What is WM3 ? Dr. Ian Bishop One Touch Data Ltd [email protected] Tel: +44 (0)1628 771731 www.hazwasteonline.com June 5, 2016 © 2016 One Touch Data Limited 1 Presentation to the East Land Quality Forum 10 th March 2016
What is WM3 ?
Dr. Ian Bishop
One Touch Data Ltd
Tel: +44 (0)1628 771731
www.hazwasteonline.com
June 5, 2016
© 2016 One Touch Data Limited
1
Presentation to the East Land Quality
Forum
10th March 2016
What is WM3? The Simple Answer
WM3 is the current technical guidance for the
classification of waste from the four UK Environment
Agencies
In force since June 2015
Changes - from WM2 to WM3 – the headlines
H1 to H15 changed to HP1 to HP15
Hazard Statement Codes (eg H350) replace Risk
Phrases (eg R45)
DSD and DPD repealed (CHIP 4 Regulation)
Except in the case of Ecotoxic assessment (HP14)
where risk phrases (eg R50/R53) are retained
Persistent Organic Pollutants (POPs) added
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What isn’t WM3
You must not use defunct guidance such as:
Technical guidance WM2
HWR08 (unknown oils, England, Wales, NI)
DRO C10-C25
SWAN04 (unknown oils – Scotland)
ASL – data from the Approved Supply List
You cannot use WAC data to determine whether your
waste is hazardous or not
If a waste classification is received that used older
guidance, it has to be re-done using WM3
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Waste Classification
Not just for landfill disposal
Not the same as Waste Acceptance Criteria
Not the same as H&S labelling
Not just for development sites
It is fundamentally different to assessing risks
from contaminated land
The investigation and remediation of land contamination is
risk based
The assessment of contaminated soil as hazardous waste
is hazard based
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Soil - Doesn’t become a waste
Definition of Waste: Development Industry Code of Practice Version 2
CL:AIRE, March 2011 (England & Wales only)
Look at re-use of excavated materials first
Materials Management Plan
Must follow CoP
Only if you have a surplus of material does it become a waste
-> Site Waste Management Plan
Then look at classification
and then WAC if necessary
Processing is evidence that it’s a waste
Recovery operation – material ceases to be a waste
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Legislative Context - 1
Revised Waste Framework Directive 2008/98/EC
Defines the legislative framework for handling of waste in EU
rWFD defines waste as:
‘any substance or object which the holder discards or intends or is
required to discard’
Provides a precise and Europe-wide definition of hazardous
waste as:
‘a waste which displays one or more of the hazardous properties
listed in Annex III’
HP 1 through HP 15
Directive enacted into national law by The Waste
(England and Wales) Regulations 2011 (as amended)
Annex III rWFD replaced by Regulation 1357/2014/EU -18/12/14
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Legislative Context - 2
rWFD in turn refers to Decision 2000/532/EC - the List of
Waste (LoW) Also known as the European Waste Catalogue (EWC)
Contains 842 waste codes for different types of waste
Every waste can be classified as either hazardous or non-hazardous
Submissions based on codes are used to measure tonnages for each
waste stream across Europe
LoW is divided into 20 chapters and sub chapters e.g. Chapter 17: CONSTRUCTION AND DEMOLITION WASTES
17 05 soil, stones and dredging spoil
17 05 03* soil and stones containing hazardous substances
17 05 014 soil and stones other than those mentioned in 17 05
03
LoW most recently amended by Decision 2014/955/EU - 18/12/14
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List of Waste
The LoW (Decision 2000/532/EC) was implemented by
the List of Wastes Regulations 2005
However today, amendment Decision 2014/955/EU is referred to
directly - with other national laws being amended by:
The Hazardous Waste (Miscellaneous Amendments)
Regulations 2015, which amended:
The Waste (England and Wales) Regulations 2011
Hazardous Waste (England and Wales) Regulations 2005
Cremation (England and Wales) Regulations 2008
Environmental Permitting (England and Wales) Regulations
2010
Controlled Waste (England and Wales) Regulations 2012
And also revoked the List of Wastes Regulations 2005
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What is link between rWFD and classification?
rWFD (2008/98/EC) states that the classification of
waste as hazardous
‘should be based, inter alia, on the Union legislation on
chemicals, in particular concerning the classification of
preparations as hazardous, including concentration limit
values used for that purpose.’
