Under the EU Waste Framework Directive, any removal of soil from a site implies that ‘your intention is to discard the material’ and the soil becomes classified as waste. Even if someone wants the waste soil, it remains classified as waste.
Part of the waste duty of care for a waste producer is establishing the correct waste classification. The identity of any hazardous properties will need to be considered in order that the waste can be classified. To establish if the waste has any hazardous properties, it must be subjected to a robust chemical analysis. A waste can only be classified as either Hazardous or Non-Hazardous. The term ’Inert’ is not a classification.
HWM makes the decision whether to accept the waste at our treatment facility depending on the EWC code that the waste has been classified with. Our treatment facility has a list of permitted EWC codes and these can be found on the Environment Agency permit.
In order to make an accurate classification of waste soil HWM Ltd require, as the waste disposal point, that the minimum requirements for chemical testing of soil to determine the correct waste soil classification will be as follows:
- Metals and semi-metals (arsenic, cadmium, chromium (III & VI), copper, lead, mercury, nickel, selenium and zinc
- Total Petroleum Hydrocarbons (TPH) C6-C40
- Aliphatic/aromatic carbon banding (C5-C8, C8-C10, C10-C12, C12-C16, C16-C21, C21-C40)
- Polycyclic Aromatic Hydrocarbons (PAHs) (speciated into USEPA 16 compounds)
- Moisture Content
- Asbestos Screen then ID and quantification
- Cyanide (free)
- Volatile Organic Compounds (VOCs)*
- PCBs - 7 Congeners*
- Phenol Index*
*Some discretion on the testing may be allowed in certain cases depending on whether there has been a site investigation report submitted to HWM Ltd The site investigation report gives important information to the assessor regarding the previous use of the site. From this, a better interpretation of the chemical data can be made leading in some instances to reduced costs for the disposal of the soil.
HWM Ltd are regularly audited by the EA and other companies to show compliance in accepting waste into our treatment facility. Therefore, it is imperative that we ensure the correct classification of all waste that we receive.
In our experience, there has been an over-reliance on the use of Waste Acceptance Criteria (WAC) testing when it comes to the disposal of waste soils generated by development. A commonly held misconception is that the result of a WAC test can be used to obtain an accurate waste classification. A WAC test must never be used to classify waste, it is purely used for the determination of how a waste will behave once it is buried in landfill. This is carried out primarily through analysis of the leachate derived from the waste during specific laboratory testing.