Challenges and recommendations in waste management
In Mexico, waste is classified as (i) hazardous waste (RP), (ii) special handling waste (RME), (iii) urban solid waste (RSU), and (iv) hazardous biological-infectious waste(RPBI). For the hydro carbons sector, ASEA is responsible for issuing the registry as generators of RP and RME and approving waste management plans that aim to minimize waste generation and maximize valorization.
Therefore, to operate without obstacles, the regulated must implement integrated waste management (IWM) in their management plans. IWM must consider, from the beginning, the amount and variety of the generated waste, the actors involved, and regulatory compliance.
The IWM is based on three fundamental principles: comprehensive management, valorization, and shared responsibility, and begins before the execution of the activities that generate waste, from the diagnosis and design of the management plans to the execution of the activities and the final destination of waste (Fig. 1).
Waste management must be addressed comprehensively and not in isolated stages. This will allow better control over the generated waste and reduce the risk of non-compliance.
Operators carry out the IWM through third parties that perform the activities of collection, transportation, storage, treatment, and final disposal of waste. Third-party control is one of the main challenges in waste management, but not the only one. The following table summarizes some associated with the IWM and our recommendations:
Operators generate large amounts of waste throughout the stages of an oil project (exploration, appraisal, development, production, and abandonment), and mismanagement of these can lead to significant penalties (see the box to the right). Therefore, visualizing and adequately executing the IWM will allow greater efficiency and the development of scale economics.
Hiring companies that handle all types of waste estimated to be generated will reduce operational complexity and optimize human and financial resources. Additionally, it will allow compliance with the applicable regulations and reduce the risk of environmental impacts.
Hierarchy in waste management
Management plans must be designed considering the hierarchy for waste management and minimization:
Possible actions and sanctions derived from non-compliance with the GIR:
- Fine of 30K to 50K days of the minimum wage (2.9 to 4.8 million Mexican pesos).
- Temporary or definitive, partial or total closure of polluting sources and facilities.
- Suspension of activities.
- Administrative arrest for up to 36 hours. Confiscation of instruments, specimens, products, or by-products.
- Suspension or revocation of concessions, licenses, permits, or authorizations.
- Remediation of contaminated sites.
Operators must be prepared to attend verification visits and deal with citizen complaints. As well as having effective emergency response plans.
At Talanza, we have experts executing specialized waste audits to ensure regulatory compliance before, during, and after operations.
We offer regulatory «Health check» services to identify possible risks of non-compliance and implement actions to operate without obstacles.
- ASEA: National Agency for Industrial Safety and Environmental Protection of the Hydrocarbons Sector.
- Valorization: Principle and set of associated actions whose objective is to recover the remaining value or the calorific value of the materials that make up the waste by reincorporating them into production processes.
- SASISOPA: Industrial Safety, Operational Safety, and Environmental Protection Administration System.
- MIA: Environmental Impact Statement.
- COA: Annual Operation Certificate. NOM: Official Mexican Standard. EvIS: Social Impact Assessment.