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ABSTRACT - The Dutch National Institute for Public Health and the Environment (RIVM) has laid the foundations of a framework to assess whether raw materials from waste can be used safely and sustainably. In this integral approach, the risk assessment of a substance is compared with the benefits of its reuse for the environment, e.g. how much CO2 emissions are reduced. By making both explicit, it becomes clear what is needed to adequately limit the risks to man and the environment and what that effort will contribute towards sustainable development. On the basis of this information, both industry and
The framework integrates legally established rules, existing risk limits and new methods into one coherent, tiered system. In this way, it supports the Dutch government's basic principle of dealing efficiently with raw materials and reducing the burden on the environment. Safety for man and the environment is a precondition for the transition to the circular economy; an economy which maximizes the reuse of materials from waste streams wherever possible. Material that is recycled may present risks to the environment if it contains substances of very high concern (ZZS), drug residues, pesticides or pathogens. Legislation and policy frameworks protect against some of the risks but are not comprehensive enough to prevent the risks currently presented by recycled material. For example, while the regulations prohibit the use of substances in new products, such as fire retardants, there is no legislation available for products which were made before the prohibition was enforced. In addition, regulations may be missing, such as those for controlling drug residues. The framework has been tested with three cases: recovering phosphate from
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