Being responsible

Caner Zanbak, Environmental Coordinator at the Turkish Miners Association, talks to Zoe Rutherford about careful management of chemicals

ZR: What is your role within Turkish Chemical Manufacturers’ Association (TKSD)? In the ‘league table’ of responsible countries, where does Turkey sit? CZ: I was environmental advisor to the Turkish Chemical Manufacturers’ Association from 1994 to 2018. I was in charge of the Responsible Care coordination in Turkey and also liaison with the European Chemical Industry Council (CEFIC) and other government entities here in Turkey, and in neighbouring countries.

In terms of a lead country, a league table, it is hard to say with the exception of five or six in Europe but knowing CEFIC and activities that are going on in the industry, I would say that Turkey is probably in the upper-mid level in such a league list.

ZR: How do we encourage countries to work better within chemical safety? Often rules and laws can be set, but they require government departments to respect and enforce them too. How do we get a ‘whole of government’ approach to this? CZ: There's no need to encourage countries to work better on chemical safety, they have to work on it, and they are. All EU applicable regulations and others are in place, and all EU countries, including Turkey, fulfil those requirements. In Turkey the regulations are harmonised, even though in some other member states they are not fully implemented. Therefore, the issue is the enforcement, management, and follow-up. How to encourage the companies within countries is the question. Enforcement is good, but Responsible Care1 somewhat provides that, not enforcement. Responsible Care is a voluntary initiative and is in some ways better than government regulations because it requires fulfilment of all the legal requirements, plus additional ones such as sustainable development, and talking and harmonising activities with the community and such.

Another good voluntary tool is the ISO standards, for example. Companies go for ISO standards

because they use them as an incentive over their competitors in the global chemical market. Even countries like China, the giant, are getting in line with voluntary requirements, although they may not be applying them internally.

Exports companies have to fulfil all the safety requirements and will. In the EU for example this is registration, evaluation, authorisation and restriction of chemicals (Reach). There are five or six different major Reach type applications, and almost every country has its own. Reach provides the necessary incentives or enforcement tools in the documentation and such.

ZR: Can you see CEFIC and Responsible Care, or things like them, being undertaken around the world? What do you think it would take to achieve this? CZ: Responsible Care started in 1984, coinciding with the year of Bhopal. It is well spread now, around the world almost. Currently, I believe there are around 68 countries using it. I don't know if they are fulfilling all of the requirements, but they are at least signing up to much of it. The problem is, within countries not all chemical companies are signing up for Responsible Care. A country may say: ‘We are employing Responsible Care principles,’ but if you ask them, how many companies are members, you find that Responsible Care is actually managed by the chemical industry associations or trade associations, and the number of member companies signed up to it is very small. All the big companies, of course, the global ones operating in many countries, employ the principles of Responsible Care. But its effectiveness is questionable on country basis.

ZR: Traditionally the users of chemical products, and sometimes the chemical industry too, prefer a ‘light touch’ that allows them to be competitive and not need expensive chemical safety and surety regulations. What can be done to educate governments and industry on how best to cooperate with their opposite numbers to promote a sense of unity and mutual respect, towards each other, the citizens, and the environment? CZ: Encouraging governments is really a very hard thing to do. If you talk to any government authority or any officer in the government, they say: ’Well, of course. Our laws and regulations are very strict to protect the safety of our people and the environment.’ But when it comes to the effectiveness of those enforcement issues, they are not that strong. That's my feeling, especially in developing countries.

Industry people, in any country, even developing countries, are aware of the need to work on the safety and security of chemicals. But the way they handle it differs very significantly... ZR: What can be done to encourage greater enthusiasm for chemical safety in countries that aren’t there yet? How do we encourage industry to get together and form associations such as the Turkish Chemical Manufacturers Association and ultimately become a part of the International Council of Chemical Associations? Some countries, such as India, experienced a lot of chemical related explosions in 2020. CZ: Unfortunately, the global market is putting a lot of pressure on the companies, including the internationals and multinationals. Even though the headquarters may be tough on overseeing the activities of their overseas units very closely, the locals are under pressure to look good for headquarters, so, there are mishaps. Also, there’s global competition and price changes. Some countries manufacture some very hard-to-manage chemicals at low cost, but if it is low cost, that means they’re likely lacking on safety and environmental protection .

Safety is the main issue because chemicals are like naughty kids. They need to be trained! They need to be managed properly otherwise if that’s overlooked, if not enough attention is paid to the immediate safety precautions, then chemicals behave unexpectedly, or expectedly, but in a manner that’s unwelcome!

ZR: In your presentation, you talked about adopting a more

integrated risk management approach. Chemical safety and chemical security are two sides of the same coin. So how can we get people to work together and recognise that? CZ: Safety is the fundamentals of providing good control of chemical management. Security involves the illicit use of chemicals by people intent on unpleasant behaviour. Any very dangerous chemical in good hands can be managed properly under safety requirements, but the same chemical in somebody else's hand may become a security risk. The simplest example is sulphuric acid, a very potent chemical. In the right hands sulphuric acid is a very useful chemical that can be managed safely. In the wrong hands it is very destructive.

The difference between safety and security can be difficult to convey in languages other than English, as in lot of other languages the words for safety and security are the same. You may be talking to someone about chemical security, but the meaning is confused as the word is the same for safety. It’s even confusing in Turkish, we mix them, and too often we use them interchangeably as if they have the same meaning or use one when we mean the other.

