REQUEST FOR REVIEW AND STRENGHENING OF THE NATIONAL DUST CONTROL REGULATIONS

The Centre for Environmental Rights, representing various community and environmental organisations, argues that the 2013 National Dust Control Regulations are ineffective due to their reliance on a 30-day monitoring average and the 'crude' ASTM D1739 test method. The letter highlights that PM10 fugitive emissions from mine haul roads account for 49% of total annual PM10 emissions in the Highveld Priority Area. It recommends adopting a pro-active 'best practices' approach and opacity standards similar to those used in Michigan and Utah (USA), and calls for mandatory geochemical and radionuclide analysis of dust from tailings storage facilities to address toxicity and radiation risks.

• The existing National Dust Control Regulations are considered ineffective because they rely on a 30-day monitoring average, which fails to capture high concentrations of fugitive emissions occurring during discrete intervals.
• The ASTM D1739 method used in the regulations is described as a 'crude and non-specific test method' that is not appropriate for determining dustfall rates in small areas affected by specific sources, despite being used by the regulations for that exact purpose.
• In the Highveld Priority Area (HPA), PM10 fugitive emissions from mine haul roads represent 49% of the total annual PM10 emissions.
• The current regulatory framework is criticized for being too reactive, as the obligation to develop a dust management plan or undertake PM10 monitoring is only triggered after demonstrating that 'acceptable dustfall rates' have been exceeded, a process that can take between three months and one year.
• The document proposes replacing the current system with a pro-active approach based on 'best practices' and the use of opacity standards, citing the regulatory models of Michigan and Utah in the United States.
• There is a significant gap in the regulations regarding the toxicity of dust from tailings storage facilities; the document notes that radioactive and toxic dust fallout from gold and uranium tailings dumps causes health impacts through inhalation and ingestion.

APA

Centre for Environmental Rights (2015). REQUEST FOR REVIEW AND STRENGHENING OF THE NATIONAL DUST CONTROL REGULATIONS. https://cer.org.za/wp-content/uploads/2016/08/CER-Letter-to-Minister-of-Environmental-Affairs-requesting-the-strengthening-of-the-National-Dust-Control-Regulations-16-Oct-2015.pdf?x21779

Chicago

Centre for Environmental Rights. REQUEST FOR REVIEW AND STRENGHENING OF THE NATIONAL DUST CONTROL REGULATIONS. 2015. https://cer.org.za/wp-content/uploads/2016/08/CER-Letter-to-Minister-of-Environmental-Affairs-requesting-the-strengthening-of-the-National-Dust-Control-Regulations-16-Oct-2015.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=REQUEST FOR REVIEW AND STRENGHENING OF THE NATIONAL DUST CONTROL REGULATIONS |date=16 October 2015 |url=https://cer.org.za/wp-content/uploads/2016/08/CER-Letter-to-Minister-of-Environmental-Affairs-requesting-the-strengthening-of-the-National-Dust-Control-Regulations-16-Oct-2015.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2015request, author = {{Centre for Environmental Rights}}, title = {{REQUEST FOR REVIEW AND STRENGHENING OF THE NATIONAL DUST CONTROL REGULATIONS}}, publisher = {Centre for Environmental Rights}, year = {2015}, month = oct, url = {https://cer.org.za/wp-content/uploads/2016/08/CER-Letter-to-Minister-of-Environmental-Affairs-requesting-the-strengthening-of-the-National-Dust-Control-Regulations-16-Oct-2015.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }