Waste Management in Nigeria through Effective Policy: Strengthening the Legal Framework – Bolaji Ramos

Introduction: 

For those who have little or no knowledge on the synergy between (improper management of) waste and climate change, the sudden explosion of the Olusosun Dumpsite and the attending fires, must have given them a hint. Reports have it that the fire started gathering momentum on the evening of 14^th March, 2018, until it reached a point of a series of sudden explosions that engulfed vehicles and buildings in the vicinity.[1] The burning fires, together with thick smokes that came from them, continued for days and took over the whole atmosphere in the site’s environs. The Lagos State Government issued a statement on 15^th March, 2018, and attributed the explosion to ‘natural outcome of trapped gasses, escaping to cause combustion, a situation which occurs occasionally in dumpsites.’[2]

While this position held by the Lagos State Government may be queried in many ways, as gaseous combustion from a dumpsite could be avoided through proper waste management that complies with international standards, the intention here is merely to link the connection between waste and climate change. According to certain experts commenting on the incident:[3]

“Decomposing materials…produce gases such as the highly inflammable methane (as implicated in the fire) which contributes to global warming. Global warming effect of methane is 21 times more than that of carbon dioxide. Now when dumpsites burn as in our present situation, there is emission of toxic substances into the atmosphere from plastics and other materials.”

In effect, whenever the issue of waste or its proper management is being brought to the fore, one cannot, in the real sense of it, divorce it from other triggers of global warming and attending climate change. Waste poses serious threat to achieving a healthy environment, conducive atmosphere, wholesome living and even positive economic and political fabrics of a nation. Waste is environmentally, socially, politically and economically costly. Ladies and Gentlemen, defining waste and stating its types at this point has become almost mandatory, as this will give a guide as proper policy formulation and legislative process.

Defining Wastes and Its Classification:

By its nature, waste is any object or substance that is destined to be disposed, discarded, recycled or destroyed. What constitutes waste could be subjective (based on individuals’ assessment) or objective (based on the law). Different attempts have been made by different legislative enactments, organizations and individuals to define waste. But let me take a cue from the 1989 Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal.

Article 2(1) of the Basel Convention defines wastes as ‘substances or objects, which are disposed of or are intended to be disposed of or are required to be disposed of by the provisions of national law.” The definition is broad and has three different legs, as it pertains to substances or objects that may be called waste— (a.) substances or objects that the users have disposed already; (b.) substances or objects that the users are yet to but planning to dispose in the near or remote future; and (c.) substances or objects that the law requires the users to dispose, even if the users have no intention or plan to dispose them.

What this means is that any policy, regulation or enactment on waste disposal and management must contemplate these three different instances— wastes that have been disposed already; wastes waiting to be disposed; and wastes that the law requires must be disposed.  The major distinction between the three is that while first and second legs of the definition are subjective and based on individuals’ discretion of what is no longer of value to them which they wish to dispose as waste, the third leg is objective and based on the government’s determination of what qualifies as waste and should be disposed in accordance with the law. Whether our extant laws effectively provide for these three situations is a burning question to be considered another day.

According to the United Nations Economic Commission for Europe,[4]

‘Waste can be classified according to its sources, generating process, composition, characteristics, waste generation and collection streams, etc. In practice, different ways of classifying wastes are used depending on the purpose for which the data are to be used, and it is often not clear what the underlying principles are, and the concepts are overlapping.’

In the real sense of it, therefore, there would appear to be no generally acclaimed classification for waste. Wastes (substances or objects) have been classified differently and into many types. Examples of such classes and types are as follows:

1. Solid Wastes— include glass, plastic, rubber, plasterboard, ceramics, bricks, concrete, building and demolition wastes or metallic wastes. Solid wastes may come in two forms— (a.) Putrescible Solid Waste which contains organic matter capable of being decomposed by microorganisms and causing offensive odours; and (b.) Non-putrescible Solid Waste which contains non-organic matter that may not be capable of decomposing.

