ENVIRONMENT LAW PROJECT

TOPIC: - An Overview of Hazardous

and Other Wastes (Management and
Transboundary Movement) Rules 2016

DONE BY: - AADHITYA NARAYANAN

L19BALB111

BA LLB SEC B

Table of Contents

1
S.NO TITLE PAGE NO
1 Introduction 3
2 Overview of Rules 4-13

2.1 Applicability of the

Rules

2.2 Control Mechanism and

Responsibility for Waste
Management

2.3 Comprehensive
Framework for the Safe
Disposal of Hazardous and
Other Wastes

2.4 Utilization of Hazardous

and other wastes

2.5 Import and Export of

Hazardous and other Wastes

2.6 Illegal Traffic

2.7 Treatment, storage, and

disposal facility for
hazardous and other wastes

2.8 Procedure for recycling,

reprocessing, or reuse of
hazardous waste

2.9 Packaging, Labelling

and Transport of Hazardous
and other Wastes.

2.10 Liability under the

Rules:
3 Constitutionality of Rules 13
4 Reforms/Suggestions 14
5 Conclusion 15
6 Bibliography 16

1.0 Introduction

2
In 1984, the Bhopal gas tragedy marked a devastating event, causing immediate deaths and
long-term environmental damage. The aftermath prompted legislative changes, leading to the
Environment Protection Act in 1986. Despite subsequent laws, the volume of hazardous
waste increased. The Hazardous and Other Wastes (Management and Transboundary
Movement) Rules, 2016, emerged under the Environment Protection Act to address this
growing concern. These rules underscore the importance of effective waste management in
protecting both the environment and individuals from hazardous waste exposure.

Section 3(17) of the rules defines hazardous waste as any substance posing a danger to health
or the environment. This includes wastes specified in schedules, those exceeding
concentration limits, and those exhibiting hazardous characteristics. The potential effects of
such waste on humans, animals, and plants are diverse and uncertain, ranging from mortality
to genetic mutations.

The rules aim to manage hazardous waste by promoting reduction, recycling, and reuse.
Some hazardous waste can be repurposed, used for energy generation, or recovered for
material recycling. The reduction of hazardous waste is vital for both environmental and
human health. Improper disposal in water bodies and landfills leads to environmental
degradation, emitting toxins that harm air, water, and land. These rules play a crucial role in
regulating the import, export, storage, and transportation of hazardous waste. Prohibited
imports and illegal shipments must be re-exported within 90 days. The rules replace the 1989
Hazardous Waste Rules and align with the International Basel Convention. The rules classify
hazardous waste into categories based on their magnitude of hazard, specifying concentration
limits for each class. High-volume low effect wastes, such as fly ash and mine tailings, are
excluded. Schedule I provides a list of processes generating hazardous waste, offering insight
into the types of waste produced.1

2.0 Overview of Rules (Rule 1-24)

The rules governing the management of hazardous and other wastes are structured into
several key sections, each addressing specific aspects of waste management. These sections

1
https://vikaspedia.in/energy/environment/waste-management/hazardous-waste/environment-ministry-notifies-
hazardous-waste-management-rules-2016

3
include Preliminary (Rule 1-3), Procedure for Management of Hazardous and Other Wastes
(Rule 4-10), Import and Export of Hazardous and Other Wastes (Rule 11-15), Treatment,
Storage, and Disposal Facility for Hazardous and Other Wastes (Rule 16), Packaging,
Labelling, and Transport of Hazardous and Other Wastes (Rule 17-19), and Miscellaneous
(Rule 20-24).

2.1 Applicability of the Rules:

The rules define the scope and applicability of hazardous waste, encompassing waste with
various characteristics such as physical, chemical, biological, reactive, toxic, flammable,
explosive, or corrosive, posing a danger to health or the environment. This definition extends
to waste generated during the manufacturing processes of commercial products and includes
those with concentrations exceeding specified limits in Schedule II or exhibiting hazardous
characteristics. Import or export of waste specified in Part A and Part C of Schedule II is also
covered.2

However, the rules outline specific exclusions, making them not applicable to certain
categories of waste. These exclusions include wastewater and exhaust gases regulated by the
Water (Prevention and Control of Pollution) Act, 1974, and the Air (Prevention and Control
of Pollution) Act, 1981. Additionally, wastes arising from ship operations beyond five
kilometres from the relevant base are exempt under the Merchant Shipping Act, 1958. The
rules do not cover radio-active wastes (governed by the Atomic Energy Act, 1962), bio-
medical wastes (regulated by the Bio-Medical Wastes (Management and Handling) Rules,
1998), and municipal solid wastes (addressed under the Municipal Solid Wastes
(Management and Handling) Rules).

