The Environment Agency (EA) is seeking to raise the awareness of the changes to the third version of the technical guidance document WM2 released in August 2013. In a letter to the Chartered Institution of Wastes Management to EA emphasised concerns regarding incorrect classification of some hazardous wastes and encourage decision makers to reference version 3 of WM2 to ensure correct processes were being observed when arriving at a considered conclusion whether a waste should be classified as hazardous or not hazardous.
Concerns raised by the EA include
- Referencing an earlier version of WM2
- The more frequent updating of the chemcial properties index from health & safety legislation
- The incorrect application of worst case chemical compounds
- Not applying the additive effect of some hazardous properties
It is important that organisations making decisions as to whether wastes should be classified as hazardous or not reference version 3 of WM2 and in particular the 21 worked examples for some complex wastes which provide specific guidance for areas which present particular challenges for decision makers. Further support is provided with an appendix detailing best practice for waste sampling.
This guidance is updated every two years and colleagues are reminded that a decision as to whether a waste should be classified as hazardous or not remains with the waste producer even where advice is being provided by a competent waste contractor. To this end waste producers should assure themselves that the process of advice is robust, up to date and accurate when undertaking any \”duty of care \” audit.
For further advice please contact Albion Environmental to be assured of expert knowledge in this potentially complex area. The technical guidance document can be downloaded from the Environment Agency Website.