C&D sector faces 'huge costs' without urgent action on waste wood testing
Wood Recyclers' Association warns lack of shared test results may require C&D companies to test every potentially hazardous wood item after September. Current regulation allows testing of one item quarterly.
Construction and demolition (C&D) companies risk significant financial and environmental consequences if they fail to act swiftly on waste wood testing requirements, the Wood Recyclers' Association (WRA) has warned.
With the Regulatory Position Statement 291 (RPS 291) set to expire at the end of September 2024, the WRA is urging C&D firms to test 'amber' waste wood items and share results immediately to avoid potential compliance issues and increased costs.
Under RPS 291, waste producers are legally required to test at least one amber waste wood item per quarter and share results with the WRA. However, the association reports that it has not received sufficient test results to build the necessary evidence base.
Vicki Hughes, Technical Lead on the WRA Board, emphasised the urgency of the situation: "Time is running out for companies in the construction and demolition sector to test their waste wood before RPS 291 is withdrawn at the end of September."
The WRA has identified specific 'amber' waste wood items that require testing:
For buildings constructed between 1950 and 2006:
- Roof timbers
- Tiling and cladding battens
- Timber frames and joists
Additional items for buildings constructed between 1950 and 1995:
- Barge boards, fascias and soffits
- External timber cladding
- External doors
- External windows
These items are considered potentially hazardous due to the possibility of containing harmful treatments or preservatives used during their manufacture or installation.
Testing process and compliance
The testing process involves taking samples of the identified amber items and submitting them for laboratory analysis. The WRA states that companies must give explicit permission for laboratories to share the test results with the association.
To achieve compliance, companies must not only conduct the tests but also receive a WRA Submission report. This report serves as evidence of participation in the testing program and is now being requested by the Environment Agency as proof of compliance.
Potential cost implications
The WRA warns that failure to act now could result in a substantial increase in testing costs for C&D companies. Currently, firms are required to conduct one test per quarter at approximately £200. Without RPS 291, companies might need to perform up to ten tests for each site or project, potentially raising costs to £2000 per site.
"At present, companies only have to test one item per quarter at a cost of around £200. Without RPS 291, companies could be forced to carry out ten tests for every single site or project. So £200 now or potentially £2000 per site -- it should be a no brainer," Hughes added.
Beyond the financial implications, the WRA cautions that inaction could lead to the loss of hundreds of thousands of tonnes of recyclable waste wood to incorrect disposal. This not only affects the panel board and biomass sectors but also impacts the construction sector's sustainability and environmental targets.
The WRA is calling on C&D companies to act immediately while RPS 291 is still in effect. Companies are urged to submit one sample per quarter and ensure that laboratories have permission to share results with the WRA.
For guidance on complying with RPS 291 and participating in testing, the WRA directs companies to their Waste Wood Classification Toolkit, available on their website. This toolkit provides detailed information on identifying amber material, taking samples, and submitting them for testing.