Main EU chemical legislation being REACH and CLP
Plus subsidiary legislation for pesticides, biocides,
pharmaceuticals and cosmetics
Alongside CLP, chemical legislation (for mixtures) was:
Dangerous Substances Directive (DSD)
Dangerous Preparations Directive (DPD)
brought into UK law under the CHIP 4 Regulation
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Chemical substances in the CLP (Annex VI, Table 3.1 or 3.2) or
the older DSD/DPD have standardized phrases describing one or
more hazards of some 4,500 harmonised substances
DSD/DPD approach uses Risk Phrases
e.g. R45 Carc. Cat. 1 (threshold 0.1%)
CLP approach uses Hazard Statements
e.g. H350 Carc. 1A (threshold 0.1%)
But CLP documents both
Risk Phrases (Annex VI, Table 3.2)
Hazard Statements (Annex VI, Table 3.1)
Risk Phrases and Hazard Statements
Exception is for Ecotoxic R50, R51, R52, R53 & R59
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Carc. 1A = Hazard Class &
Category
H350 = hazard statement
code
Together = hazard statement
EU Chemical Legislation - CLP
CLP Regulation (EC) No. 1272/2008
Classification, Labelling and Packaging of
substances and mixtures
Came into force 20th January 2009
Adopts UNs’ Globally Harmonised System (GHS) of
classifying and labelling of chemicals
GHS heavily influenced by the older EU chemical
legislation
Transition period for mixtures, classified under
DSD/DPD (ie Risk Phrases) ended 1st June 2015
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CLP Data
Regulation (EC) No 1272/2008 - Classification, labelling and
packaging of substances and mixtures (CLP)
Annex VI, Table 3.1 (& Table 3.2)
Tables contain the hazard statements and risk phrases for
~4500 substances
1st , 2nd, 3rd & …. Adaptations to Technical Progress for
European Regulation 1272/2008/EC (ATPs)
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Hazard Statement codes
Note
Hazard statement codes e.g. “H300 Fatal if swallowed” can have TWO thresholds:
H300 Acute Tox. 1 - 0.1%
H300 Acute Tox. 2 - 0.25%
So you need to record both Hazard Class & Category and hazard statement code to determine the correct calculation approach
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Regulation (EU) No.1357/2014
Replaces Annex III to rWFD 2008/98/EC
Renames H1 to H15 to HP 1 to HP 15
Defines hazard statement codes and thresholds
e.g. Carc. 1A H350 0.1%
Repeals DSD and DPD
Requires an additional study HP 14 ecotoxic
And requires us to carry on with DPD approach for
ecotoxic i.e. the R50-R53 risk phrases
Revises some Hazard Property names:
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Revised Hazard Property Names
Name Status
HP 3 Flammable H3-A (4 indents) and H3-B
replaced by 5 indents
HP 4 Irritant - skin irritation and eye damage Revised to specifically include
eye damage
HP 5 Specific Target Organ Toxicity
(STOT)/Aspiration Toxicity
Amended to align with changes
in chemicals legislation and in
particular new hazard class /
categories in CLPHP 6 Acute Toxicity
HP 12 Produces Toxic Gases in Contact with
water, air or acid
New names to ensure
consistency with the naming of
the other hazard propertiesHP 15 Waste capable of exhibiting a
hazardous property listed above not
directly displayed by the original waste
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Decision (EU) No. 2014/955
Updates the List of Waste
Defines a “hazardous substance”
Lists “heavy metal” as any compound of
antimony, arsenic, cadmium, chromium (VI), copper, lead,
mercury, nickel, selenium, tellurium, thallium and tin
Specifically links Persistent Organic Pollutants (POPs)
into waste classification
Concentration limits… do not apply pure metal alloys in
their “massive” form … unless a specific entry in LoW
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WM3
Technical Guidance WM3 1st Edition, published 15th
May 2015.
How should we be classifying wastes in land development projects ?
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First – how is waste coded in the LoW ?
