When addressing waste management within an agricultural business, the first step towards effective waste management is to identify and classify all waste streams generated on-site. This is essential, as each waste stream must be managed and handled in accordance with applicable legislative requirements and recognised waste management practices.
The Waste Management Plan should therefore identify all waste sources generated by the agricultural business. These may include, but are not limited to, hazardous waste, general waste, recyclable materials, and organic waste. For each identified waste stream, the Waste Management Plan should clearly outline appropriate procedures for handling, storage, transportation, treatment, recycling, and final disposal. These measures should be designed to ensure that waste is managed in a safe, environmentally responsible, and legally compliant manner.
Hazardous waste
Hazardous waste generated by an agricultural business may include empty chemical containers, used oil, used oil filters and rags, and chemical wastewater generated from chemical filling areas or the cleaning of personal protective equipment (PPE).
The primary principle when assessing the storage of hazardous waste is to prevent contact between the waste and the surrounding environment, including soil, surface water, groundwater, and people. All hazardous waste should therefore be stored on a non-porous surface and within an appropriately designed bunded area to ensure that any spills, residues, or leakage are effectively contained. Adequate access control must also be implemented for areas where hazardous waste is stored, particularly for empty chemical containers. Access to these storage areas should be restricted to authorised personnel and managed in accordance with the applicable requirements of SANS 10206.
The disposal of hazardous waste must be undertaken in accordance with all applicable legislative and regulatory requirements. Appropriately authorised and accredited hazardous waste management service providers should be appointed for the collection, transportation, treatment, recycling, and final disposal of hazardous waste generated on site. The Cradle-to-Grave principle must be applied to ensure that hazardous waste remains traceable throughout the entire waste management process, from its generation and collection through to its final treatment or disposal. The appointed service provider should provide appropriate documentation and supporting evidence confirming that the waste has been managed and disposed of in an environmentally responsible and legally compliant manner. Adequate records and documentary evidence confirming the safe disposal, treatment, or recycling of hazardous waste should be maintained on-site and made available to auditors.
General waste (for landfill)
General waste generated within an agri-business is classified as non-hazardous and unsuitable for recycling. This may include various waste materials generated through routine agricultural, operational, and administrative activities that do not fall within the hazardous or recyclable waste streams. The generally accepted practice for disposing of general waste is to transport it to an appropriately managed landfill facility. Depending on the applicable requirements and available infrastructure, disposal may take place at a suitably managed on-site landfill or at an authorised municipal landfill site. Records for the disposal of general waste (in weight) at an on-site landfill or municipal landfill site must be available to the auditor.
Although the establishment of an on-site landfill is generally discouraged, it is permitted under the applicable legislative framework, provided that appropriate environmental management measures are implemented in accordance with the Duty of Care Principles. These measures should include ensuring that the landfill area is adequately fenced and appropriately signposted to restrict unauthorised access. The landfill should preferably be located within a previously disturbed area and must be suitably situated to minimise the risk of environmental contamination. In particular, the landfill should not be located above shallow or emergent groundwater tables, or in areas where its operation may result in nuisance conditions or other adverse impacts on the surrounding environment.
Recyclable waste
Recyclable waste, including but not limited to glass, cardboard, and plastic, should be separated at the source within the agri-business. There are two primary approaches for the management and removal of recyclable waste generated on-site. The first is to transport the recyclable materials to an appropriately authorised recycling facility or recycling company for processing. The second is to deliver the recyclable waste to a local municipal landfill facility where recycling activities are undertaken.
Traceability of recyclable waste is an important component of effective waste management. Appropriate records and supporting documentation should therefore be maintained to verify that recyclable materials have been diverted from disposal and successfully recycled. Where recyclable waste is collected by a recycling company, documented confirmation of the quantities collected and recycled should be obtained from the service provider. Where recyclable waste is delivered to a municipal landfill or waste management facility, written confirmation or other appropriate evidence should be obtained from the facility to demonstrate that recycling or material recovery activities are undertaken.
Waste Management in challenging situations
In cases where generally accepted waste management practices, as outlined above, are not reasonably practicable due to the remote location of farms, packhouses, or processing facilities, alternative waste management measures should be implemented. Such measures should be appropriate to the site-specific circumstances and must ensure that the fundamental objective of responsible waste management is achieved, while minimising potential risks to human health and the environment and maintaining compliance with applicable legislative requirements.
Where recycling opportunities are not reasonably practicable due to the remote location of a site or the absence of a suitable recycling company within the vicinity, documented evidence of an investigation into the feasibility of recycling should be maintained and made available for verification during an audit. Such investigations should be conducted at appropriate intervals to ensure that changes in the availability of recycling services are identified and taken into account. This will demonstrate an ongoing commitment to the principles of continuous improvement and responsible waste management. An alternative approach is to establish a cooperative arrangement with neighbouring agri-businesses that face similar challenges regarding the feasibility of recycling. By collaborating with surrounding agri-businesses, the costs associated with collecting, transporting, and recycling materials can be shared, thereby improving the economic feasibility of recycling activities.
The Auditor’s Approach: Looking Beyond the Paperwork
When auditing waste management practices, auditors should look beyond the presence of a Waste Management Plan and supporting documents and assess whether the system is effectively implemented in practice. This includes considering the site-specific circumstances, observing how different waste streams are identified, separated, stored and managed, and verifying that the procedures described in the Waste Management Plan are being followed. Auditors should also assess the availability and reliability of supporting records, such as disposal certificates, collection records, recycling confirmations and weight records, and determine whether these provide sufficient evidence of traceability. Where a site faces practical challenges, particularly due to its remote location, the auditor should consider whether the business has taken reasonable, risk-based steps to manage waste responsibly and whether there is evidence of ongoing efforts to improve its practices.
The objective is therefore not simply to identify whether a requirement is met, but to determine whether the overall waste management approach effectively protects people and the environment, meets applicable legal requirements, and demonstrates a commitment to continuous improvement.
