Convention,32 where the States declare that they are “mindful of the growing threat to human health […] and the environment caused by transboundary movements of hazardous wastes”.33 As indicated in Annex 2, referred to in Article 2(1)(c) of the Bamako Convention, these hazardous wastes include toxic materials defined as “substances or wastes liable either to cause death or serious injury or to harm human health if swallowed or inhaled or by skin contact”. 131. The Court further recalls that international human rights law imposes a fourfold obligation on States, being, to respect, protect, promote and implement the rights guaranteed by the conventions to which they subscribe.34 While the obligation to respect requires the State party to refrain from committing violations, the obligation to protect requires the State party to protect rights-holders from violation by third parties. The obligations to promote and implement require the State to take the necessary measures to ensure the effective dissemination and enjoyment of the rights concerned. 132. This fourfold obligation to guarantee the right to life is confirmed by the United Nations Human Rights Committee (hereinafter referred to as “the Committee”) which, in its General Comment No. 36, underscores that: States parties must establish a legal framework to ensure the full enjoyment of the right to life by all individuals as may be necessary to give effect to the right to life. The duty to protect the right to life by law also includes an obligation for States parties to adopt any appropriate laws or other measures in order to protect life from all reasonably foreseeable threats, including from threats emanating from private persons and entities.35 32 The Respondent State became a party to the Bamako Convention on 16 September 1994. The Bamako Convention, Preamble, points 1 to 3. 34 The Social and Economic Rights Action Center and the Center for Economic and Social Rights v. Federal Republic of Nigeria, ACHPR, Communication 155/96 (2001) AHRC 60 (ACHPR 2001), § 44; The Registered Trustees of the Socio-Economic Rights and Accountability Project (SERAP) v. Federal Republic of Nigeria, Preliminary ruling No. ECW/CCJ/APP/07/10, 10 December 2010, § 10. 35 Human Rights Committee, General Comment No. 36 on Article 6 of the International Covenant on Civil and Political Rights, concerning the right to life,120th Session (3-22 July 2017), § 18. 33 33