Taking Out the International Garbage

Remember last week, when we were (re)celebrating luxury cruise provider One Ocean Expeditions decision to (maybe) establish a home port in Sydney, provided all its requirements could be met here?

One of those requirements had to do with the disposal of “international waste” at the Sydney Marine Terminal.

At the time, I noted that “international waste” sounded like piles of Belgian beer bottles and French cheese rinds (and, in fact, it could be) but disposal of international waste turns out to be a big deal — so big it falls under the watchful eyes of both the Canadian Food Inspection Agency (CFIA) and the Canada Border Services Agency (CBSA):

In late 2004, the CFIA and the Canada Border Services Agency (CBSA) came to an agreement whereby the control, monitoring and disposal of international waste (IW) falls within the responsibility of the CBSA. Program design and approval of disposal routes and sites remain the responsibility of CFIA. Monitoring of transportation is a joint CBSA-CFIA responsibility.

Sydney-Victoria MP Mark Eyking told the Cape Breton Post that dealing with IW in Sydney was a question of “planning and making sure staff is around.” One look at the CFIA’s International Waste Directive, however, suggests he may have missed a few steps.


Hog cholera, etc

orange trashbagIW is usually not permitted entry into Canada, explains the directive, because of the risk of introducing:

…plant diseases, pests, and important animal diseases of concern such as foot-and-mouth disease, rinderpest, African swine fever, hog cholera (classical swine fever), swine vesicular disease, Newcastle disease, avian influenza, African horse sickness, and many other animal diseases.

Exceptions are made if a CBSA inspector can be convinced the material can be disposed of without introducing any “vector [a living organism that can transmit infectious diseases between humans or from animals to humans], disease or toxic substance” into Canada. At a marine terminal like ours (read: small) IW must be placed in bags that are clearly distinguishable from those containing domestic waste (orange is a nice choice), stored in a separate area and double-tied before being removed from this area. The terminal must also post signs saying, “Orange bags are used for international waste only.”

Compaction is often used at marine terminals or airports to reduce the volume of waste, but it produces a lot of liquid which must then be dealt with:

The liquid waste must not be allowed to contaminate the soil, water supply, or surface water of the area where it is generated or during transportation to another location for waste water treatment. This liquid waste from IW must be captured and handled on location or transported to another location for waste water treatment. It is the responsibility of the disposer of liquid waste to ensure compliance with all municipal, provincial, and federal requirements on liquid waste disposal within their area.

The terminal also has to handle IW from ships’ galleys without “cross-contaminating” it with domestic waste and in leak-proof containers. CBSA inspectors will monitor weekly or monthly (depending on volumes) to ensure all regulations are being met and that there are no “signs of vermin.”


Disposal sites

By this point in my reading I was thinking, “Piece of cake. I could handle IW myself with my eyes closed.” (Although, obviously, that would be strictly against CBSA regulations).

But then things began to get more complicated. Ship owners don’t just dump IW at marine terminals and kiss it goodbye — they are responsible for ensuring it is delivered to an “approved disposal site.”

I asked the CFIA where the nearest approved disposal site to the Sydney Marine Terminal is, but as of press time I hadn’t received a response.

If the CBRM, say, wanted to operate an IW disposal site, it would have to apply to the CFIA and meet some pretty stringent requirements. To operate a landfill site, for example, it would need a currently valid provincial permit or license but it would also need a site that was:

…completely enclosed, physically situated, or operated so that no domestic and feral animals have access, direct or indirect, to the IW. This can be accomplished either by its being fenced or by its having natural geographic barriers that prevents the entry of animals, so that the landfill site is free of domestic, feral, and wild animals such as swine, other domestic livestock and poultry, and wild ruminants such as deer and moose.

There can be no livestock or poultry within 0.5 km of the IW disposal site, no waste can be removed from the site and IW from ships (or aircraft) must be covered by a minimum of 1.8 meters of domestic garbage.

If you apply to the CFIA for disposal site approval, the agency will send an inspector to ensure compliance initially and then once a year forever after.

There are equally strict rules for incinerator and autoclave disposal facilities.


On the road

So what if OOE (or any other ship owner) just sent the IW to the nearest approved disposal site?

Well, that opens a whole new can of (international) worms.

Haulers of IW (in distinctively colored bags, in leak-proof containers) must comply with the regulations found in both the International Waste Directive and the Animal Health Act. The hauling company is responsible for having CBSA-approved standard operating procedures (SOPs) that include driver training, handler training and a storage plan.

The hauler must have proper leak-proof containers and they must be cleaned to the CBSA inspector’s satisfaction following IW drop-off. But wait, it gets better:

Routing Map

  1. The CFIA’s advance approval is required for the transportation route from the POE [Point of Entry] to the approved disposal site. In the event of emergency road closure, an alternate route is also required and must be pre-approved by the CFIA.
  2. Copies of approved routes will be provided by the CFIA to the local CBSA office dealing with the IW hauler.

Not just any route will be approved — the preferred route will be the shortest distance (and within a “reasonable” distance) from the POE and avoid agricultural crop and livestock areas. Other requirements include:

Spill Contingency Plan

A written contingency plan must be in place in case of an accident resulting in spillage of IW. CBSA and CFIA contact names and numbers must be part of the contingency plan. The contingency spill plan must be approved by the CFIA in advance.

Waste Manifest

Each truckload requires a waste manifest, or some other form of proof of delivery. These are to be reviewed periodically by CBSA inspectors and must be made available when requested by the CBSA or the CFIA.

The directive ends with a detailed discussion of the disinfectants to be used on instruments and IW containers (powdered citric acid for your clothes and sodium hydroxide for your water tanks, for instance).


Et cetera

In short, taking out the international garbage involves more than getting up early on Saturday morning and dragging the green bin to the curb in your pajamas (not that I’ve ever done that).

And while Eyking dismissed it as a question of “planning and making sure staff is around,” OOE founder and CEO Andrew Prossin didn’t even mention IW or the CFIA in his list of requirements for doing business in Sydney as cited in the Post

We just need to see a little bit of change in some of the regulations to make it easier to do business in a place like Sydney. I’ll be honest, the deck is a bit stacked, the rules sort of give us an incentive to do more in places like Halifax because offices have been moved to Halifax and different departments in the government, Transport Canada, Canada Customs, et cetera, et cetera.

I guess it’s one of the “et ceteras,” but as those of you who take the time to stretch out in a hammock with a cold drink and a copy of the International Waste Directive will agree, it’s quite an et cetera.



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