Recently, law enforcement officers from the Foshan Municipal Bureau of Ecology and Environment discovered, during a patrol in a remote area of Ronggui Subdistrict, Shunde District, that among a pile of mixed waste inside the yard of an unnamed waste recycling station run by someone surnamed Zhu, there were a number of discarded packaging barrels with coating markings visibly exposed. These containers still retained chemical substances and gave off a pungent odor.

After weighing the materials on site, the waste coating barrels totaled 0.15 tons. Zhu admitted that he was unable to provide any lawful certificates and explained that these waste coating barrels had been purchased from a certain hardware spray coating factory in Huangpu Town, Zhongshan City at a price of 900 yuan. The hardware spray coating factory was suspected of illegally providing hazardous waste to an entity without a permit for collection and operation activities. The clue was quickly transferred through the joint coordination mechanism to the Zhongshan Municipal Huangpu Town Bureau of Ecology and Environment. Law enforcement departments of both places immediately formed a joint task force to carry out a joint investigation into the hardware spray coating factory.

A certain waste recycling station was punished by the Foshan Shunde environmental protection department for suspected illegal collection, storage, utilization, and disposal of hazardous waste without a permit.

The joint law enforcement team found that the factory was engaged in metal product spray coating processing, and hazardous waste such as paint residue, waste activated carbon, and waste chemical packaging materials was generated during the production process. Although the factory had signed a hazardous waste disposal contract with a qualified environmental protection company, it was unable to provide the transfer manifest for that year, and there were obvious loopholes in its management records. During the inquiry, the person in charge of the factory argued: “When Zhu came to collect the waste, our staff were not on site and did not notice that he also took away the waste coating barrels.” This excuse of “work negligence” could not hold up in the face of the complete chain of evidence and the 900 yuan transfer record.

Overall, the company’s illegal conduct was by no means a simple case of “work negligence,” but rather an “intentional release” intertwined with multiple opportunistic calculations.

“Suspicion of mixing the real with the fake.” The company mixed the waste coating barrels into ordinary waste, attempting to use the name of regular waste recycling to carry out illegal disposal in substance. During the loading and transport process, the factory personnel happened not to be on site; this deliberate “negligence” was in fact a way to evade supervision.

“Profit-driven” mindset. Proper disposal requires payment, whereas handing it over to an unqualified trader could instead bring in 900 yuan. This temptation of “making money in reverse” led the company to take the risk regardless of the consequences. “The company may have settled the economic account, but it forgot the environmental account and the legal account.”

“Quantity too small” mindset. The company believed that the small amount of 0.15 tons would not attract the attention of the regulatory authorities. However, the environmental risk of hazardous waste is not measured solely by quantity; the residues from just one waste coating barrel are enough to contaminate a piece of soil and a body of water.

Fourth, the “regional evasion” mindset. The company chose to transfer hazardous waste across cities, hoping to exploit the boundaries of regional jurisdiction to escape supervision. However, under the increasingly improved interregional joint prevention and control mechanism, this opportunistic mindset clearly did not work.

The identification report issued by a third-party appraisal company showed that these waste coating barrels belong to HW49 other waste (code 900-041-49) and have hazardous characteristics such as toxicity and infectivity. According to Article 80, Paragraph 3 of the Law of the People’s Republic of China on the Prevention and Control of Environmental Pollution by Solid Waste, it clearly states that “it is prohibited to provide or entrust hazardous waste to units or other production and business operators without a permit to engage in the collection, storage, utilization, or disposal of such waste.” The factory’s conduct has already seriously violated the law. According to legal provisions, such violations will face a fine of more than three times but less than five times the required disposal cost; if the disposal cost is less than 200,000 yuan, it will be calculated as 200,000 yuan. If the amount of hazardous waste reaches 3 tons or more, the relevant responsible persons will also be investigated for criminal liability.

To avoid repeated violations, enterprises handling hazardous waste must strictly follow the following standards when disposing of hazardous waste:

1. Establish account registration: establish a hazardous waste management ledger and record in detail the time, type, quantity, source, and destination of the generated hazardous waste;

2. Find the right recipient: disposal must be entrusted to a unit holding a “Hazardous Waste Operation Permit”; do not seek small gains by choosing an unqualified institution;

3. Manifest traceability: when transferring hazardous waste, the hazardous waste transfer manifest must be completed, and the data must be truthfully declared on the online solid waste platform to achieve “traceable source and traceable destination”;

4. Retain supporting documents: properly keep disposal contracts, transfer manifests, disposal invoices, and other materials for environmental authorities’ supervision and inspection;