In essence, these rules establish a comprehensive framework for the effective management of
hazardous and other wastes, detailing procedures, regulations, and exclusions to ensure
environmentally sound practices.

2.2 Control Mechanism and Responsibility for Waste Management

Rule 4 of the regulations explicitly stipulates that the "occupier" bears the responsibility for
the secure and environmentally sound handling of hazardous wastes generated within their
establishment. This responsibility extends to the implementation of measures for prevention,
2
Ibid

4
minimization, reuse, recycling, recovery, and the safe disposal of both hazardous and other
wastes. Furthermore, the occupier has the authority to send or sell these materials to an
authorized disposal facility for recycling, reuse, or reprocessing.3

In the realm of waste management, industries play a significant role in generating various
hazardous and non-hazardous wastes during their processing and manufacturing activities.
The rules allocate the responsibility for the management of such wastes to both the occupier
and the state government. This signifies a recognition of the challenges associated with the
disposal of hazardous and other wastes.

The occupier, as outlined in Rule 4(2), assumes a crucial role in ensuring the safe and
environmentally sound management of hazardous and other wastes. Rule 4(1) outlines a
series of steps that the occupier must adhere to, encompassing prevention, minimization,
reuse, recycling, recovery, co-processing, and safe disposal. Additionally, the occupier is
obligated to take specific actions, including containing contaminants, preventing accidents,
and mitigating their consequences on both human beings and the environment. To ensure the
safety of personnel working on-site, the occupier is required to provide adequate training,
equipment, and essential information.4

These regulations, therefore, establish a comprehensive framework for waste management,

with a specific focus on the responsibilities of the occupier in ensuring the safe and
environmentally sound handling of hazardous and other wastes. The outlined steps
underscore the importance of a proactive approach to waste management, incorporating
measures for prevention, recycling, and the overall reduction of environmental impact.

2.3 Comprehensive Framework for the Safe Disposal of Hazardous and Other Wastes

Proper and scientific disposal of hazardous and other waste is crucial to mitigate adverse
impacts on human health and the environment. The rules governing this process outline two
key mechanisms for safe disposal: authorization for actual users and authorized disposal
facilities (Rule 4(3)).5

3
Ibid
4
https://www.drishtiias.com/daily-news-analysis/hazardous-and-other-wastes-management-transboundary-
movement-rules-2016

5
https://blog.ipleaders.in/hazardous-waste-management-rules-2016/#Reforms_and_Suggestions

5
Authorized Actual User: An "actual user" is defined as an occupier who procures and
processes hazardous and other waste for activities such as reuse, recycling, recovery, pre-
processing, and utilization, including co-processing (Rule 3(2)). This mechanism ensures that
those directly involved in the productive use of such waste follow established guidelines for
safe disposal.

Authorized Disposal Facility: When an occupier sends hazardous and other wastes to an
authorized disposal facility, they must provide specific information necessary for safe storage
and disposal (Rule 4(5)). Transporting these wastes must adhere to the regulations outlined in
the rules (Rule 4(4)).6

Authorization for Handling Hazardous Wastes (Rule 5): The rules mandate that
individuals engaged in various activities related to hazardous waste, including generation,
processing, treatment, storage, transportation, and disposal, must obtain authorization from
the State Pollution Control Board (SPCB). The SPCB has the authority to grant or refuse
authorization within 120 days of application, contingent upon the applicant's technical
capabilities and compliance with regulations. Authorization is valid for five years, with the
SPCB having the power to impose conditions, refuse, or cancel/suspend authorization if
conditions are not met or if violations occur.7

Application Process: To obtain authorization, individuals must apply in Form 1 to the SPCB
within 60 days from the date of publication of the rules. The SPCB conducts an inquiry, and
upon satisfaction, authorizes the applicant within 120 days using Form 2.8

