The 4,200 tons of waste dump suspected in Shandong: the responsibility of supervision behind the first and the second trans-municipality of the special screening.

In February 2023, the Eco-Environmental Department of the East Camp in Shandong Province announced a city-wide special survey of industrial solid waste and chemicals, with a focus on enterprises with annual generation of hazardous waste of 1,000 tons and above. However, in April of the same year after the survey was launched, the Shandong Transcrete Chemical Industries Group Ltd., which produced more than 12,600 tons of hazardous waste annually, entered into an industrial solid commissioning contract with a regenerative resource company in Zhuanggong. In the following months, the Shinzuku chemical workers were reported to have transferred some 4,200 tons of industrial waste across the city to be illegally dumped in various areas of the village.

The Identification Notice issued by the Public Security Department of Suu Xin City in 2023 showed that the samples of the waste liquid involved were of a dangerous nature to leach toxic. This pollution case, which occurred during the local industrial solidification survey, still lacks a public record of the waste flows, corporate responsibility, law enforcement and environmental rehabilitation that can be fully accounted for.

Focus China previously disclosed the General Steaming Commission Disposal Contract between the Shinzuku Chemical and the Zhuang Factory for the Use of the Equivalent Regeneration Resources, the certificate of identification of the Public Security Department of Suu Xin City and several photographic materials suspected of being dumped at the site. Further investigations found that East Camp City had publicly acknowledged the existence of local regulatory gaps in hazardous waste as early as 2021, and that some regulatory functions had been long-standing.

From official recognition of regulatory gaps to the deployment of new special investigations, to the involvement of large chemical companies in suspected cases of trans-municipal waste dumping, three sets of facts occurred in different years, placing responsibility for the regulatory authorities at the centre of the events.

Specialized screening before waste re-shipment started, and the Zodiac Chemicals fit the focus survey scale

On 14 February 2023, the Survey of Industrial Solid Waste and Chemicals Arrangements for the Deployment of East Camp, published by the Eastern Camp Environment and reproduced by Shandong Radio and Television Network Ziru, revealed that the East Camp Eco-Environment Agency had issued a circular to organize industrial solid waste and chemical surveys throughout the city.

The report clearly identified the enterprises that produced 1,000 tonnes of hazardous waste per year and more, and those that produced 5,000 tonnes of solid waste per year in general, with the exception of oil-mining enterprises.

The survey focuses on the intensity of industrial solidity generation, integrated utilization, disposal rates, current status of governance, and risk control of hazardous waste throughout the process. Officially, the results of the survey will be an important support for city-wide industrial solid waste pollution prevention and control planning.

The data published by the Script Chemicals themselves provide the basis for a determination of whether the enterprise meets the scale threshold of the survey.

The Shandong Transcreasing Environmental Emergency Response Program (as revised in May

1. published on the official website of the Shandong Monksing Group, shows that the company ' s current project produces 12668.305 tons of hazardous solidity annually, with a general solidity annual yield of 4366 tons. Together with the expected hazardous solid waste from ongoing projects, the total production of hazardous solid waste listed in the document is 12693.265 tonnes.

On the basis of the scale of generation of hazardous solidity years for existing projects in the enterprise alone, the Zeners chemical industry has exceeded the threshold of 1,000 tons for the year's special survey.

This means that the Zeners meet at least the conditions for the amount of waste published in the special survey. The East Camp Eco-Environment Agency should be able to indicate whether the company was on the survey list and what regulatory measures were actually taken through the survey deployment of the year, the company's data declaration, the monitoring desk account and the on-site inspection records.

The Enterprise Environment Project also revealed that the Zeners Chemicals are the priority management unit for the clearance of sewage. The Eastern Camp Eco-Environment Agency issued it with a sewage clearance permit on 21 April 2022, valid until 20 April 2027, licence No. 9137050273714369D001P.

Thus, the Zanchak chemical industry is not a strange enterprise outside the environmental regulatory system. The scale of their production operations, pollutant emission management, industrial solid waste generation and related licensing information are now in the formal environmental management system.

The way in which the regulatory authority has managed the actual flow of waste to the enterprise since the launch of the special investigation is an important point to be followed up in this case.

