineration of pulp and paper mill biosludges. Chemosphere 27(7): 1253-1268; Halonen, I., Tarhanen, J., Kopsa, T., Palonen, J., Vilokki, H., Ruuskanen, J. 1993. Formation of polychlorinated dioxins and dibenzofurans in incineration of refuse derived fuel and biosludge. Chemosphere 26(10: 1869-1880; Wagner, J., Green, A. 1993. Correlation of chlorinated organic compound emissions from incineration with chlorinated organic input. Chemosphere 26(11): 2039-2054; Fangmark, I., van Bavel, B., Marklund, S., Stromberg, B., Berge, N., Rappe, C. 1993. Influence of combustion parameters on the formation of polychlorinated dibenzo-p-dioxins, dibenzofurans, benzenes, and biphenyls and polyaromatic hydrocarbons in a pilot incinerator. Environ. Sci. Technol. 27: 1602-1610

(7) Manninen, H., Perkio, An., Vartiainen, T., Ruuskanen, J. 1996. Formation of PCDD/PCDF: Effect of fuel and fly ash composition on the formation of PCDD/PCDF in the co combustion of refuse-derived and packaging-derived fuels. Environ. Sci. & Pollut. Res. 3 (3): 129-134; Huotari, J., Vesterinen, R. 1996. PCDD/F emissions from co-combustion of RDF with peat, wood waste, and coal in FBC boilers. Haz. Waste & Haz.. Materials 13(1): 1-9; Vesterinen, R., Flyktman, M. 1996. Organic emissions from co-combustion of RDF with wood chips and milled peat in a bubbling fluidized bed boiler. Chemosphere 32(4): 681-689; Moller, S., Larsen, J., Jelnes, J.E., Faergemann, H., Ottosen, L. M., Knudsen, F.E. 1995. "Environmental Aspects of PVC." Environmental Project No. 313. Denmark: Ministry of the Environment, Danish Environmental Protection Agency, 1995.

(8) Moller, S., Larsen, J., Jelnes, J.E., Faergemann, H., Ottosen, L.M., Knudsen, F.E. "Environmental Aspects of PVC." Environmental Project No. 313. Denmark: Ministry of the Environment, Danish Environmental Protection Agency, 1995.

(9) U.S. Environmental Protection Agency, 1998. The Inventory of Sources of Dioxin in the United States. EPA/600/P-98/002Aa. Washington, DC, April 1998.

(10) U.S. Environmental Protection Agency, 1998. The Inventory of Sources of Dioxin in the United States. EPA/600/P-98/002Aa. Washington, DC, April 1998.

(11) U.S. Environmental Protection Agency, 1998. The Inventory of Sources of Dioxin in the United States. EPA/600/P-98/002Aa. Washington, DC, April 1998.

(12) U.S. Environmental Protection Agency, 1995. Regulatory Determination on Cement Kiln Dust. 40 CFR Part 261, Federal Register: February 7, 1995.

(13) U.S. Environmental Protection Agency, 1995. Regulatory Determination on Cement Kiln Dust. 40 CFR Part 261, Federal Register: February 7, 1995.

(14) U.S. Environmental Protection Agency, 1993. Report to Congress on Cement Kiln Dust, Vol. II: Methods and Findings. Washington, DC, December 1993.

(15) Murphy, B., and Mix, T., 1984. Risks associated with waste-fuel use in cement kilns. Environmental Progress 3:64-70

(16) Pope, C., 1989. Respiratory disease associated with community air pollution and a steel mill, Utah Valley. Am. J. Public Health 79: 623-628;

(17) Richardson, M., 1995. Recycling or Disposal? Hazardous Waste combustion in Cement Kilns: A Briefing Paper of the American Lung Association Hazardous Waste Incineration Project. Washington, DC: American Lung Association, April, 1995.

(18) U.S. Environmental Protection Agency, 1992. Cement Kiln Dust Report to Congress: Briefing for Sylvia Lowrance, Office Director, OSWER. Washington, DC.

(19) Mournighan, R. and Branscome, M., 1987. Hazardous Waste Combustion in Industrial Processes: Cement and Lime Kilns. EPA-68-03-3149. Washington, DC: U.S. Environmental Protection Agency.

(20) Mournighan, R., and Branscome, M., 1987. Hazardous Waste Combustion in Industrial Processes: Cement and Lime Kilns. EPA-68-03-3149. Washington, DC: U.S. Environmental Protection Agency; Murphy, B., and Mix, T., 1984. Risks associated with waste-fuel use in cement kilns. Environmental Progress 3:64-70.

(21) California Air Resources Board, 1987. Evaluation of Combustion Process for Destruction of Organic Wastes -- General Portland. ARB/SS-87-02 (10- 15-87), Sacramento, California.

(22) Systech Environmental Corporation, 1990. Non-point air emissions estimates for 1987 from National Cement Company, Lebec, CA. Toxics Release Inventory (on-line database). Bethesda, MD: National Library of Medicine.

(23) Beers, A., 1987. Hazardous Waste Incineration: The Cement Kiln Option. Prepared for the Legislative Commission on Toxic Substances and Hazardous Wastes, State of New York, Albany, NY.

(24) United Nations Food and Agriculture Organization, undated. The Problem of Obsolete Pesticides.

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