2. Liquid Wastes— Include wastewater, fats, oils or grease (FOG), used oil, liquids, solids, gases, or sludges and hazardous household liquids.[5]

3. E-Wastes— include used electrical and electronic wastes destined to be disposed, discarded or recycled.

4. Special Wastes— include clinical wastes, cytotoxin wastes, pharmaceutical and medical wastes and related wastes[6]

5. Hazardous Wastes— include wastes that have substantial or potential threats to public health and the environment,[7] with features such as ignitability, reactivity, corrosivity and toxicity.[8] Hazardous wastes can be solid, liquid, gaseous or even e-waste.

6. Harmful Wastes— include any injurious, poisonous, toxic or noxious substance and nuclear waste that emits radioactive substance in such quantity to subject any person to the risk of death, fatal injury or incurable impairment of physical and mental health.[9]

As earlier indicated, understanding the scope of wastes, its nature and classification is instructive before conceiving proper policy formulation and legislative process for waste management. With the identified classes of waste in view and their somewhat unrelatedness, it is arguable that these classes of waste somewhat have the tendency of defying the same waste management approach. Without prejudice to overlapping classes of waste, different classes of waste will often warrant different management approaches. Our law and policies need to effectively and sufficiently contemplate this.

Existing Legal Framework on Waste Management:

In Nigeria today, there is already a wide range of laws regulating the environment, and by extension waste disposal and management. The Environmental Law Research Institute (ELRI) compiled a list of up to 100 laws and statutory institutions regulating waste management in Nigeria both at the federal and state levels.[10]  That there is dearth of laws on this area has never been an issue. The overall body of laws regulating waste in Nigeria comes in form of statutory enactments (Acts of the National Assembly and Laws made by State Houses of Assembly of the respective 36 states in Nigeria) on the one hand and regulations/policies made by the statutory institutions on the other hand. For want of space, I shall concentrate only on the Environmental Protection Law of Lagos State 2017 (because of its innovativeness) and some of the salient Acts of the National Assembly.

(A) Environmental Protection Law of Lagos State 2017 

This law is one of the most comprehensive laws made by the Lagos State House of Assembly and the leading law on overall environmental protection, not only in Lagos State, but in Nigeria at large. The law is a consolidation of all the environmental-related laws in Lagos State, and it repeals major environmental enactments such as LAWMA Law, LASEPA Law, Lagos Water Sector Law and Environmental Sanitation Law. The law, however, retains the authorities such as LAWMA and LASEPA established under the repealed enactments. The law has 526 sections with schedules and forms, and it is divided into 14 parts. The part relevant to waste management is Part III which establishes LAWMA[11] and confers it with powers[12] and functions[13] relating to waste management generally.

Under the law, waste is inclusively defined to mean any substance, object or anything that constitutes scrap or unwanted surplus which is discarded or required to be disposed or arising from application of any process.[14]  The classes of waste envisaged under the law are domestic waste, commercial (bulk containerized) waste, industrial waste, special industrial waste, hazardous waste, recyclable waste, healthcare waste, building waste and household waste.[15] All the classes come under the umbrella of what is termed ‘controlled solid waste.’[16]

As presently is, this law has taken innovative steps to provide for effective and pragmatic management of waste in Lagos State generally. The below listed facts will lend credence to this view—that is, LAWMA is empowered to:[17]

1. take over overall management of controlled waste in the state. In doing this, LAWMA must work with the LGAs, collaborate with key stakeholders in waste management sector and licence waste disposal contractors;

2. monitor environmental impact of waste management as it relate air, water and soil pollution, and inspect waste management facilities permitted by it;

3. issue, suspend, renew and revoke licenses of private waste collectors and waste recycling plants;

4. approve and monitor all solid waste disposal systems in the state;

5. regulate proper segregation and containerization of waste through formulation and public awareness;

6. preserve proper collection, transportation, treatment and disposal of waste by adopting best environmental practice;

7. engage in conjunction with LGAs waste disposal contractors to collect and dispose waste from streets, roads and designated public places within the state;

8. prohibits operating of waste collection, transportation, recycling and disposal business without a licence

The Law also:[18]

9. compels commercial and industrial waste generators not to dispose waste on their own and deal only with approved private waste operators;

10. compels domestic or bulky waste generators to collect and dispose their waste within a reasonable time or they may deal with licenced operators;

11. compels healthcare, industrial and biomedical solid waste generators to authorize LAWMA first in writing before prior to the commencement of such activities; and

12. regulates treatment and disposal of special or hazardous waste.

