Current EC regulations and Environment Agency guidance requires waste holders (producers, carriers or disposers) and their advisers to make an assessment of their waste material and classify as either hazardous or non-hazardous.
Even though this is not a new concept there continues to be much confusion in the waste recycling and associated industries on what steps should be taken to correctly classify end of life waste streams.
Some notable points -
•The revised waste framework directive 2008/98/EC defines waste as -
‘any substance or object which the holder discards, intends to or is required to discard ‘
Although at the end of a Waste classification process you might have to have one completed, a Waste Acceptance Criteria test (WAC test) does not meet the requirements for a WM3 hazard classification. It is not the same as site investigation and remediation of land contamination reports, these reports are ‘risk based’. Hazard assessments are as the name suggests, ‘hazard based’.
This applies to many matrices including - filter cakes, sludges, ash, tarmac, soils and trommel fines.
Hazard classifications based on WM2 which was superceded by WM3 in May 2015 are no longer adequate and should have been reclassified using WM3 now superseded by Version 1.1.
• If you have a classification report consisting of just one page (or less) it doesn't comply.
• If it uses WAC or total metal concentrations it doesn't comply.
• If the classification you have received doesn't state which metal compounds were used, it is not fit for purpose
• If the report you have uses total metal or elemental concentrations it will be wrong and will not comply.
• Your classification should contain a full copy of the laboratory data. It should state why selected compounds were chosen and all assumptions that have been made, and contain details of your sampling plan. It should contain a history of the waste/process from which it was created.
• The goalposts as new information becomes available to regulators are always moving, if you are completing waste characterisation yourself, you are duty bound to keep up with new legislation and laws.
Alternatively please contact MSSL to discuss your waste stream and find out how cost effective it actually is to have a professional classification carried out for you when measured against getting caught without one that meets the required criteria.