WRA releases hazardous waste wood guidance
In the wake of concerns from the Environment Agency (EA) about waste wood classification, the Wood Recyclers Association (WRA) has published a guide to help wood recyclers and reprocessors accurately report hazardous waste wood if it arrives on site in waste wood loads.
This publication comes in response to concerns raised by the EA in September 2017 that some treated waste wood was being described as Grade A ‘clean’ untreated material, and thus ending up being processed in boilers not compliant with the Industrial Emissions Directive (IED). The WRA highlighted the issue to its members but the EA proposed stricter rules that could see entire loads of mixed waste wood potentially classified as hazardous waste, if the load cannot be properly assessed at the front end.
In November last year, this was followed up with a Regulatory Position Statement (RPS), temporarily allowing unassessed treated or mixed waste wood to continue to be classified as non-hazardous, provided it is to be used in an IED Chapter IV-compliant incinerator, or to be used for the manufacture of board. Waste wood that is already recognised as hazardous (including railway sleepers, telegraph poles and creosote-treated wood) must still be consigned and segregated as such.
The RPS will be withdrawn on 1 November 2018, after which point all unassessed waste wood must be classed as hazardous, if its properties cannot be properly assessed at the front end. This could bring the UK more in line with other European countries, which report far higher levels of hazardous waste within their waste wood: Germany, for instance, recorded around 15 per cent of its waste wood as hazardous, compared with less than 0.5 per cent in the UK, suggesting that Britain is indeed misclassifying its waste wood.
A letter jointly signed by a group of organisations in the waste and recycling sectors (including the WRA, the National Association of Waste Disposal Officers (NAWDO) and the Local Authority Recycling Advisory Committee (LARAC)) claimed the changes could be ‘catastrophic’ for UK wood recycling rates, potentially reducing recycling by up to six per cent a year.
Now, the WRA is leading a group of industry representatives to identify best practice for front-end classification and processing of waste wood. Its guidance comes at a crucial time for the waste wood industry to develop and improve its assessment of waste wood before the RPS comes to an end.
Executive Director of the WRA, Julia Turner, said she hoped all WRA members would be compliant with the guidance by 1 April 2018, adding: “Although reprocessors have been removing and returning any hazardous waste they find, the difference now is the reporting method.
“This guidance will ensure that our members report hazardous materials in a consistent and transparent way, which will help to build evidence for our ongoing work on waste wood classification.
The WRA quick guide to reporting hazardous waste wood
All loads will be inspected as tipped.
Hazardous material needs removing, weighing, recording and reporting as soon as it’s identified.
The supplier of the hazardous material needs to decide what happens next while the driver is still on site, and all actions are at the supplier’s cost:
- Return it on delivery vehicle to supplier or alternative site immediately; or
- Collect it and return it to supplier or alternative site within 24 hours; or
- Ask the reprocessor to dispose, raise paperwork and charge supplier.
A consignment note needs to be raised by the supplier to confirm the above action and must be seen by the reprocessor.
The reprocessor must also raise a consignment note to record the reject which must be raised and sent to the supplier and haulier immediately after the action is agreed.
Notification of rejection and subsequent consignment notes need to be reported by both parties to the EA by phoning 03708 506 506 within 24 hours and included on quarterly consignee returns.