A contract of 350 yuan a ton to connect business production to cross-market waste disposal

According to the contract materials obtained by Focus China, on 18 April 2023 Shandong Transcrete Chemical Group Limited and Yuen Croping and Reclamation Resources Utilization Limited entered into a General Resolute Commissioning Contract, which is valid until 18 April 2024.

The contract included the scrambling chemical as a supplier, the scavengers as a purchaser, and the item of disposal, written as “general solid, sodium sulfate”, at a unit price of $350/t, including taxes and transportation costs. The contract provided for a bill of pounds for the Zodiac Chemical and for the transport and harmless disposal of the Zhuang factory.

The contract unit price was calculated on the basis of the 4,200 tons claimed by the lead, and was approximately 1.47 million yuan. The actual amount of the transaction, the direction of payment and the proceeds of each party need to correspond to the pound bill, invoices and bank payment records.

It is of concern that the contract was signed after the deployment of a special investigation in the East Camp and that it was valid for the reporting period of major waste shipments.

According to the source, the waste involved was mainly transported outside the country from April to early July 2023, in areas such as the coastal area of the city of Yumong, the kiosk district and the town of Suu Xin. In July of that year, the police station of the Suu Guang City Public Security Bureau found the alleged dumping, followed by the intervention of the relevant investigative authorities.

This timeline shows that there is a clear written disposition arrangement between the Zhuang Chemical and the Zhuang Yug Yi, and that the relevant trans-shipment leads overlap with the contract performance period.

The core of the problem lies in how industrial waste generated by a large petrochemical enterprise enters the inter-municipal transport and disposal chain through a “general solid” contract.

The contract's “general solidification, sodium sulphate” is the name of the subject(s) agreed upon in writing, and the actual hazardous properties of the waste shall be determined by its source, composition, process and relevant identification.

The scrambling plant should have the source, classification basis, weight and delivery target of each shipment. As a trustee, the best practices in the Zhuang factory should be in the hands of the receiving quantity, transport arrangements and final disposal sites.

The records of these two links can be matched with each other and can be checked against the physical sampling by the public security organs, the vehicle transport tracks and the investigation files.

What is really needed is to trace the waste in question when it leaves the Zenan chemical plant, what material is registered within the enterprise, whether the necessary hazard attribute identification has been completed and whether the transport and final disposal are in conformity with the contract.

The classification of industrial waste determines the regulatory process to be followed, and misclassification or circumvention of regulation may result in a complete deviation from the statutory regulatory requirements for subsequent transport, receipt and disposal.

Public security certification involves the storage tanks and multiple locations of enterprises, and the pollution chain crosses administrative boundaries

Suu Guang City Public Security Bureau, Validation Notice, previously disclosed in Focus China, Instrument No.

The notification concerned a case of alleged environmental pollution and the public security organs commissioned the identification of hazardous waste properties, toxic substances and associated pollution indicators for waste fluids, sediments and contaminated soil.

The sampled sites covered by the instrument include the pits of the Sun-ray City ' s small yard, the warehouse of the precision chemical plant in the Shandong Baelucque, the draining canals of the 309 provincial road near the Haining road, the PV block of the Hana Temple Village, and the storage tanks north-east and west of the Shinzun chemical plant area.

The evaluation showed that some of the waste samples involved had toxic properties of leaching, and that the identification projects involved substances such as arsenic, fluoride and so on.

Of concern are the sites identified for sampling, which involve both the East Camp waste plant and the various suspected contaminated sites in the Zhuang district.

This provides specific investigative leads for the process of tracing industrial waste from its source to the outside environment.

According to the available material, approximately 4,200 tons of industrial waste were reported as a total, while public security identifications were made for specific samples. The full amount of hazardous waste should be further matched with the various batches of dumping, through the original transport and identification records.

The division of regulatory responsibilities can be based on the location of the enterprise, the place where the waste is received and the place where the pollution occurs.

The Eco-Environmental Directorate of the East Camp and its relevant territorial subdivisions, which are responsible for the supervision and management of the control of industrial solid pollution by the enterprises that produce the waste. The eco-environment sector in the Zhuang region involves environmental law enforcement and governance for reception, utilization, disposal activities and on-site pollution sites.

