IN JUNE’S edition of Skip Hire & Waste Magazine, I struggled to fit advice for asbestos waste on a single page.
So I thought I would finish off the topic with a quick review of which EWC codes to use if a customer’s waste contains asbestos.
There are numerous EWC entries for asbestos-related waste. However, caution should be expressed, as the manufacture and supply of all asbestos is now banned, and the codes in Chapters 6 and 10 of the EWC are rarely appropriate.
You can download the waste classifi cation guidance WM3 (Google it!), which contains the full EWC listing, and provides some limited guidance on classifi cation of waste containing asbestos.
The most common codes encountered are listed below and will only be used if the quantity of asbestos in the waste is above the hazardous threshold of 0.1% by weight – otherwise a mirror non-hazardous code should be used (MN in WM3).
17 06 01* insulation materials containing asbestos (Mirror Hazardous – MH)
17 06 05* construction material containing asbestos (Mirror Hazardous – MH)
Other mirror hazardous codes may apply if asbestos is present as a hazardous material - such as loose fi bres - but requires quantifi cation to establish whether the code is appropriate. One of the most common is 17 05 03* and if the waste is not hazardous 17 05 04* should be used instead.
17 05 03* = soil and stones containing hazardous substances (MH)
17 05 04* = soil and stones other than those mentioned in 17 05 03* (MN)
As always, this is a brief overview to generate interest and to be able to advise waste producers. They are, in the main, lacking experience in waste coding - despite it being their legal responsibility.
End of waste is defi nitely a subject which is shrouded in mystery, and as it’s been a long time since I addressed the issue, here it goes.
Most of you will have heard of – or tried your hand at – the Aggregates Quality
30 SHWM July, 2018
Protocol (QP), which is available on gov.uk
. The QP is widely used to assist in the manufacture of recycled aggregates, which directly replaced the use of virgin aggregates.
The common thread is that end-of-waste decisions are usually followed by a Protocol, which acts as a code of practice for the industry to process materials in an agreed manner.
The other most common end of waste use is the CL:AIRE Protocol (www.claire.co.uk
) which enables the reuse of excavated on-site materials or at other sites, and is a useful (albeit just as bureaucratic) alternative to applying for a permit.
I am often asked about ‘end of waste’ for many waste streams, and have to disappoint those asking the question - because the scope is limited by the EU End-of-Waste Regulations, which applies to certain glass and scrap metal, and the Court of Appeal OSS case.
This means very strict criteria apply to turning waste into product. The waste must be converted into a distinct and marketable product: an example of this is producing playground surfaces from waste tyres.
A summary of the criteria is presented below, and a failure to meet one of them will be detrimental to any application for end-of-waste status.
The new product is diff erent from the original waste: for example, non- packaging plastic recycled material is processed to make new plastic products, or plastic packaging is turned into fl ake or pellets, which meet a specifi cation for reuse in manufacturing.
This example requires regular testing of batches of product and detailed record-keeping.
There is a genuine market for the material, so it will defi nitely be used. If it is stored indefi nitely with little prospect for use, the material remains waste.
If a genuine market opens up, then this could change, but realistically storage would be limited by a permit or
exemptions. This could be complicated by a change in market conditions – reducing the need for a product.
The processed substance can be used in exactly the same way as a non-waste. This means some form of testing or analysis will be required, to prove the material has similar or identical properties to the product it will be replacing. If there is a British Standard for your product then the regulator will expect you to meet it.
The processed substance can be stored and used with no worse environmental eff ects when compared to the material it’s intended to replace.
Even if it looks and behaves the same as the product it is replacing, any contaminants must be at a level that does not cause a problem.
End of waste can only be achieved on a case-by-case basis, and will require more work than applying for a permit, but the long-term benefits are worth the hard work.
However, meeting the requirements is tough and I discuss many potential products with clients that have no direct comparator in the open market, which is a major diffi culty.
The added complication is that the use of material does not meet an agreed specifi cation and protocol, which could be classed as an illegal use or deposit of waste - an outcome which cannot occur if you are using a manufactured product.
MARCO MUIA Marco Muia BSc (Hons) MSc MCIWM is
a Director of Oaktree Environmental Limited. He specialises in all aspects
of waste planning and regulation
consultancy. He also holds the level 4 COTCs for Hazardous Waste Treatment and Transfer. You can contact Marco on: 01606 558833.
If you have any questions about this article, e-mail him via:
Follow him on Twitter @wastechat
MARCO MUIA: DIRECT AND TO THE POINT www.oaktree-environmental.co.uk
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