You may be aware from our previous blog posts that the criteria for the classification of hazardous wastes in the UK and Europe will be changing from 1st June 2015*.
For UK readers the full details of the reasons why can be found in the Environment Agency consultation document.
The following steps provide an outline of what you need to do to stay compliant.
1. Download a copy of the Environment Agency’s draft WM3 document, which replaces WM2.
Keep your eyes peeled for the finalised version when it comes out, there are some mistakes in the draft version. The procedure for H14/HP14 has not been decided.
2. Make sure you follow the correct procedure for choosing a European Waste Catalogue (EWC) code.
It is the type of EWC code which decides whether a waste is hazardous, non-hazardous or whether the waste should be assessed to determine its hazard.
Some have been added or revised, but not many.
3. Use the correct source for obtaining chemical hazard information.
In WM3, this is given as CLP Table 3.1 and non-harmonised notified entries, both available in the ECHA C&L Database, in that order, before consulting other data sources (such as SDS).
4. Check whether substance thresholds have changed in WM3 and check for POPs
The flash-point threshold for flammable liquids has increased to 60 ºC and the threshold for sensitising substances has changed from 1% to 10% e.t.c.
POPs are Persistent Organic Pollutants, see WM3 Page C49.
5. Update hazardous waste consignment notes
‘H Codes’ become ‘HP Codes’, e.g. H6 becomes HP6.
Waste and chemical hazards more closely align with dangerous goods classes and packing groups.
Please contact us if you require any help or advice.
If you require a detailed overview, we have a training course available that can be delivered on-site.
We’ll keep you informed of any developments as we hear them.
*NB. The implementation date of 1st June has been delayed until mid June 2015