The Public Security Directorate of Shou Guang City has formed an opinion, and the investigation and transfer procedures for the investigation of criminal leads involving offences are matters which the Public Security Judiciary is required to deal with in accordance with the law.

When industrial waste is operating from the east to the mill, environmental regulation cannot stop at the boundaries of the enterprise, nor can cases be handled without a complete chain of responsibility because of the multiple administrative areas involved.

Where a group of industrial waste is generated, by whom, by which route, by which site and by whom, ultimately, should be disposed of, it should be possible to find corresponding information in the records of business management, transport vouchers, regulatory systems and public security investigation materials.

As early as 2021, the Eastern Battalion officially recognized that there were loopholes in hazardous waste control

In this tracking survey, an official document published in 2021 on the East Camp Disciplinary Commission website revealed the deep-seated problems of the local hazardous waste regulatory system.

On 22 March 2021, the East Camp Environmental Regulatory Commission website published a bulletin from the Eastern Central Communist Party Environmental Agency on the progress of the city council ' s inspection and reform.

This document revealed that in 2020 the Eastern Camp Commission Inspectorate conducted a “back-to-back” inspection of the Municipal Eco-Environmental Agency's party team and found that some of the regulatory responsibilities were not being fulfilled.

Among them, the content of hazardous waste regulation directly points to:

“Full-out regulation is flawed. The Bureau ' s group is not sufficiently aware of the long-term, complex nature of the problems involved and is not taking the initiative. The blogger adds:

The circular stated that five local letter-call cases involving hazardous waste were not included in the regular movement control and long-term tracking control list. The Eastern Camp city was tested for the standardized management of hazardous waste in 2018 and 2019, which were the first and fourth lowest in Shandong Province, respectively.

The inspection material also revealed that the Municipal Centre for the Management of Hazardous Wastes and Radiation, which has the responsibility for hazardous waste management, had failed to perform its specific functions and was inspected as “units are not functioning”.

The restructuring of the municipal eco-environment department at that time indicated that the restructuring had not been completed and that the functions were being performed by the SWC and ERS.

More seriously, the inspection circular also referred to cases of hazardous dumping that had previously occurred in the eastern battalion. The local authorities, which had been poorly regulated because of the public ' s perception of the dangerous waste ponds, had led to a long-term continuation of the dumping and an increase in the number of dumpings, which had been criticized by the Department of Eco-Environment of Shandong Province and had been placed under the executive board.

These records show that the risk of industrial waste management in the East Camp was repeatedly revealed by local patrols, superior eco-environmental units and mass reports prior to the suspected dumping by the Visible Chemical Workers in 2023.

The official circular also lists corrective measures such as cross-enforcement inspections, specific waste management, enhanced classification management and the establishment of long-term regulatory mechanisms.

However, the practical effects of the overhaul system will ultimately need to be tested through the subsequent management and detection of specific enterprises, specific pollution incidents.

In 2023, the East Camp City again launched a special survey on industrial solidification and chemicals, requiring priority enterprises to implement a full-process risk control. This survey should be a realistic test of the results of the overhaul.

The 2023 case of a trans-municipal transfer of industrial waste by the Shinzuku Chemical Industries occurred at a time when the Eastern Battalion claimed to have enhanced the management of hazardous waste throughout the process.

Specific regulatory matters to be addressed by the Eco-Environment Agency of the East Camp include whether the Visible Chemical Industry is subject to a special survey in the year, whether the firm's solid generation and transfer account is subject to verification, whether the actual disposal capacity of the Trustee is included in the inspection and what unusual information is available to the authorities during the shipment of the waste involved.

Only by comparing the record of the special investigations with the actual disposal of the business will it be possible to determine whether the previous regulatory changes were actually translated into effective environmental protection measures.

The end-of-life enterprise has a contract that does not shift its legal responsibility for pollution prevention

The Law of the People ' s Republic of China on the Environmental Prevention and Control of Solid Waste Pollution, which was applied in 2023, makes clear provisions for the commission of third-party transport, utilization and disposal of industrial solid waste by enterprises that produce and use waste.

Article 36 of the Act requires the units producing industrial solid waste to establish a system of liability for the prevention of pollution and to manage the accounts of the desk, and to record the true type, quantity, flow, storage, utilization and disposal of the waste.