With all these in place, it is not in doubt that the law envisages most of the classes of waste earlier mentioned, their nature and how they can be properly managed. To cap it all, the law further makes adequate provisions for enforcement which must be carried out by LAWMA and the Environmental Health Officers of the LGAs Local Government Areas in collaboration with the Environmental Sanitation Corps.[19]

i) The NESREA Act 2007

National Environmental Standards and Regulations Enforcement Agency Act is the principal law in Nigeria today which governs protection of the overall environment. It particularly aims at creating standards, regulations, principles and guidelines for the protection of the Nigerian environment.  With respect to waste regulation, NESREA, as an agency established under the Act, has a duty to:

a) Control and regulate concentration of gaseous wastes, emissions and substances in the air;[20]

b) Enforce compliance with the provisions of international agreements, conventions and treaties on biodiversity, marine environment and pollution[21];

c) Enforce compliance with policies, standards, legislation and guidelines on water quality, including pollution abatement[22]; and

d) Enforce through compliance monitoring, the environmental regulations and standards on land, seas, oceans and other water bodies.[23]

The Act prohibits discharge of harmful quantities of any hazardous wastes and substance into the waters of Nigeria or at any adjoining shorelines, except where such discharge is permitted or authorized under any law in force in Nigeria.[24] Any violation of the provisions of the Act or guidelines and regulations made pursuant to it by NESREA is a criminal offence, and the offender could be liable to up to N1,000,000 (one million naira)fine and/or imprisonment for up to five years.[25]

One noticeable gap in this law is that NESREA is expressly disabled under sections 7 and 8 of the Act from regulating wastes as they relate to the oil and gas sector.[26] My considered view is that excluding the oil and gas sector from NESREA’s regulation has the high tendency of bringing about a situation where one area of the environment is better regulated or protected than another area of the environment due to unequal or difference in the practice and procedure of the waste management regulatory agencies.

ii) The Oil in Navigable Waters Act 1968

The Oil in Navigable Waters Act is a domesticated version of the1954 Convention on Prevention of the Pollution of the Sea By Oil. It deals with prohibition discharge of waste (i.e oil and any mixture containing oil). Section 3 of the Act appears to be the principal section that covers hazardous wastes and liquid wastes. The section provides thus:

(1) If any oil or mixture containing oil is discharged into waters to which this section applies from any vessel, or from any place on land, or from any apparatus used for transferring oil from or to any vessel (whether to or from a place on land or to or from another vessel), then subject to the provisions of this Act- 

(a) if the discharge is from a vessel, the owner or master of the vessel; or

(b) if the discharge is from a place on land, the occupier of that place; or

(c) if the discharge is from apparatus used for transferring oil from or to a vessel, the person in charge of the apparatus, is guilty of an offence under this section. 

(2) This section applies to the following waters, that is-

(a) the whole of the sea within the seaward limits of the territorial waters of Nigeria; and

(b) all other waters (including inland waters) which are within those limits and are navigable by sea-going ships.

Apart from this, the section scopes both the limits of the territorial waters of Nigeria on the one hand and the inland waters within the limits on the other hand. A breach of section 3 is a criminal offence, and upon conviction the polluter may be asked by the court to pay in fine which may be ordered to be used to clean up the pollution.[27]

iii) Harmful Wastes (Special Criminal Provisions) Act 1988

The Act seeks to prohibit the carrying, depositing and dumping of harmful wastes on any land and the territorial waters of Nigeria.[28] Even though the Act was enacted by the Nigerian legislature and not a treaty domesticated in Nigeria, it can be said to have taken after the 1972 Convention on Prevention on Marine Dumping, popularly known as the London Convention which also aims to prohibit dumping of harmful and noxious wastes captured in the Black and Grey Lists respectively.

