WRc is now classifying wastes according to the new methodology set out in Environment Agency Technical Guidance WM3, published in May 2015.
On the 1st of June 2015, the UK implemented the European Union “Regulation on classification, labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC , and amending Regulation (EC) No 1907/2006” (the CLP Regulation) which repeals the old Dangerous Substances Directive (DSD) 67/548/EEC. The changes to chemical regulation have direct implications for the waste regulations and revisions to the methodology for classifying wastes as hazardous have been implemented to bring it in line with the CLP regulations.
In the UK, the Environmental Agencies for England, Wales, Scotland and Northern Ireland have produced a new Technical Guidance Document, WM3, to lay out the process for classifying wastes, which has brought some fundamental changes to the assessment of wastes. The Global Harmonised System (GHS) used for labelling the hazardous properties associated with chemicals and compounds now requires the use of “Hazard Statement Codes” instead of “R-phrases”. The number of hazard properties remains the same (HP1 to HP15) but some of the properties and thresholds have changed. In particular H5 (Harmful) is now HP5 (Specific Target Organ Toxicity (STOT)) and H6 (Toxic) is now HP6 (Acute Toxicity). Another fundamental change is the number of compounds that need to be considered as “worst-case”. More databases, including the entire CLP inventory, need to be searched and therefore the number of compounds for assessment has significantly increased. It is now also a requirement to consider all of the hazard properties for every single compound being assessed. Previously if a compound had a harmonised classification then those classifications should be used and no further information was required. The new requirements mean that even compounds with harmonised classifications must be considered under all 15 hazardous properties. It is recommended in the WM3 that that assessment should be undertaken by someone competent in the requirements of the CLP regulations. Additionally, thresholds for Persistent Organic Pollutants such as dioxins, furans and PCBs have also been included in the new Technical Guidance Document, as well as the existing 15 hazardous properties.
WRc have been through this process and have developed a new methodology for assessing the hazard properties of incinerator bottom ash (IBA). This is based on previous work done by the Environmental Services Association on the speciation of some elemental compounds (namely zinc, copper and nickel compounds) and applying the new requirements of the WM3 Technical Guidance. WRc has also undertaken a comprehensive review of the available evidence base to make a recommendation for the classification of lead compounds in IBA with respect to carcinogenicity (HP7). This followed suggestions that lead should attract the lower threshold of Carc.1A/B (H350) with a threshold for hazard of 0.1%, which would be an issue for IBA from some UK EfW facilities.
All hazard report and spreadsheets that WRc issue for samples received from the 1st July onwards will be compliant with the requirements of WM3.
WRc helps waste producers to understand the basic characteristics of their wastes - type, quantity, physical and chemical properties - in order to make informed recovery option assessments. Our experts can prepare sampling plans according to Environment Agency guidance (Annex D of WM3 and M4), manage complex testing programmes, benchmark data against in-house datasets and provide expert interpretation with respect to the 15 hazardous properties.
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