Article 37 further provides that the waste unit entrusts another person with the transport, use and disposal of the industrial solidity, shall verify the principal qualifications and technical capabilities of the trustee, enter into a written contract in accordance with the law and agree on pollution prevention requirements.

The law also provides that, in addition to being punishable by law, the waste unit shall be liable, in conjunction with the trustees responsible for the environmental pollution and ecological damage, for the violation of the above-mentioned obligation to commission verification.

The legal requirements for hazardous waste are stricter. Hazardous waste operators should be legally licensed and the transfer process requires the implementation of a hazardous waste billing system.

The Hazardous Waste Transfer Management Scheme, which was implemented from 1 January 2022, further clarifies the specific responsibilities of the removed person, the carrier and the recipient, including the verification of the qualifications of the operation, the establishment of a heavy bill, the recording of the transport trail, the execution of the transfer chain and feedback on the final disposal of the waste unit.

This means that although the contract between the Zhigashi and the Zhuang Zhuang Zhuang Zhui has been expressly agreed to be carried out by the trustee, the Zhighu Zhig Zhig Zhig Zhui has been rendered a waste business and has been subject to the corresponding management and verification responsibilities.

For the purpose of poaching, the commitment to transport and harmless disposal in the contract also means that its actual business qualifications, shipping arrangements, disposal facilities and final delivery records should be investigated.

The case requires further examination of the business relationship between the parties and the actual transaction structure.

The contract uses the name of the supplier and the buyer, but contains both commissioning and harmless disposal arrangements. The price of $350 per ton corresponds to the purchase of waste, treatment services or other means of settlement, directly related to the business ' s motivation and economic interests.

In particular, in the case of suspected illicit dumping leads, regulatory and investigative authorities should also ascertain the actual whereabouts of each shipment and whether there are any low-cost movements, illegal receptions or irregular disposals that may have been used to obtain benefits.

Any transaction carried out in the name of resource use, industrial by-products or general solid waste must be subject to legal tests of the actual nature of the waste, the quality of the disposal and the obligation to prevent and control pollution.

From the enterprise to the Zhuang land, the responsibility for pollution management also needs to be tracked

The environmental risks posed by the illegal dumping of industrial waste will not normally end with the departure of the transport vehicle from the site.

The SSP identification documents already cover a number of sampling sites, including waste fluids, sediments and contaminated soil. These different types of pollution media mean that follow-up to cases requires attention to both waste removal, contaminated soil management and related environmental monitoring.

For areas where the leads are directed, such as succulent light, kiosks and the seafront, the relevant authorities should determine the extent of the contamination, the destination of disposal and the subsequent rehabilitation requirements, based on specific contamination sites, identification results and on-site surveys.

Contaminants in soil may enter the surrounding environment through rainwater wash-down, surface runoff and infiltration. In the case of heavy metals or other toxic industrial residues, pollution management is particularly dependent on standardized sampling, risk assessment and continuous monitoring.

Contamination wastes removed from the site should be entered into treatment facilities with appropriate qualifications and capabilities and should be recorded for retroactive transport, reception and final disposal.

This is not only about whether pollution is controlled, but also about who bears the costs of governance.

Under the regime of compensation for damage to the environment and related civil liability, the subject of the responsibility for damage to the ecological environment shall be liable for the resulting repair or liability in accordance with the law. Liability for offences investigated by public security organs, administrative supervision by the environmental sector and civil ecological damages may be dealt with separately within the legal framework.

In this case, the relevant department of the factory, which is responsible for the supervision of the contamination site, needs to have a complete record of pollution investigations, clean-up disposal, environmental monitoring and damage recovery.

One industrial waste dumping involving multiple locations can only be complete in the chain of enforcement if the source of pollution is traced, the disposal of illegal liability and environmental governance is completed.

Local governments support petrochemical industries and corporate environmental responsibilities must be implemented simultaneously

On 27 October 2026, the East Camp Network published the " México Santsi ". Reports indicate that on 26 October, Shin, Secretary of the East Camp, had just studied the petrochemical industry in the East Camp, and had travelled to the Wantung Petroleum Chemical Group in Shandong and the Shintung Transchemical Group to check the operations of the enterprise and to speak with the officials in charge.