This law unarguably comes with very strictest penalties. A polluter (corporate or individual) found guilty of dumping or attempting to dump harmful wastes into the marine environment under this Act can incur criminal and civil liability simultaneously. Where the polluter is convicted for the offence, the person is to be sentenced to life imprisonment, in addition to forfeiture of any carrier, aircraft, vehicle, container and any other thing whatsoever used in the transportation or importation of the harmful waste.[29] If the discharge emanated from land, the polluter will also forfeit the land to the Federal Government.[30] The sentence, which is free from the exercise of the discretion of the judge as it is absolute, is the same where the polluter only makes an attempt.[31]

The Minister can also seal a dumping site for up to one year on reasonable suspicion that the site is being and will be used for dumping harmful wastes.[32] Also, civil liability will arise against the polluter if the dumping of harmful wastes into the territorial waters, exclusive economic zone or contagious zone, caused damage, except where the damage is the fault of the person affected by it or where the person consented to it.[33]

iv) Petroleum Act 1969 and Petroleum (Drilling & Production) Regulations

The Petroleum Act is presently the principal law in Nigeria regulating oil and gas exploration and licensing for oil mining lease (OML), oil prospecting license (OPL) and oil exploration license (OEL). Section 9 of the Act gives the Minister of Petroleum Resources power to make regulations pertaining to the following:

a) prevention of pollution of water courses and the atmosphere;[34]

b) regulating the construction, maintenance and operation of installations used in pursuance of this Act, which include offshore operation construction and installations;[35]

c) defining dangerous petroleum and dangerous petroleum products, prescribing anchorages for ships carrying dangerous petroleum or dangerous petroleum products as cargo and requiring those ships to proceed to and remain at those anchorages;[36] and

d) subject to subsection (2) of this section, regulating the transport of petroleum and petroleum products, prescribing the quantity of petroleum and petroleum products which may be carried in any vessel, cart, truck, railway wagon or other vehicle, the manner in which they shall be stored when being so carried, the receptacles in which they shall be contained when being so carried and the quantities to be contained in those receptacles, and providing for the search and inspection of any such vessel, cart, truck, railway wagon or other vehicle.[37] 

In accordance with the regulation making power under section 9 of the Act, different regulations have been made over the years by the successive Ministers of Petroleum Resources. Very noticeable among the regulations made pursuant to the Act is the Petroleum (Drilling and Production) Regulations.  (Regulation 25) which provides that:

The licensee or lessee shall adopt all practicable precautions, including the provision of up-to-date equipment approved by the Director of Petroleum Resources, to prevent the pollution of inland waters, rivers, watercourses, the territorial waters of Nigeria or the high seas by oil, mud or other fluids or substances which might contaminate the water, banks or shoreline or which might cause harm or destruction to fresh water or marine life, and where any such pollution occurs or has occurred, shall take prompt steps to control and, if possible, end it.

v) Other Regulations— 

As the leading national agency responsible for controlling and regulating pollution (all forms of wastes inclusive), NESREA has made a good number of regulations that seek to curtail and/or prevent disposal of all classes of waste being produced by different sectors of the economy and individuals. The Regulations come with punishments as provided in the enabling Act. Some of the Regulations are as follows:

1. National Environmental (Sanitation and Waste Control) Regulations
2. National Effluents Limitations Regulation
3. Management of Solid and Hazardous Waste Regulations
4. NEP (Pollution Abatement in Industries and Facilities Generating Waste) Regulations
5. National Environment (Sanitation and Wastes Control) Regulations.
6. National Environmental (Electrical/Electronics Sector) Regulations
7. National Environmental (Non-Metallic Minerals Manufacturing Industries Sector) Regulations.
8. National Environmental (Control of Vehicular Emissions from Petrol and Diesel Engines) Regulations.
9. National Environmental (Construction Sector) Regulations.
10. National Environmental (Domestic and Industrial Plastics, Rubber and Foam Sector) Regulations.
11. National Environmental (Control of Bush/Forest Fire and Open Burning) Regulations.
12. National Environmental (Base Metals, Iron and Steel Manufacturing/Recycling Industries) Regulations.
13. National Environmental (Standards for Telecommunications/Broadcasting Facilities) Regulations.
14. National Environmental (Chemicals, Pharmaceuticals, Soap and Detergent Manufacturing Industries) Regulations.