842 six digit code covering all wastes :
Absolute Hazardous (AH) – marked with an
asterisk, automatically hazardous, e.g. 13-07-01*
fuel oil and diesel
Absolute Non-hazardous (AN) – not marked with
an asterisk e.g. 03-01-01 waste bark and cork;
Mirror entries – typically a “pair” of codes, one
Hazardous (MH), one Non-hazardous (MN);
17 05 03* or 17 05 04 Soil and stones…
the selection of which depends on whether one or
more substances contain ‘hazardous substances’ at or
above a given threshold.
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LoW
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1. Look in chapters 1-12
(industry process) or 17-
20 (business activity)
2. No luck – look in 13-15
3. No luck – look in 16
4. No luck - 99 codes may
be considered
Exercise - Multiple Choice
Waste: A radiation apron dumped in a skip of builder’s waste
Questions to ask:
Where did it (the waste) come from..?
What is it made of?
Fabric
Leather
Lead
Is it :
A. 20 Municipal wastes (household waste and similar commercial, industrial and
institutional wastes
20 01 separately collected fractions
20 01 10 clothes
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Radiation Apron
Is it?
B. 18 Wastes from human or ….. health care
18 01 wastes from …diagnosis, treatment of disease in humans
Is it?
C. 15 Waste packaging, wiping cloths.. and protective clothing not otherwise
specified
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Different examples
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Two examples of Chapter 16: Wastes not otherwise specified in the list:
• liquor from composting
• portable toilet waste
Waste: Soil 17 05 04 or 17 05 03*
We have a waste soil.
So we need to decide:
What to sample
We will discuss:
What to ask the lab to test for (and why those tests)
Which metals
Which other substances
TPH
POPs
…
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Which LoW code?
Estranged husband dumps bricks and rubble on wife's car
A man has been arrested after allegedly using a JCB digger to tip
bricks and mud over his estranged wife's car.
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LoW code(s) ?
20 02 02 soil and stones
20 03 03 street cleaning
residues
20 03 01 mixed municipal
waste
16 -1 04 * end of life
vehicles
17 05 04 or 03* soils
17 09 04 or 03* C&D
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Soils Scenario 1 – the SI Report…
SI performed in winter 2014
20 test pits
Original consultant used HazWasteOnline
to ascertain that of 20 test pits:
19 were non hazardous and 1 was
hazardous …..
Summer 2015, developer excavating soils
Muck haulier submits the SI Report for
disposal of 2000 cube of waste soil
Q1 - Is stock pile 17 05 04 or 17 05 03* ?
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Soils Scenario 1 – Further Problems
Contractor needs the space where the 2000 cube
stock pile is sitting – in 2 days time
And - Contractor is only now thinking about disposal
And - Financial penalties could be incurred for delays
Issues
Contractor has excavated the soils without
consideration for any hazardous areas
Contractor has mixed non hazardous soils with
hazardous soils
Contractor now has 2000 cube of hazardous soil?
Discuss….
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A better approach
Soils excavated from hazardous area should be
kept separate from non hazardous soils
Mixing should be minimised
More sampling may be needed to better define
actual extents of hazardous area
Sampling and testing should be factored into the
management plan(s) from the start so not an
afterthought
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Sampling ?
There is no off-the-shelf sampling plan for soil
Both the stratigraphy and contamination on every
site are different
Different Sampling Plans are needed for
Site investigation/characterisation
Human health risk assessment
Waste Classification
Waste Acceptance Criteria
And
WAC is only required if the soils are going to (certain
classes of) landfill
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Lab testing of our soil samples
We’ve decided what and where to sample
But what do we actually test for?
Phase I should have discovered the sites’ history
Industries and their processes - over time
Chemicals used by those industries
Raw materials, products, treatments, spills
And potentially spilt/leaked/buried
Phase II should have identified
Different types of contamination (populations)
Spatial extent and degree of contamination
Need for any extra investigation
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Lab testing
You shouldn’t be asking for (just) the HazWasteOnline
suite of lab tests (or any other standard suite) …
You may have a minimum suite comprising
metals (but which ones?)