Official reports emphasize that the petrochemical industry is the backbone of the East Camp and that all levels of the sector need to implement a policy of preferential enterprise to help enterprises to solve their production difficulties. At the same time, the report requires that enterprises assume primary responsibility for safe production and ecological protection.

The study was more than three years away from the 2023 dumping lead.

The support of local governments for the development of an enterprise reported to have been involved in the illegal dumping of large-scale industrial waste and the use of waste from the plant into public security identification procedures should be consistent with the implementation of environmental regulatory responsibilities.

As the main head of the East Camp Municipal Council, the local party system, under the leadership of the Makoto Makoto, has the responsibility to promote the implementation of the environmental protection and pollution management responsibilities of the competent authorities in accordance with the law. The body responsible for the relevant supervision and those responsible for it in 2023 should be investigated in accordance with the specific duties and records of the duties performed at the time.

Similarly, the competent authorities of the city and the relevant regions, such as the Zhuang city and the Zhuong kuo and the sea coast, shall also exercise their responsibility for the management of the territory in question, in accordance with the circumstances of the case, such as the reception, transport, dumping site and environmental damage.

These responsibilities can be traced back through specific administrative documents and law enforcement records: who is responsible for the year ' s special investigations, who has the license for sewage and solid declaration of the Vicar chemical, who conducts daily inspections of the enterprises involved, who is responsible for the implementation of the pollution scene law and what procedures have been followed to process the case materials after the public security assessment has been completed.

Local industrial policies can support business operations, but environmental protection laws also require that enterprises and government departments exercise clear responsibilities.

More than three years later, a complete survey and governance results still have to be handed over

The time series revealed a problem of local governance that deserved in-depth oversight, from official public recognition of regulatory gaps in hazardous wastes in 2021 to the launch of a special industrial solidification survey in February 2023 and the emergence of a trail of about 4,200 tons of waste suspected of being illegally dumped across the city at the Zocene Chemicals in the same year.

The regulatory authorities already have basic environmental information on large waste enterprises, and have developed specific screening, classification management and risk-control requirements for the entire process.

The scrambling chemical works have written environmental management documents, a sewage licence and a third-party disposal contract. The Zhuang Zhui Yui is the counterpart of the contract and is responsible for the agreed transport and disposal work. The public security organs of Zhuang, in turn, have issued written opinions on the dangerous characteristics of some of the waste liquids involved.

These facts relate to a set of established business management, administrative supervision and judicial investigation procedures.

The real test of the effectiveness of this system is whether the regulatory authorities have control over the actual flow of industrial waste, whether illegal disposal can be detected and stopped, and whether the rehabilitation can be held accountable and completed after the pollution has occurred.

As of this report, there is still a lack of complete case handling notices that can be directly matched by the 4,200 tons of trans-shipment leads of the Zenhu chemical plant, the contract for the Zhuang Zhuang Zhuang disposal and the Public Security Identification Notice of Life.

According to the available leads, Shindong ' s Transchemical Group Limited, the Yughuang Industries and Regeneration Resources Corporation Limited, and the environmental and public security judiciary in the East Camp and the Shangang regions are in the process of fact or responsibility for the case.

Enterprises should account for the generation, classification, trans-shipment and final disposal of relevant industrial wastes; The eco-environment sector should describe specific investigations, supervisory inspections, illegal disposal and pollution rehabilitation; Public security judicial authorities shall, in accordance with the law, deal with the investigation leads for crimes related to environmental pollution.

In cases of major cases involving trans-municipal industrial waste and multiple pollution sites, which have entered the public security identification process, the responsibility of local governments for environmental governance cannot be limited to the oral demands of the deployment of special operations and the responsibility of the business owners.

The effectiveness of the controls should be proven by the examination record; The responsibility of the enterprise should be demonstrated by the waste desk account and the final disposal certificate; The remediation of the contamination should be demonstrated by the results of on-site clean-up, repair and environmental monitoring.

The suspected 4,200 tons of waste dumps in Shandong need to be traced, from the complete chain of responsibility for waste industries, commercial connections and trans-municipal transport to environmental regulation, public security investigations and pollution management.

A special screening exercise has been initiated, which must ultimately be tested for the outcome of a specific case.