This extension, in the “Milleproroghe” decree, suspended for the moment the application of the new system, extending to the end of 2016 the existing transition period which obliged companies to apply to distinct procedures for the same kind of activity of waste disposal and handling. Thus many companies, above all those whose production processes require the disposal of large quantities of dangerous waste, have continued to operate both using the old procedures and at the same time applying SISTRI.
But what is exactly SISTRI, and how did this come about?
Below is a brief summary.
The environmental code
Sensitivity towards the correct disposal of waste has attained growing importance in recent years and legislation has been gradually completed with various provisions that have had a greater impact on companies than in the past. The main law on the issue is legislative decree N. 152 of 3/4/2006 “Environmental regulations” (Environmental Code) which, with later modifications and implementations, has rewritten the rules on waste management. The aim of the law was to introduce, as an obligatory operational practice for all producers, holders, transporters and disposers of special waste, adhesion to a waste tracking system (SISTRI) to monitor waste handling throughout the chain by using electronic systems and eliminating printed documentation. The decree laid down that the specific part concerning SISTRI should only become operative from April 2014.
What SISTRI is
The first approach to the SISTRI system dates back to 2009, when the environmental and territory and sea protection Ministry began a computerisation process as part of attempts to modernise the Public Administration, aiming also to identify interventions to tackle the problem of waste disposal in the Campania Region.
The SISTRI system was thus a “forced” introduction of advanced electronic technologies in the special waste disposal sector designed to simplify procedures and conformity for companies while reducing costs and at the same time ensuring more efficient control. SISTRI simplifies the task of authorities in preventing illegal operations, since the flow of information it produces is handled by the Carabinieri, to permit tighter control of their handling of special waste all along the chain, including transport and the final phase of disposal, showing the incoming and outgoing flows of vehicles in the tips.
What SISTRI involves
Every potential producer of special waste must register with SISTRI and acquire one or more USB flash drives (according to the number of production sites). When specific types of special waste are disposed of, all the data usually provided in the printed documentation that accompanies the waste must be memorised on these drives. When the waste is handed over to the transporter/disposal company or to an intermediary engaged to dispose of the waste, the drive must be plugged into a special black box (equipped with a SIM data card) installed on the vehicles of the operator or environmental handler so that the data they contain can be transferred automatically to the central SISTRI registry. Once the connections are completed, a system/network will be created that will make it possible to track all movement of the waste from production to the final destination.
The printed system
The system in force before SISTRI arrived (which is still in use today after the extensions conceded) is based on three documents: the waste identification form, the loading and unloading register and the single environmental declaration form (MUD).
The waste identification form travels with the waste and contains all the characteristics of it (origin, type and quantity), the name and address of the producer, handler and consignee plus other information on the route they will take.
The loading and unloading register, detained in each production site, contains information on the qualitative and quantitative characteristics of all waste produced and/or handled and makes possible control by the authorities. The register has numbered pages and is authenticated by the local Chamber of Commerce.
The single environmental declaration form (MUD) contains a declaration of waste produced, disposed of, sent for recycling or transported in the preceding year. The form must be presented by April 30 each year.
The double track
During the extension conceded for the implementation of SISTRI, the traditional obligations and printed documents on waste tracking (forms, registers and MUD) remain in force, but for some categories the SISTRI procedures must be followed as well.
Those obliged to follow this “double track” system because of their primary professional activity are mainly bodies and companies with more than 10 employees that originate dangerous special waste or store, transport, recycle or dispose of it.
Until December 31, 2016 they must respect both the new “informatic” SISTRI tracking obligations and also the “old” ones, operating in a “double track” regime during which they are liable to the sanctions laid down for failure to respect legal decree N. 152 of 3/4/2006.
What’s new in 2017
What will happen this year? Will there be a new extension? Everything leads us to think that the double system currently in force will be extended into 2017. So the dangerous waste sector, which creates the biggest problems because the extensions implemented so far make this waste more onerous to handle, will still have to follow the double track procedure.
The only positive element is that the Milleproroghe decree has delayed the application of sanctions for failure to use SISTRI, except for those relating to failure to register with SISTRI for companies obliged to do so.
So we are waiting for another extension, also of the suspension of the application of sanctions.