PAHs (16 USA EPA PAH suite)
TPH CWG or EPH ….
also
BTEX, pH, POPs …..
Selection should be steered by findings of Phase I
and II
Plus observations made since
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Metals - Not straight forward…
1. When lab tests soils for metals: cadmium, zinc, copper
etc
i. Lab reports total concentration of the metal
ii. However, it cannot tell you which compound of
cadmium, zinc or copper etc. you are dealing with
iii. Lab does not report the total amount of a metal
compound
2. However, in classification (in most cases) you have to
identify either
i. worst case metal compound, or
ii. most likely case metal compound
3. Then you have to convert total metal concentration - to
the chosen total metal compound concentration…
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For Example
Your laboratory tells you that the concentration of total
copper in your waste sample is 2750 mg/kg, which you
suspect to be in the form of copper (I) oxide Cu2O.
What is the actual concentration of copper (I) oxide?
The atomic weight of copper is ~ 63.5
The atomic weight of oxygen is ~ 15.9
The molecular weight of copper (I) oxide is 143
The concentration of copper (I) oxide is:
(143 /(2x63.5)) x 2750 mg/kg = 3096 mg/kg
[& conversion factor is simply 143/127 = 1.126]
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Is the waste (soil) hazardous?
Does the waste possess any of the
hazardous properties HP 1 to HP 15 - or
POPs? Yes = hazardous 17 05 03 *; No = non hazardous 17 05 04
Hazardous because either;
Where hazardous substances are present,
identified hazard statement codes are
compared against thresholds; and/or
Testing indicates the waste possesses a
hazardous property (e.g. flashpoint for
flammability HP 3).
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What you can’t do
Is use rules of thumb - such as:
“If all the metals add up to less than 2500mg/kg, the
waste is not hazardous……”
Which metals?
Which metal compounds?
Trial HazWasteOnline and get it to work out thresholds
for different metals…
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Nickel sulphate is
commonly used in
electroplating
Why rules of thumb don’t assess waste
You have to assess all the hazardous substances as:
Many hazard properties are additive
Case where concentrations of substances have to
be added together
Irritant HP 4, STOT HP 5, Toxic HP 6, Corrosive HP 8
Or test based on “fiddly” equations
Ecotoxic HP 14
Also they don’t allow for a (helpful) correction for things
like:
Moisture content
“Cobble” correction
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Σ((M × 10 × H410) + H411) ≥ 25 %
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Why can’t we use “experience”?
What are the risks?
No defensible record to document how a classification
was reached
No metal conversions and/or unsuitable metal species
Substance specific thresholds / M factors not applied
No correction for amendments to rules or thresholds
when ATPs published
No identification of Hazard Properties
No audit trial
So no ability to check
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Whereas
A report should document
everything that a third
party would need to check
a classification
Who did work & when
Lab data & meta data
Conversions
Additive/cumulative
Rules/equations used
Moisture
Note 1
Legislation
Software version
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Another reason…
The Environment Agency is running a campaign to
crackdown on dubious 17 05 04 classifications
For last few months EA have been sending out
letters to different parts of the waste chain asking for
evidence that a waste is 17 05 04
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Other wrinkles in the law/guidance
Some substances;
Have substance specific thresholds
Benzo[a]anthracine 25 mg/kg
Are Note 1
Case where you can use just the metal concentration
e.g. lead compounds (see next slide)
Are Note H
Effectively means they have missing hazard
properties e.g. HP 14 ecotoxic
All the oils in the CLP are Note H
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Worse still?
Some hazard statements in Table 3.1 are only considered a minimum classification
As shown by * or ****
And, in contrast to DSD approach,
all entries in CLP are considered potentially incomplete
i.e. not only those that we still label Note H
Good example is CLP entry: “lead compounds with the exception of those specified elsewhere in the Annex”
Doesn’t have an entry for HP 7 carcinogenic
But many sources including IARC consider it carcinogenic
So CLP requires classifier to add the missing hazard property(s)
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WAC
Waste classification tells you whether a waste is
hazardous or non hazardous
It does not tell you whether the waste is “inert”
You cannot use WAC tests to classify your soil and
determine whether it is hazardous or not
WAC is only required for disposal (of wastes) at certain
classes of landfill
How many times have I heard
“It’s failed Inert WAC therefore it’s hazardous”
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“It’s failed Inert WAC therefore it’s hazardous”
What this often relates to (from the “classifier’s” point of
view) is that the soil has failed WAC because:
Total organic content or
Dissolved organic carbon
has exceeded the WAC criteria for the Inert Class of
landfill
However
Neither are hazardous substances, and
Neither make a waste hazardous
And
“Classifier” hasn’t and doesn’t understand the law
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Conflict between terminology & laws
Landfill Directive - 1999/31/EC
Article 2e
Defines “inert waste” as:
Waste that does not undergo any significant physical,
chemical or biological transformations.