Towards Effective Legal and Policy Policing:

According to the Federal Government of Nigeria, National Policy on Municipal and Agricultural Waste (August 2012), over 72% of houses did not have any formal arrangement for collection and disposal of waste.  It should be recalled that on 30^th November, 2017, stakeholders from across the nation gathered for a one-day National Stakeholders’ Workshop for the Review and Validation of Draft National Policy on Solid Waste Management in Nigeria.[38]  It was explained that:

The policy should be able to address the unwholesome practice of co-disposal of general and hazardous wastes on land, water bodies, roads and uncontrolled and open burning of wastes; as well as promote waste reduction at source, recycle and reuse, resource conservation and environmental protection. It will also set down clear framework for private sector participation and investment including Foreign Direct Investment in waste management, as well as cooperation and active participation of all including citizenry, corporate bodies, NGOs/CBOs, development partners, and private practitioners in the environmental sector.

There is nothing new in the approaches sought to be taken by the policy document in the management of (solid) waste in Nigeria.  Waste management policies that the general body of our laws has favoured with respect to solid waste are recycling and reuse. With respect to hazardous and other special waste, our law favours treatment and regulated disposal.[39] In effect, our extant laws (both at the national and state levels) are not deficient or short of policies and regulations on waste management. In the light of the number of existing regulations on waste by actors such NESREA at the national level and LAWMA (and the likes) at the state level, it will be unrealistic to conceive that we don’t already have sufficient and effective law and policies in place.  In fact, as at 2012 when LAWMA (in its own name and spirit) was still in active and efficient operation, the achievements of LAWMA were so enormous that any responsible government would want to continue to give it accolades.  Iriruaga reported the following to actively be in place in respect of LAWMA:[40]

a) A compost plant at Ikorodu for the treatment of market waste which generated a minimum of 24,000 tons and maximum of 42,000 tons of compost in the second half of 2011;

b) A waste-to-energy plant at Ikosi Market that generates biogas from the market waste which is used to operate a 2KVA generator at the market;

c) Aplastic recycling plant at Olusosun for the conversion of empty plastic water packets into garbage bags; and

d) Initiating recycling clubs in secondary schools to instill recycling habits in young people. 

What then is our problem on waste management? This is a simple question, and I shall face it with a simple answer. Our problem is lack of (effective) enforcement of the extant laws and policies— which is often brought about by a number of factors. The only way to achieve proper management of our waste is by strengthening our laws and policies through the instrumentality of effective enforcement. Major factors impeding achieving enforcement of waste management laws and policies are:

1. Lack of political will:

An unwilling government (together with its agencies) cannot achieve proper enforcement of waste management laws and policies no matter the number of enactments on waste management we have available. The government is the driver that drives all the machineries of the state. If there is unwillingness on the part of the government, little is what can be achieved.

2. Politicization of waste management:

As mentioned earlier, improper management of waste may trigger of global warming and attending climate change and pose serious threat to achieving a healthy environment, conducive atmosphere, wholesome living and even positive economic and political equilibrium in a nation. A matter as serious as waste management should never be politicized by the government, as doing so may have negative environmental, social, political and economic effects. An agency like LAWMA that has performed wonderfully well in the past should not just be relegated to in the name of politics. A successive government or holder of a political office should not destroy an existing waste management approach that has proven to be very effective. Waste management is a serious business and it is a public health issue that should be handled with utmost sincerity of purpose by any government or agency.