Monitoring and Compliance: The SPCB retains the authority to monitor compliance with
conditions and regulations. If the holder of the authorization fails to comply, the SPCB can
suspend or cancel the authorization, necessitating the secure storage of residue hazardous
waste.9

This comprehensive framework establishes a robust system for the safe disposal of hazardous
and other wastes, emphasizing accountability, authorization procedures, and adherence to
environmental protection standards.
6
Ibid

7
https://enterclimate.com/blog/rules-governing-the-transboundary-movement-of-hazardous-waste/
8
Ibid
9
S.C. Shastri, Environment Law, (6th Edition), Eastern Book Company, Lucknow, 2018

6
 2.4 Utilization of Hazardous and other wastes

The proper utilization of hazardous and other wastes, whether as a resource or through pre-
processing for co-processing or any other purpose, is subject to obtaining authorization from
the State Pollution Control Board. This authorization is contingent upon adherence to
standard operating procedures or guidelines provided by the Central Pollution Control Board,
as outlined in Rule 9(1). In instances where specific guidelines are unavailable for a
particular utilization, approval must be sought from the Central Pollution Control Board,
which may grant approval based on trial runs (Rule 9(2)).10

Regarding the storage of hazardous and other wastes, occupiers of facilities are permitted to
store such wastes for a maximum of ninety days. However, the State Pollution Control Board
has the authority to extend this period under certain conditions. Extensions are granted in
cases where the occupiers lack access to suitable treatment, storage, or disposal facilities
within the state or when the waste must be stored for the development of a process for
recycling, recovery, pre-processing, co-processing, or utilization. The extension period can be
further prolonged to one hundred and eighty days in specific situations, such as for small
generators (up to ten tonnes per annum), actual users, disposal facility operators, or under
justifiable grounds (Rule 8).11

2.5 Import and Export of Hazardous and other Wastes

The rules governing the import and export of hazardous and other wastes encompass several
key provisions. Importation of hazardous and other wastes specified in Schedule VI is
explicitly prohibited under Rule 12(6). Additionally, the rules expressly forbid the import of
such wastes for disposal, as outlined in Rule 12(1). However, there are exceptions, as
importation is allowed for activities such as recycling, recovery, reuse, and utilization,
including co-processing.12

The Ministry of Environment, Forest and Climate Change holds a central role in managing
the transboundary movement of hazardous and other wastes, as stated in Rule 11. Specific

10
Ibid

11
Ibid

12
Supra note 7.

7
details regarding permissible imports are outlined in Schedule III, with Part A listing items
that can be imported with the prior informed consent of the exporting country and permission
from the Ministry. Part B of the same schedule permits importation by actual users with
Ministry approval, obtained through the submission of Form 5. Importation without
permission is allowed for items listed in Part D, provided that the necessary information is
furnished to Customs authorities in Form 6, accompanied by requisite documents.

On the export front, Rule 14 delineates the process for exporting hazardous and other wastes
from India. Items listed in Part A, Part B, Part C of Schedule III, and Schedule VI necessitate
permission from the Ministry of Environment, Forest, and Climate Change. Applicants must
file an application in Form 5, and the Ministry may impose conditions for export. The
exporter is obligated to maintain records and ensure that the shipment is accompanied by a
movement document in Form 6.13

The Ministry of Environment, Forest and Climate Change serves as the nodal agency for both
the import and export of hazardous wastes. While the import of such wastes into India is
strictly prohibited, exceptions are made for recycling, recovery, reuse, and utilization, subject
to the prior informed consent of the importing country. The case of Research Foundation for
Science v. Union of India emphasizes the need for proper handling of hazardous waste oil
imported under false pretences. Schedule III provides detailed lists of hazardous wastes that
can be imported with consent and those exempt from the requirement of prior informed
consent. Schedule VI outlines items that are entirely prohibited for import. Applicants for
importation must simultaneously submit their applications to the Central Government and the
State Pollution Control Board (SPCB). The Central Government assesses SPCB comments
and verifies the importer's valid registration for waste management. Exporters of hazardous
wastes listed in Schedule III need a no objection certificate for transboundary movement,
insurance coverage, and must inform the Ministry of Environment, Forest and Climate
Change while maintaining records of the entire process.14

2.6 Illegal Traffic

13
Rani, Lata, and Arun Lal Srivastav. "Hazardous waste monitoring and transboundary movement." Hazardous
Waste Management. Elsevier, 2022. 275-287.