Inert waste will not dissolve, burn or otherwise physically or
chemically react, biodegrade or adversely affect other matter
with which it comes into contact in a way likely to give rise to
environmental pollution or harm to human health.
The total leachability and pollutant content of the waste and
the ecotoxicity of the leachate must be insignificant and in
particular not endanger the quality of surface water and/or
groundwater.”
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Inert Waste
It should be noted that
inert waste is by definition non-reactive and
therefore not harmful (non-hazardous) to the
environment, whereas non-hazardous waste
includes non-inert, reactive waste like organic matter
present in household waste (kitchen waste, garden
waste…).
Then we have the landfill tax as originally defined by
the Finance Act 1996
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The Finance Act
Part III Finance Act 1996 (Landfill Tax: sections 39 to 71)
Section 42 – Amount of tax
Refers to reduced rate for qualifying materials
material listed is “of the kind commonly described as
inactive and inert”
Section 63 introduces “qualifying materials”
And the concept of “small quantity of non-qualifying
material”
Exemptions
Section 43 Material removed from water
Section 44 Mining and quarrying
Section 45 Pet cemeteries
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Landfill Tax
Landfill tax
Standard Rate: £82.60/tonne
Increasing to £84.40/tonne
Lower Rate : £2.60/tonne
Increasing to £2.65/tonne
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Today
Excise Notice LFT1 updated 16th December 2015
Lower Rate: qualifying material
Waste must be:
Listed in Landfill Tax (Qualifying Material) Order 2011
And
Non Hazardous within meaning of rWFD
LFT1 defines qualifying materials in groups including
Group 1 includes:
Rocks and soil - Naturally occurring
Group 2 includes:
Concrete, including brick, concrete blocks
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Why WAC is not suitable for waste
classification
Primarily, because of the metals:
1. Metals in a WAC test are a test of the eluate
They are only a test for 12 soluble metals
Not a test for the insoluble fraction of same 12
metals
2. Mineral oil may only be testing the aliphatic component
3. WAC is a fixed list of chemical tests
No tests for any other potential hazardous
substances
Other metals
Other organics
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However, WAC can be helpful
WAC can provide clues for which metal compounds
present
Example
Cyclone ash from incineration of municipal waste
For zinc, research had shortlisted
zinc oxide (insoluble)
Zinc chloride (soluble)
Which species to use?
Lab results:
zinc (WAC): < 0.5 mg/kg
zinc (solids): 2,630 mg/kg
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Waste Classification data v WAC data
They are not the same and cannot be mixed
Classification has to be done first
Waste Producers must obtain characterisation data that, amongst other
uses, will determine the destiny of each of their waste streams.
First, there may be a need to determine whether the waste is
hazardous or non-hazardous (Classification).
Then, if it is to be landfilled, the class of landfill at which it can be
accepted must be identified.
Then, you look at whether the waste has to comply with the WAC for
that class of landfill
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Waste Acceptance Criteria
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WAC not applicableIs the waste defined as hazardous ?
May be accepted at
inert landfill
Hazardous WAC apply
Can be accepted at hazardous
landfill
Can not be accepted at hazardous landfill.
Other options required, such as treatment.
May be accepted at
non-hazardous landfill
Fail Inert WAC Meet Inert WAC
Yes No
Yes No
Met Failed
Is the waste to be disposed of to landfill ?
