WRA publishes Waste Wood Assessment Guidance

The Wood Recyclers Association (WRA) recently published guidance on how to handle and process all items of waste wood, the culmination of a four-year project.

Two separate sets of ‘Waste Wood Assessment Guidance’ have been published, one pertaining to those working in the wood recycling sector and one to those in the construction and demolition sectors.

A pile of shredded woodOver 3.81 million tonnes of waste wood was processed in 2020 with 2.42 million tonnes going to Chapter IV biomass, 982 k tonnes going to panel board manufacture, 350 k tonnes into animal bedding, equine surfacing, reuse and other recycling, and 55 k tonnes going into small-scale biomass.

The WRA represents 90 per cent of the UK’s wood reprocessors, with an aim to ‘influence environmental legislation’ and ‘assist members to understand and respond to changing market conditions, legislation and regulation’.

The published guidance documents are aimed at helping waste producers and operators to understand and follow procedures to ensure the correct waste wood ends up in the right end market.

The sets of Waste Wood Assessment Guidance will also help operators to follow the correct procedures for two new Regulatory Position Statements (RPS), issued tomorrow by the Environmental Agency (EA).

RPSs are issued by the EA and let businesses know when they do not need to be in possession of an environmental permit to carry out certain activities.

The two new RPSs are titled RPS 249 and RPS 50.

RPS 249 will allow ‘potentially hazardous’ waste wood received at household waste recycling centres (HWRCs) to move as un-assessed, non-hazardous material, as long as it is destined for Industrial Emissions Directive (IED) Chapter IV compliant biomass or for the manufacture of panel board. 

This RPS will remain in place until the end of March 2024 to give the waste wood industry time to demonstrate that there is no longer any hazardous content in household waste wood, though this level of content is already diminishing and is ‘not expected to exist at all’ by the time the RPS expires.

RPS 250 will cover hazardous waste wood from demolition and refurbishment activities and will require all waste wood from construction and demolition sites to be assessed, and where deemed hazardous, consigned as hazardous waste using a hazardous waste consignment note.

It will also allow for the collection, storage, processing and blending of potentially hazardous waste wood from domestic premises, demolition sites and other business premises, to be carried out under existing environmental permits.

This RPS will remain in place until the end of August 2023.

The report suggests that, for both waste streams, further testing will continue to be undertaken until there is ‘sufficient evidence’ to demonstrate what, if any items, continue to be hazardous.

If hazardous material remains in the waste stream after the RPSs have expired, those who wish to handle the waste wood will need to apply for a permit variation to accept hazardous material.

Under RPS250, it is the responsibility of the waste handler to assess, segregate and consign the wood before passing it to a wood recycler or reprocessor.

If they assess it against the guidance and think it may be hazardous, they either have to get the waste wood tested to WM3 standards or move it under a hazardous code.

Where segregation is not possible, RPS250 also allows transfer stations and skip operators to move the material as mixed waste wood to a non-hazardous processing facility.

If the waste handler does this, it is also their responsibility to estimate the percentage of hazardous waste wood in the load and to record it on the consignment note, before transferring it to the wood recycler or reprocessor.

Waste wood recyclers and reprocessors can receive hazardous and non-hazardous waste wood under the two RPSs and can subsequently process and blend both materials to be sent to the two approved outlets - Chapter IV biomass and panel board manufacture - under a non-hazardous waste note.

In this context hazardous wood does not include the traditional hazardous waste wood items such as telegraph poles and railway sleepers, however.

These will continue to be classified as hazardous material (Grade D) and will need to be sent to specialist hazardous outlets. 

The new guidance will be sent out to members of the Wood Recyclers’ Association, the CIWM Construction and Demolition Forum, and the National Federation of Demolition Contractors respectively.

It will also be available to download from these associations’ websites.

Julia Turner, Executive Director of the WRA, commented: “We are pleased to have finally reached a conclusion for operators in England and we are satisfied that this is the best way forward for all concerned.”

“We are still working with the regulators in Wales, Scotland and Northern Ireland to finalise the position for operators in those nations but hope to have this agreed very soon.

“On behalf of the WRA I would like to extend my thanks to all involved in this project.”

Howard Button, Chief Executive of the National Federation of Demolition Contractors, said:
“As a result of great collaboration and a huge body of work by all involved, we now have a clear pathway forward and a tangible deliverable to our sector.

“NFDC is on hand to support its members and the wider industry with understanding the new demolition and construction specific RPS 250 and ensuring the guidance is followed effectively.

“It has been a pleasure to participate in the process and we are delighted to have reached a satisfactory conclusion.”

Howard Leberman, Team Leader for the national leads on Non-Hazardous Waste, Biowaste, Waste Exemptions and Fire Prevention at the EA, said: “We have worked very closely with the WRA and their partners on this project and I am grateful to all the sector organisations that have played a part for their commitment to this undertaking.

"We support the publication of [this] industry guidance which identifies waste wood types that are potentially hazardous. 

“With ongoing sampling and testing by industry, we are confident that some wood types currently identified as hazardous can be moved to non-hazardous. 

“Our time-limited Regulatory Position Statements provide a risk-based and proportional approach to how specific types of hazardous waste wood can be handled. 

“However, we still expect the majority of hazardous waste wood to be identified, segregated and consigned to facilities authorised to receive such waste."