14
Supra note 7.

8
The regulations explicitly address the illegality of the export and import of hazardous or other
wastes under certain conditions. Such activities are considered illegal if they occur without
the permission of the Central Government, as outlined in these rules. Additionally, if
permission is secured through falsification, misrepresentation, or fraud, or if the
transportation deviates from the specified shipping details, it falls under the category of
illegal traffic. Moreover, deliberate disposal, including dumping, of hazardous or other waste
in violation of the Basel Convention and international or domestic legal principles constitutes
illegal traffic (Rule 15). In instances of the illegal import of wastes, the regulations stipulate a
mandatory course of action. The importer becomes obligated to re-export the waste at their
own expense within a period of ninety (90) days from the date of arrival into India. This re-
exportation process is conducted under the supervision of the relevant Port and customs
authorities.15

Furthermore, these rules encompass provisions for various aspects of hazardous waste
management. They outline specific procedures and standards for the treatment, storage,
disposal, packaging, labelling, and transportation of hazardous wastes. This comprehensive
framework ensures that the entire lifecycle of hazardous waste is carefully regulated to
prevent adverse environmental and health impacts while complying with international
conventions and legal principles.

2.7 Treatment, storage, and disposal facility for hazardous and other wastes

Treatment, Storage, and Disposal Facilities (TSDFs) for hazardous and other wastes are
subject to specific regulations that delineate key responsibilities throughout their
establishment and management. One crucial aspect is the identification of suitable sites for
these facilities, a responsibility that may be undertaken by the state government, the occupier,
the facility operator, or any association of occupiers. This collective or individual
responsibility is outlined in Rule 16, emphasizing the pivotal role of the State Pollution
Control Board in overseeing the entire process within the state. In the event of accidents
during the transportation of hazardous or other wastes or at the facility itself, immediate
action is imperative. The occupier, operator, or transporter is obligated to promptly report
15
Supra note 1.

9
such incidents to the State Pollution Control Board through telephone or email. This reporting
duty, outlined in Rule 22, is reinforced by the subsequent submission of a detailed report in
Form 11, providing comprehensive information about the incident. This reporting mechanism
ensures the swift communication of incidents, enabling timely responses and regulatory
actions.16

Overall, these regulations establish a structured framework for the responsible management
and oversight of TSDFs. The rules underscore the significance of proactive measures, both in
the site identification process and in the reporting and handling of accidents. This emphasis
reflects a commitment to safeguarding environmental and public health, highlighting the
interconnected responsibilities of various entities involved in the establishment and operation
of Treatment, Storage, and Disposal Facilities for hazardous and other wastes.

2.8 Procedure for recycling, reprocessing, or reuse of hazardous waste

To facilitate the recycling, reprocessing, or reuse of hazardous waste, individuals or entities

are required to follow a specific procedure outlined by the regulations. For these purposes, an
application must be submitted to the Central Pollution Control Board (CPCB), accompanied
by a consent letter from the State Pollution Control Board (SPCB) for the granting or renewal
of registration. The CPCB evaluates the application to ensure that the applicant utilizes
environmentally sound technology and possesses the necessary technology facilities and
equipment for the proper recycling, reprocessing, and reuse of hazardous waste. Upon
satisfaction, the CPCB grants registration with specific conditions attached. The processing
of such applications is subject to a time frame, with a commitment to disposing of the
application within 120 days from the date of receipt. The registration obtained through this
process remains valid for a duration of five years. Importantly, before rejecting an
application, the regulations mandate providing the applicant with an opportunity to be heard,
ensuring a fair and transparent assessment of the request. 17This structured procedure aims to
regulate and oversee activities related to the recycling, reprocessing, or reuse of hazardous
waste, promoting environmentally responsible practices within a defined legal framework.

2.9 Packaging, Labelling and Transport of Hazardous and other Wastes.

16
Supra note 4.
17
Supra note 13.

10
Packaging, labelling, and transportation of hazardous and other wastes are subject to strict
regulations outlined in the rules. Any occupier or facility operator dealing with such wastes
must adhere to guidelines provided by the Central Pollution Control Board (CPCB) to ensure
safe handling, storage, and transport. The packaging of hazardous and other wastes must
conform to the specifications stipulated by the CPCB.

