The culmination of the Waste Wood Classification Project will see two separate sets of Waste Wood Assessment Guidance published, one for those working in the wood recycling sector and one for those in the construction and demolition sector.
The 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.
In England the Environment Agency (EA) is publishing two new Regulatory Position Statements (RPS) on July 23 for anyone handling waste wood. The RPSs will mean that mixed loads of waste wood in England can continue to be processed by operators for use in panel board manufacturing and Industrial Emissions Directive (IED) Chapter IV compliant biomass boilers.
The two sets of Waste Wood Assessment Guidance will help operators to follow the correct procedures for the RPSs. Regulators in Scotland, Wales and Northern Ireland are due to announce their final positions on this work shortly.
The two new RPSs are as follows:
RPS 249: This allows 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 IED Chapter IV compliant biomass or 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. This is already diminishing and is not expected to exist at all by the time the RPS expires.
RPS 250: This covers hazardous waste wood from demolition and refurbishment activities. This now requires 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 with the correct waste codes. However, it also allows 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.
For both waste streams further testing will now continue to be undertaken until there is sufficient evidence to demonstrate what, if any, items continue to be hazardous.
If hazardous material is still in the waste stream after the RPSs have expired, those that wish to handle it will need to apply for a permit variation to accept hazardous material.
Under RPS250, it is the responsibility of the waste handler (ie: contractor/skip operator/waste transfer station etc) to assess, segregate and consign the wood before passing it to a wood recycler/reprocessor. If they assess it against the guidance and think it may be hazardous they either have to get it 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 it as mixed waste wood to a non-hazardous processing facility. If they do 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/reprocessor.
Waste wood recyclers/reprocessors can receive hazardous and non-hazardous waste wood under the two RPSs and can then process it 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.
However, it is important to note that in this context hazardous wood does not include the traditional hazardous waste wood items such as telegraph poles and railway sleepers. These will continue to be classified as hazardous material (Grade D) and need to be sent to specialist hazardous outlets. A full list of these items is contained in both guidance documents.
Both sets of the new Waste Wood Assessment Guidance explain how to work under the new RPSs in detail. They will be sent out to members of the Wood Recyclers’ Association, the CIWM Construction & Demolition Forum, and the National Federation of Demolition Contractors respectively and will also be available to download from these associations’ websites.
Julia Turner, executive Director of the WRA, has been leading the project since it began in 2017. “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,” she said.
“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.”
“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,” said Howard Button, chief executive of the National Federation of Demolition Contractors (NFDC).
“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.”
“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,” added Howard Leberman, team leader for the national leads on Non-Hazardous Waste, Biowaste, Waste Exemptions and Fire Prevention at the EA.
“As environmental regulators we have a duty to ensure that industry is operating within safe boundaries and we are happy with the outcome of this project and believe that the guidance documents and the two Regulatory Position Statements will ensure that all waste wood is correctly classified going forward and will therefore be destined for the appropriate end use.”