Stable Non-Reactive Hazardous Wastes
You can dispose of Stable, Non-Reactive Hazardous
Wastes (SNRHW) in non-hazardous landfills
Managed in dedicated cells
This is waste that is incapable of reacting with other
wastes
SNRHW potentially include
Monolithic solidified wastes in large blocky forms
e.g. those mixed with cement or PFA
Granular solid wastes
e.g. filter cakes, treated fly ash
Asbestos
SNRHW specific Waste Acceptance Criteria apply
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WAC Responsibilities
There is no obligation on any landfill operator to
take waste if they choose not to
Their Environmental Permit entitles them to take
waste of particular descriptions but does not
compel them to do so
Waste operators may require additional testing of
waste soils prior to acceptance at landfill
The obligation to ensure compliance with Waste
Acceptance Criteria (WAC) is placed on the
operator of the landfill.
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Waste oils and oil contaminated waste
WM3, Chapter 3.4 focuses on mineral and hydrocarbon
oils
1) Waste mineral oils (predominately oils, liquid fuels &
lubricants, synthetic oils & waste separator oil)
= Absolute entries
even if no hazardous properties
Exceptions = edible oil and sometimes biodiesel
Use safety data sheet, failing that petroleum group
2) Wastes contaminated with oil
i.e. oil phase is not major component
1. Known oil
2. Known group of oils
3. Unknown oil
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Scenario 1 – Known oil
Example – spill from a domestic oil tank in a garden
Brand of oil is known
Safety Data Sheet (SDS) can be obtained from supplier
Use hazard statement s on SDS
Cannot apply any markers
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Scenario 2 – Known Petroleum Group
If can identify petroleum group, e.g. diesel tank on a farm - but
specific brand is unknown
Can use petroleum group
Cannot assume that if DRO range (C10-C25) is present that it
is a diesel
Would need lab to report that results are consistent with fresh,
weathered or a biodegraded diesel
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Scenario 3 - Unknown oil
Case where identity of the oil is unknown
Should consider potential presence of other organic
“contaminants” e.g. coal tar, coal, solvents, peat
Have to ask lab to consider whether oil could be diesel
or gasoline
Otherwise assume following hazard statements:
H304 & H373 (HP 5 STOT/Aspiration Toxicity) ≥25%
H340 (HP 11 Mutagenic) ≥0.1%
H350 (HP 7 Carcinogenic) ≥0.1%
H361d (HP 10 Toxic for Reproduction) ≥5%
H411 (HP 14 Ecotoxic) ≥ 2.5%
Flammability (HP 3)
HazWasteOnline’s “TPH (C6-C40) Petroleum Group” applies
H226 Flammable liquid and vapour
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Unknown oil & the benzo[a]pyrene marker
Unknown oil can be classified as non carcinogenic :
1. where the concentration of TPH is ≥ 0.1%, the
waste will be classified as HP 7 Carcinogenic and
HP 11 Mutagenic, unless the concentration of the
marker, benzo[a]pyrene is <0.01% w/w of the
concentration of the TPH, and
2. laboratory analysis has concluded, through
examination of the chromatograph and carbon
bands, that the hydrocarbons present have not
arisen from petrol or diesel, and
3. this has been determined by an appropriate and
representative sampling approach in accordance
with the principles set out in WM3, Appendix D.
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What is Coming ?
Legislation
EC Regulation for HP 14
Replacement of R50-R53 risk phrases and substance specific
thresholds
Through use of H400, H411, H412, H413 and M factors
EC Guidance document
28 member states would have to agree….
8th ATP
Main objective: Alignment with 5th revision of GHS
New test method for oxidising solids
Amended criteria for skin corrosion/irritation, severe eye damage/irritation, and
aerosols
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What is Coming ?
HazWasteOnline™
Electronic Data Delivery (EDD)
Lab data are emailed to HWOL servers for validation
and publication
Quicker
Better QA/QC
Deals with units, moisture and other sources of error
Will include an interface for WAC data
German classification engine
Smartphone App for waste receivers
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Dr. Ian Bishop
One Touch Data Ltd
Tel: +44 (0)1628 771731
www.hazwasteonline.com
June 5, 2016
© 2016 One Touch Data Limited
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Presentation to the
East Land Quality
Forum
10th March 2016