by Mr. Mario Armand Ugón and Ms. Silvia Aguinaga

In the initial list of twelve groups or products listed by UNEP for evaluation of POPS, three include groups of industrial chemical products, by-products, and contaminants, and the other nine are pesticides.

It should be stated that there is still no exhaustive study in Uruguay that has quantified the incidence of this group of POPs. However, it is possible to arrive at an approximation of the problem, albeit on a preliminary and qualitative basis.

In addition, national legislation, regulations, and standards governing the emission and disposal of these products to prevent adverse effects on health and the environment are nonexistent.

Of the industrial chemicals, polychlorinated biphenyls (PCBs) are the main POPs and continue to be used in electronic equipment, transformers, and capacitors.

The state-owned company that generates and distributes electricity, together with the industries and services that are major consumers of energy comprise the priority sector to be identified and evaluated.

There are several types of situations in industry in terms of the handling of PCBs:

1) Companies that have identified equipment in use that contain PCBs and oversee its handling well.

2) Companies that have identified equipment, have replaced it with other equipment with non-PCB fluids, and are waiting to undertake appropriate final disposal.

3) There is also a segment of small- and medium-sized industries that still have no real awareness of the problem, lack of information being one of the major causes of this situation.

4) There is also another type of company: scrap dealers engaged in purchasing all types of equipment in disuse, including transformers and capacitors; their handling of this equipment is poor, producing emissions that can affect health and the environment.

Dioxins and furans arise as by-products and accidental contaminants in various production processes and are also released into the environment as emissions during the combustion of products containing bromine and chlorine.

Places and processes are identified below as sources of these contaminants to be evaluated in our country:

1) The uncontrolled burning of PCBs by the companies using the equipment or by the scrap dealers mentioned above. Incineration of these products requires special ovens with high temperatures and appropriate timing, equipment not available in Uruguay.

2) The incineration of hospital waste, a common practice in the country, and in some cases incineration of municipal waste containing organohalogenated compounds.

3) The recovery of metals from cables removed from electric and telephone transmission lines by open-air burning to eliminate the coating. This procedure poses an additional problem in that the coating contains halogenated products used as flame retardants, further complicating the situation. These tasks are carried out secretly on land close to small populated centers.

4) Waste from the paper pulp industry, from the chlorination processes for bleaching the cellulose.

5) Finally, establishments engaged in purchasing materials in disuse handle this type of equipment in a haphazard fashion, leading to spills and burns in marginal housing areas.

As part of a General Environmental Management Plan, this company has implemented a detailed program for the management of equipment with PCBs to ensure proper final disposal of products and equipment that are no longer in use and that contain or are contaminated with PCBs; it also monitors the equipment still in use.

For equipment that is out of order, it maintains an inventory indicating the equipment number, type, oil content, and weight.

This equipment and its contents are treated as hazardous waste awaiting final disposal. For this purpose, a series of procedures are carried out, including preparation of the material for transportation, temporary storage, and conditioning in holders for transfer and incineration in suitable facilities outside the country.

The conditions of the temporary storage site (walls, floor, ceiling, ventilation, drainage, etc.) as well as the safety measures to be used in case of an accident of some type are fully considered so as to minimize risks.

All these tasks are performed in keeping with the provisions of the Basel Agreement, to which our country is a signatory, and the procedures are carried out with the National Environment Directorate and its Hazardous Substances Unit (DI.NA.MA. - U.S.P.), the unit that establishes the connection with the country receiving the waste and supervising the operation.

At the same time, the company also makes the necessary arrangements with other authorities such as Customs, the National Naval Prefecture, etc.

Regarding equipment still in use, the company maintains an inventory and a database that records the type of equipment, quantity, location, state of preservation, and provision for when it is removed from service.

This information is utilized for monitoring the equipment in use and as the basis for providing temporary storage until volume justifies a new shipment.

In summary, it is felt that this company conducts very adequate management of equipment with PCBs, in coordination with the responsible authorities.