3. Corruption of enforcement agents and officers: 

Up till today, one of the reasons why it is difficult in Nigeria to properly manage wastes in line with the existing laws and policies is that most of the enforcement agents are scaringly corrupt. What we have seen in practice is a situation where officers who are sent to enforce waste management law are seen soliciting for kickbacks for the violators so that they can let the violators go scot free. This has become so pronounced that some co-coordinators of these officers are aware and are actually part of the scheme.

4. Poor follow-ups and supervision of licensees by the enforcement authorities: 

The enabling laws of most of the enforcement agencies normally empower or mandate the authorities to follow up and supervise private waste management licensees and other stakeholders involved in waste management.  There has always been a culture of poor follow-ups, and lack of adequate supervision and this has been one of the reasons why laws are not being enforced.

5. Over-dependency of LGAs on State Government & Agencies:

While waste management laws often put the LGAs in a subservient position to the State Governments or statutory authorities on waste management, the LGAs are constitutionally empowered to (independently) function as waste managers in respect of certain wastes or activities that may bring about wastes. For example, the LGAs are empowered under the Constitution[41] to maintain public conveniences, drains, sewage and refuse disposal. This is a constitutional provision, and a law that seeks to take it away from the LGAs will be faced with constitutional rejection. LGAs need not wait for NESREA, LAWMA, VisionScape or any other waste management authorities (by statute or by contract) before they ensure proper waste management in their constituencies.

Conclusion:

Ladies and gentlemen, I have tried to discuss the topic “Waste Management in Nigeria Through Effective Policy: Strengthening the Legal Framework”. To achieve this, I relied on the definition of waste as captured in the 1989 Basel Convention, and with it I explained the nature and classes of waste. I took a look at the existing legal framework on waste management both at the Federal level and Lagos State, and I reached the conclusion that while it would be unrealistic to opine that we don’t already have sufficient and effective law and policies on waste management, what we have always lacked is enforcement of the extant legal laws and policies.  Through effective legal and policy policing cum enforcement, Nigeria still has hope of proper management of waste and avoidance of direct impact of poor waste management, one of which is global warming and the attending climate change.

Being a paper presented by Bolaji s. Ramos (bolajiramos@gmail.com)
at the Lagos Climathon 2018 on 26th October, 2018 at LASEPA Hall, LASEPA, Alausa Secretariat, Ikeja, Lagos. 

References: 

1. Nwufo, C.C, Legal Framework for the Regulation of Waste in Nigeria, African Research Review, vol.4 (2) April, 2010.
2. Ijaiya, H, The Legal Framework for Solid Waste Disposal and Management in Kwara State, Journal of Environmental Protection, 2013, 4, 1240-1244.
3. Fagbohun, O.A and Ramos, B.S, Protecting Nigeria’s Marine Environment: Towards an Agenda for Enforcement of Relevant Laws, ELRI Monograph Series, 2015.
4. Iriruaga, E.T, Solid Waste Management in Nigeria, D-WASTE.COM (Nov.15, 2012)
5. United Nations Economic…., Problems with Waste Statistics and A Proposal for Action
6. State of NSW Environmental Protection Authority, Waste Classification Guidelines Part 1.
7. This Day Newspaper of 29^th March, 2018.
8. The Punch Newspaper of 7^th December, 2017
9. Lagos State Government Blog of 15^th March, 2018.
10. US Resources Conservation and Recovery Act.
11. The NESREA Act
12. The 1999 Constitution of the Federal Republic of Nigeria (as amended).
13. Environmental Protection Law of Lagos State 2017
14. Petroleum Act 1968
15. Harmful Waste (Special Criminal Provisions) Act 1988
16. Petroleum (Drilling and Production) Regulations
17. Oil in Navigable Act 1968
18. National Environmental (Sanitation and Waste Control) Regulations
19. National Effluents Limitations Regulation
20. Management of Solid and Hazardous Waste Regulations
21. NEP (Pollution Abatement in Industries and Facilities Generating Waste) Regulations
22. National Environment (Sanitation and Wastes Control) Regulations.
23. National Environmental (Electrical/Electronics Sector) Regulations
24. National Environmental (Non-Metallic Minerals Manufacturing Industries Sector) Regulations.
25. National Environmental (Control of Vehicular Emissions from Petrol and Diesel Engines) Regulations.
26. National Environmental (Construction Sector) Regulations.
27. National Environmental (Domestic and Industrial Plastics, Rubber and Foam Sector) Regulations.
28. National Environmental (Control of Bush/Forest Fire and Open Burning) Regulations.
29. National Environmental (Base Metals, Iron and Steel Manufacturing/Recycling Industries) Regulations.
30. National Environmental (Standards for Telecommunications/Broadcasting Facilities) Regulations.
31. National Environmental (Chemicals, Pharmaceuticals, Soap and Detergent Manufacturing Industries) Regulations.

