Resource Use

EA starts demanding RPS 291 compliance on waste wood

Waste and recycling firms are being urged to check whether they are meeting their legal duties for storing and processing waste wood under RPS 291 as the Environment Agency starts to actively check compliance.

waste wood rps 291Regulatory Position Statement 291 (RPS 291) was introduced in November 2023, allowing operators who handle potentially hazardous ‘amber’ waste wood to move and process it as non-hazardous - provided they meet certain conditions.

Amber waste wood refers to roof timbers, tiling and cladding battens, timber frames and joists from buildings built between 1950 and 2006.

Under RPS 291, facilities must test amber waste wood at least once a quarter, before sharing results with the Wood Recycling Association (WRA) which then issues the ‘WRA Submission Report’ that demonstrates compliance.

The Environment Agency (EA) is now asking operators to present WRA Submissions Reports as evidence of a supply chain’s participation in testing and data sharing.

The reason behind the demand for test results is that it is hoped that mounting evidence will demonstrate that more items are non-hazardous, meaning they wouldn’t be subject to the costly hazardous waste controls when the RPS is removed in October 2024.

RPS 291 compliance

Howard Leberman, Senior Advisor at the Environment Agency, said: "In order to be compliant with RPS 291, operators who take amber items of waste wood must check that it is being tested at least once per quarter and results are shared with the WRA.

“We're now past the first quarter so are actively looking for WRA Submission Reports to confirm participation."

Vicki Hughes, Technical Lead on the WRA Board explained how some sites are carrying out testing but are not sharing their data with the WRA, so are seen as non-compliant. She also clarified that while the RPS puts the producer of the waste as responsible for testing the material, in practice that means that waste wood processors also have to test, unless they are able to demonstrate that all the material they handle is already compliant.

She advised: “All test results are anonymous and operators only need to identify and test one of the ten potentially hazardous items each quarter to comply.

“The amber items are not that easy to find, so if you find one of these items, it is advisable to take a sample for testing straight away to ensure compliance for that quarter. It is important to note that once the sample has been taken and sent to a lab for WRA 02 testing, the tested item does not need to be stored separately while awaiting the results and can be moved immediately as non-hazardous.”

RPS 291 is a temporary measure following the removal of RPS 250 in September 2023, at which point operators became required to test all potentially hazardous material. RPS 291 will be in place until October 2024, which is why the WRA is keen to use the coming months to gather data and prove more items are non-hazardous, to avoid costly mass testing when it expires. This will, Vicki Hughes explains, “cut red tape and ensure as much waste wood as possible is recycled and save the industry significant sums.”

Waste wood classification toolkit

The WRA has developed a Waste Wood Classification Toolkit offering a step-by-step guide on how to identify amber material, take samples and send them off for testing. Whilst material should be tested according to an WRA testing suite, operators need to actively ask laboratories to share the results with the WRA. However, operators do not need to ask laboratories to determine whether the material is hazardous or not, as all results are analysed by the WRA’s in-house team.

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