ZR: In your opinion what are the biggest challenges facing Iraq in terms of hazardous waste management? Do you think they can be overcome in the coming decade? CZ: The challenges for Iraq have to be overcome not in 10 years but sooner than that. I have been in several seminars and workshops for Iraqi people, and there was almost no private chemical manufacturers or recognised chemical trade association, but it was decided to establish one. This syndicate, as it is called, wants to be accepted by government entities and establish a line of communication.

That's the biggest challenge. The government, besides agreeing to talk to them, should trust them, should make them feel liable for the industry’s behaviour. The industry, by the way is not only about manufacturing but also trade in chemicals. The production and the trade people should get together and establish a good association and then consider the principles of Responsible Care. Even if they cannot fulfil all the requirements of Responsible Care, they can follow the guidelines and principles. They have laws for chemical management, and also hazardous waste regulations and

Turkey has been improving its hazmat response agency, AFAD, in the past five years ©CBRNe World

the government wants to enforce them, but on the other hand, they don't know how and who should enforce them effectively.

ZR: In terms of best practice, what do you think is the most valuable piece of guidance you could pass on in terms of hazardous waste management? Is it communication and cooperation, or is there something else you would advise? CZ: Totally, communication and cooperation are key, especially with hazardous waste issues. Generally waste management should start with recognition of the waste. It’s necessary to recognise the existence of hazardous wastes and what they are, otherwise, anything they want to throw away is considered waste. During the conference I was following discussions and the only hazardous waste being talked about was the waste from universities and some government institutes like laboratories. But there are a lot of other sources of hazardous waste in Iraq, like in any country.

One big issue is that there is nowhere for hazardous waste to go, it’ll either go to landfills or dump sites, or into the rivers. If this waste is recognised as hazardous, they will act differently. The definition of hazardous waste has to be understood, it is not only certain types of waste from laboratories or certain lines of manufacturing. People are generating hazardous waste too, all those small companies are generating lots of waste which is not good for the environment because they have to throw it away. There's no designated place for it to go.

To manage the waste effectively the government needs to first establish the existence of the waste producers, how many companies are there, where are they, what do they generate, how is the waste collected and disposed of? Then they can begin to work together to manage the problem.

Once waste is recognised as hazardous people treat it differently ©CBRNe World ZR: Are there comparable standards between Iraq and Pakistan in terms of the training you have been involved with on the benefits of voluntary safety, security and environmental standards? CZ:I would say yes, there are. But the way standards and such are managed or employed, are quite different. It varies from country to country, especially for very heavily populated countries, and those below certain income levels. For developing and underdeveloped countries, it is really hard to enforce or fulfil the regulations’ requirements. I'm sure every country has copycat waste management regulations, a copy/paste version of REACH, but is it manageable? ZR: So, for countries like this, and those with lax chemical safety, do you think the incident in Beirut created shockwaves in governments, or do you think that it was of

passing interest for them and not enough to make them change their ways? CZ: The Beirut thing…Who would keep that much of one type of commodity material for over a year, two years even, in one area just because of unresolved commercial or legal issues, and especially if it is fertiliser? You can't put all your eggs in one basket in terms of safety, same for security, and you don't let anybody with a sledgehammer come near that basket.

ZR: After Beirut we saw quite a lot of scrambling, with people checking what sort of stocks of ANFO they have lying around. But do you think that was a gut reaction, they did a little bit, looked good, but don’t intend to actually do anything about it in the long-term? CZ: Well, I'm sure they are doing something, it's a security issue. It's also an issue of accessibility with certain types of commodity materials, such as ammonium nitrate. It is a common commodity, unless you mix it with fuel oil and find the right igniter, then it becomes an explosive. Farmers are really suffering because of the nonsense restrictions that governments are enforcing on the distribution of ammonium nitrate. In Turkey, for example, they stopped selling it to cooperatives. What do people say? Nothing. Because of that the crop value came down last year from two years ago. Now, they are distributing under tighter security. A terrorist doesn’t necessarily need tonnes of ammonium nitrate for a bad act, so it's not the quantity, it’s accessibility. We should cut the accessibility, that's the most vulnerable area we are facing in chemical security, especially in this region.

ZR: What do you see as the major challenges for chemical safety and security in the next two to three years, and how can countries orientate themselves to face them? How can we encourage both the private and public sectors to enter into voluntary partnerships to tackle chemical security matters together? CZ: The main issue is to open up communication line between the government and the private sector, especially in the area of security. For safety, it is just to enforce the laws there are and keep good track of certain chemicals, especially the dual-use chemicals, and establish a knowyour-customer arrangement, be aware of who is buying what and establish a reporting scheme. In developing countries these issues are usually run by the ministry of the interior. It's not enough because those people do not necessarily know anything about chemical security and safety, they know policing security and keeping people safe. So, communication is the biggest hurdle here.

Government authorities worry about customs duties and taxation, the private sector is concerned about its marketing network. If the government restricts or bans imports, exports, or the production of something, then availability of chemicals becomes a problem for the private sector, which cannot survive, therefore, they have to come together. The government will lose money if they ban certain things because nothing will be manufactured from the things that would have been imported commodities. Also, there is the issue of human safety, as banning something will lead to smuggling and uncontrolled trading. For narcotics, for example, there is good international understanding and cooperation between governments and companies, but for some everyday chemicals, there are problems.

The major challenges are first, realising that there's a problem for both the government side and private sector, then communication. Good governance is the most important. Governance doesn't just mean setting up regulations or copycatting them, but making them doable, workable, enforceable, manageable, and allowing infrastructure for it.