According to Rule 17, the labels affixed to the waste packages must meet specific criteria.
These labels should be made of non-washable material, weatherproof, easily visible, and
compliant with the conditions outlined in Form 8. This ensures that the labels remain intact
and legible throughout the handling and transportation process.

Transporting hazardous and other wastes must comply with the regulations set forth in these
rules, as well as those established by the Central Government under the Motor Vehicles Act,
1988. Additionally, adherence to guidelines issued by the CPCB is crucial in ensuring the
safe and lawful transportation of such wastes. Rule 18 emphasizes the importance of proper
labelling during transportation, with waste accompanied by movement documents in Form
10.18

In the event of an emergency during transportation, it is imperative that the transporter is

well-informed about the necessary measures to be taken. This provision, as outlined in Rule
18, underscores the significance of preparedness and communication in addressing
unforeseen circumstances. This comprehensive approach, spanning from packaging to
transportation, reflects the commitment to maintaining the safety and integrity of handling
hazardous and other wastes throughout the entire process.

2.10 Liability under the Rules:

The regulations establish a comprehensive framework for liability concerning the handling
and management of hazardous and other waste. According to Rule 23, the occupier, importer
or exporter, and the operator of the disposal facility bear responsibility for any damages
inflicted upon the environment or third parties due to improper waste handling and
management. Financial penalties for violations of these rules are determined by the State

18
Supra note 9.

11
Pollution Control Board (SPCB) with prior approval from the Central Pollution Control
Board (CPCB).19

Appeal Procedures:

In the event of disputes or adverse decisions by the State Pollution Control Board, individuals
affected have recourse through an appeal process outlined in Rule 24. Any person aggrieved
by the suspension, cancellation, refusal of authorization, or its renewal can submit an appeal
using Form 12. The designated Appellate Authority, namely the Environment Secretary of
the State, handles these appeals. The appellant must file the appeal within thirty days from
the date of the order's communication.20

Additionally, Rule 24 allows for considerations beyond the initial thirty-day period if the
Appellate Authority is satisfied that the delay was due to sufficient cause. Each appeal
undergoes a timely disposal process, with the Appellate Authority ensuring resolution within
sixty days from the date of filing.

Accident Reporting:

Moreover, the regulations emphasize prompt reporting in case of accidents. If an accident

occurs at any facility managed by the occupier, especially those dealing with hazardous or
other wastes, or during transportation, immediate notification to the State Pollution Control
Board is mandatory. This notification, which can be made via phone or email, ensures timely
response and appropriate actions to mitigate the impact of the accident on the environment
and public safety. This integrated system of liability and appeal mechanisms, coupled with
stringent accident reporting, enhances the overall effectiveness of the Hazardous Waste
Management Rules.21

3.0 Constitutionality of Rules

In the case of Research Foundation for Science vs. Union of India (2000) 9 SCC 42, the
Supreme Court of India took a firm stance on the disposal of hazardous waste, emphasizing

19
Ibid

20
Ibid

21
Supra note 5.

12
that the Union of India has the responsibility to ensure that such disposal does not result in
environmental pollution. The court observed a lack of concerted and consistent efforts by the
ministry in implementing hazardous waste rules. In response to this, the Supreme Court
appointed a high-powered committee to address these concerns.22

Subsequently, in the case of Ganpathi Metals vs. M.S.T.C. Ltd (2005) 12 SCC 169, the
Supreme Court clarified that rules governing the disposal of hazardous wastes, which impose
statutory obligations, are applicable to involved parties regardless of whether they are
explicitly mentioned in tender notifications. This underscores the court's commitment to
enforcing regulations concerning the safe disposal of hazardous waste generated by
industries.23

Turning to the constitutionality of these rules, the Supreme Court, in the same case of
Research Foundation for Science vs. Union of India, asserted that the rules align with
constitutional provisions, specifically Articles 21, 47, and 48-A. However, the court directed
the Central Government to bring these rules in conformity with the Basel Convention and the
constitutional articles. In a subsequent order related to the same case, the Supreme Court
reiterated the importance of strict adherence to Basel Convention norms. The court
emphasized the necessity of following these international standards before allowing the entry
of vessels suspected of carrying toxic and hazardous materials into Indian territorial waters.
This underscores the court's commitment to aligning national regulations with global
environmental standards, aiming to prevent pollution and protect the health of both current
and future generations.24

4.0 Reforms/Suggestions

Several reforms have been implemented to enhance hazardous waste management, including
the 2019 amendment to the Hazardous and Other Wastes (Management and Transboundary
Movement) Rules, 2016. While this amendment aimed to simplify stringent regulations, it
may not be adequate in controlling the industry as it primarily outlines procedures without
clear consequences for non-compliance.