[1] See This Day Newspaper of 29^th March, 2018. The article is headed “Burning Health Issues of Olusosun Dump Site”

[2] See https://lagosstate.gov.ng/blog/2018/03/15/lasg-explainsdumpsite-smoke. Last accessed 23^rd October 2018.

[3] Ibid.

[4] Problems with Waste Statistics and A Proposal for Action, being a paper presented by the UNECE to the Bureau of the Conference of European Statisticians (CES) at the request of the Joint Task Force on Environmental Statistics and Indicators (JTF). Avail at https://www.unece.org/fileadmin/DAM/stats/documents/ece/ces/bur/2016/October/07-Waste_statistics_final.pdf.

[5] See https://www.ewastedisposal.net/liquid-waste . Last accessed 10^th October, 2018.

[6] See the publication of the NSW Environment Protection Authority titled ‘Waste Classification Guidelines (Part 1)’. Available at https://www.epa.nsw.gov.au/-/media/epa/corporate-site/resources/wasteregulation/140796-classify-waste.pdf?la=en&hash=604056398F558C9DB6818E7B1CAC777E17E78233

[7] See the US Resources Conservation and Recovery Act.

[8] https://en.wikipedia.org/wiki/Hazardous_waste. Last accessed 10^th October, 2018.

[9]See s.15 of Harmful Waste (Special Criminal Provisions) Act LFN 2004.

[10]

[11] Section 42 of the Law.

[12] Section 57 of the Law

[13] Section 53 of the Law.

[14] Section 41 of the Law.

[15] Sections 41 and 63 of the Law.

[16] Section 41 of the Law.

[17] Section 57 of the Law.

[18] See sections 78-91 of the Law

[19] Section 109(4) of the Law.

[20] Section 20 of the Act.

[21] Section 7(c) of the Act .

[22] Section 7(d) of the Act.

[23] Section 7(h) of the Act.

[24] Section 27 of the Act.

[25]  See generally sections 20(3), 23(3) and 26(3) of the Act.

[26] See section 7(g),(h), (j) and (K) of the NESREA Act 2007.

[27] See section 13(2) of the Act.

[28] See the long title of the Act.

[29] Section 6 of the Act

[30] Ibid.

[31] Section 8 of the Act.

[32] Section 11 of the Act.

[33] Ibid, section 12.

[34] Section 9(1)(b)(iii) of the Act.

[35] Ibid, section 9(1)(c).

[36] Ibid, section 9(1)(e)(iii).

[37] Ibid, section 9(1)(e)(viii).

[38] The Punch Newspaper of 7^th December, 2017: https://punchng.com/validating-nigerias-policy-on-solid-waste-management/ Last accessed 25^th October, 2018.

[39] See generally section  91 of Environmental Protection Law of Lagos State 2017; section 20 of the NESREA Act.

[40] Iriruaga, E.T, Solid Waste Management in Nigeria, D-WASTE.COM (Nov.15, 2012). Available at www.d-waste.com/new-infographics/items/124-solid-waste-management-in-nigeria,html?

[41] See the Fourth Schedule to the Constitution

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