Is a waste hazardous or non-hazardous? WM3 Waste Hazardous
Property Assessments

The List of Wastes classifies wastes as hazardous, non-hazardous or ‘mirror entries’ (hazardous or non-hazardous depending on their properties). Waste producers need to undertake a hazardous property assessment to determine whether a mirror entry waste is hazardous or non-hazardous.  For hazardous wastes, the producer needs to identify which properties are relevant to the waste classification.

In 2015 the UK implemented the Classification, Labelling and Packaging (CLP) Regulation (1272/2008/EC) and the Environment Agencies published updated technical guidance WM3 on the classification and assessment of waste (  The Global Harmonised System which they implement requires the use of ‘Hazard Statement Codes’, replacing risk phrases (R-phrases) which were used previously. The number of hazardous properties remains the same (15), including irritant (HP4), corrosive (HP8) and ecotoxic (HP14), but limits have now been set for Persistent Organic Pollutants (POPs).

WRc has developed a bespoke commercial service for the preparation and testing of wastes along with expert hazard assessment.  We offer a tiered approach. The first and second tier provide a face value assessment of worst case compound concentrations in comparison to hazardous property thresholds. The third tier is based on compounds expected to be present in the waste gathered from weight of evidence reviews and specialist testing (e.g. in vitro irritancy), metal speciation and geochemical modelling.

Landfill waste acceptance criteria (WAC) test data cannot be used to classify wastes as hazardous or non-hazardous but may be included in further testing to determine a waste's suitability for treatment or recovery. If a hazardous waste is destined for landfill, landfill (WAC) testing is needed to confirm that the waste meets acceptance limits for hazardous waste landfill. For non-hazardous wastes a range of tests are available to inform decisions about recovery.

A carefully planned sampling and testing programme can address a range of testing objectives. WRc designs bespoke waste characterisation exercises that will ensure that a waste is appropriately classified according to the WM3 assessment procedure and help unlock the value of a waste.

Dr Kathy Lewin Head of Resource Efficiency