22
Supra note 7.
23
Supra note 1.
24
Supra note 4.

13
One notable issue is the time-consuming and paperwork-intensive process for obtaining
permissions, which may impede organizational operations. Introducing online portals could
streamline this process, reducing both time and effort. Another concern is the cost of testing
waste, particularly for Small Quantity Generators (SQGs). SQGs, producing small quantities
of waste, may benefit from subsidized testing rates, addressing financial barriers to
compliance. While the 2016 rules mandate training for workers, its implementation is left to
facility operators. Standardized training programs, like the Hazardous Waste Worker
Training Programme in the United States, could ensure consistent training and adaptability to
guidelines and technological changes. 25Despite the necessity of stringent rules for hazardous
waste management, some find the 2016 rules overly restrictive. Suggestions like
implementing online portals and providing training aim to facilitate adherence to the rules
while ensuring industry efficiency. The recent amendment in 2019 aimed to improve
procedures and relax certain requirements for consent from authorities. However, incidents
like the Visakhapatnam gas leak highlight the critical importance of adhering to proper
procedures to prevent disasters. The rules also played a role in legal cases, such as The
Commissioner of Customs vs M/S City Office Equipment, emphasizing the importance of
strict adherence.

5.0 Conclusion

The Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016,
born out of the aftermath of the 1984 Bhopal gas tragedy, represent a significant step forward
in India's hazardous waste management. These rules, formed under the Environment
Protection Act of 1986, define hazardous waste, and establish a comprehensive framework
emphasizing reduction, recycling, and reuse. They replace the 1989 Hazardous Waste Rules
and align with international standards, particularly the Basel Convention. The rules cover
various aspects of hazardous waste management, from classification and import-export
regulations to the operations of treatment facilities and waste transportation. Rule 2 defines
the applicability of the rules, offering clarity on the types of waste covered and specifying
exclusions. Rule 4 places responsibility on the "occupier" for the secure handling of
25
Supra note 9.

14
hazardous wastes, outlining specific duties from prevention to safe disposal. A robust control
mechanism attributes responsibility for damages to the environment or third parties to the
occupier, importer, exporter, and disposal facility operator. Financial penalties are determined
by the State Pollution Control Board, ensuring accountability. The rules incorporate an appeal
mechanism (Rule 24) for individuals to contest adverse decisions. The constitutionality of
these rules has been affirmed by the Supreme Court of India, aligning them with
constitutional provisions and international standards. The court's directives emphasize
adherence to global conventions, particularly the Basel Convention. Despite progress,
concerns persist, leading to the 2019 amendment aimed at simplifying regulations.
Challenges include the time-consuming permission process and the cost of waste testing.
Proposed improvements include introducing online portals for form submissions, providing
subsidized testing rates for Small Quantity Generators (SQGs), and establishing worker
training programs modelled after successful international initiatives. While the Hazardous
Waste Management Rules, 2016, provide a robust framework, ongoing reforms and strategic
enhancements are essential to address emerging challenges, ensure industry compliance, and
protect the environment and public health from the adverse effects of hazardous waste.

6.0 Bibliography

Websites

1. https://blog.ipleaders.in/hazardous-waste-management-rules-2016/
#Reforms_and_Suggestions
2. https://vikaspedia.in/energy/environment/waste-management/hazardous-waste/
environment-ministry-notifies-hazardous-waste-management-rules-2016
3. https://www.drishtiias.com/daily-news-analysis/hazardous-and-other-wastes-
management-transboundary-movement-rules-2016

15
 4. https://enterclimate.com/blog/rules-governing-the-transboundary-movement-of-
hazardous-waste/

Books

1. S.C. Shastri, Environment Law, (6th Edition), Eastern Book Company, Lucknow, 2018

Article

1. Rani, Lata, and Arun Lal Srivastav. "Hazardous waste monitoring and transboundary
movement." Hazardous Waste Management. Elsevier, 2022. 275-287.

16