13 November 2020
Recently the Environment Agency (EA) released a letter to be sent to all waste operators (in England) who produce Trommel Fines. This letter stressed the importance of correct classification of trommel fines and highlighted the fact that “only when a waste assessment, carried out in accordance with WM3 guidance, shows the waste does not display any hazardous properties, can the non-hazardous mirror waste codes be assigned (19 12 12)”
The need to classify waste in accordance with WM3 guidance is not new and applies to all waste regardless of its LOW code.
Following its national campaign to better understand the chemical composition of trommel fines the EA reported to have found over half the samples breached hazardous waste thresholds. Typically, waste operators have assumed that non-hazardous waste treatment would produce non-hazardous fines and have coded this waste 19 12 12 rather than 19 12 11* (hazardous waste) without undertaking any analysis and assessment.
The EA sign off the letter by stating that they ‘will request to see copies of your waste assessments during future compliance visits’.
In addition to the analysis required to assess hazardous properties and correctly classify the trommel fines, if the fines are to be disposed of to landfill then there are other tests that need to be carried out in relation to landfill waste acceptance criteria. I generally find that operators are more familiar with these landfill requirements but not with waste classification requirements. The Technical Guidance document WM3 provides a detailed and comprehensive account of how waste should be classified.
- That the technical goals and objectives are identified.
- That sampling is undertaken to ensure a representative sample is obtained.
- That all compounds that may be present in the waste are analysed for.
- That an assessment is carried out to identify if the waste displays any of the 15 possible hazardous properties.
It is no longer the case that old rules of thumb can be used, such as ‘the metal concentrations add up to less than 2,500mg/kg therefore waste is non-hazardous’.
What Should I Do?
Firstly, do not rush off, grab a sample and send it to the lab asking for a WM3 test and assessment. In many cases this will not result in a robust classification that would pass the scrutiny of the EA. Consider how you will sample the waste and document this (see WM3 appendix D and the sampling form).Talk to the lab/consultant about a suitable suite of determinants that would be appropriate and get a properly trained person to undertake the assessment. When you get the assessment report – make sure you are satisfied with the accuracy of its content.
I am certain that right now that any trommel fines producers are counting the additional costs of these requirements. However, also consider the potential ramifications of not classifying this waste or of misclassification, including increased permit costs, fines, prosecutions etc. You will find a free video resource available on our website that talks about trommel fines in more depth. Click here.
Westbury Environmental Limited have worked with many waste operators over several years to ensure that waste classification requirements are met as efficiently as possible. We work with laboratories and have fully trained haz. waste assessors to ensure a robust assessment is achieved. We also provide training via our webinars. Are you classifying your waste correctly? Are you sure? If you answered "No" to either of these questions, then you are not alone. Join us for our upcoming webinar Your Waste: Is it Hazardous? starting on Tuesday 1st December, to gain an understanding of waste classification and the consequences of getting it wrong. Find out more and register your place here.