Technical Guidance

What is Hazardous Waste?

There are strict controls about what may be disposed of in hazardous landfills.

The Environmental Permitting (England & Wales) Regulations 2010 details the criteria for waste acceptable at hazardous waste landfills by outlining the parameters and limit values for the chemical composition of the waste. Waste must be pre-treated and meet waste acceptance criteria (WAC) before it can be accepted at the site.

The main types of wastes that we accept at Whitemoss are contaminated soils, asbestos cement, and treatment residues from recycling processes.

A hazardous waste is defined as a waste that has one or more of the fifteen specified hazardous properties listed in Annex III to the Waste Framework Directive.

For technical information download the WM3 technical guidance, on the interpretation of the definition and classification of hazardous waste.

Key point: Landfill WAC analysis (specifically leaching test results) must NOT be used for waste classification and hazardous waste assessment purposes.

This analysis is only applicable for landfill acceptance and does not give any indication as to whether a waste may be hazardous or non-hazardous. (Page 23, WM3).

In June 2017 the Environmental Services Association working with partners in the waste industry produced an easy to use guide on common misconceptions in waste classification and how to avoid them.

What Hazardous Wastes can Whitemoss accept?

Whitemoss can dispose of a wide range of hazardous wastes. The nature of the waste, its classification and coding, determines whether a waste facility can accept the waste or not. At Whitemoss the wastes we can accept under the European Waste Catalogue (EWC) classification is defined in our IPPC permit under Schedule 2. The Whitemoss IPPC permit can be viewed on our Documents page.

Hazardous waste is further coded by the designation of Hazard Property codes. Whitemoss can only accept Hazardous Property codes HP4-HP7 and HP10-HP15; Hazard Property Codes HP1-HP3 and HP8-HP9 are not accepted.

A list of the Hazard Property Codes with descriptions can be viewed in WM3 technical guidance.

How do I know if my waste is hazardous?

Waste classification is a multi-stage process involving the assessment of hazardous properties, assignment of list of waste codes, and identifying whether a waste is hazardous or not. The Environment Agency publishes WM3 technical guidance which details this assessment process.

The European Waste Catalogue (EWC) is a classification system which assigns a six digit reference to each waste type arising from an industry or process. In the catalogue hazardous wastes are identified by an asterisk. There are more than 840 waste EWC codes.

On the 5th of July 2018 Annex III (list of hazardous properties), to the Waste Framework Directive (2008/98/EC), was amended to incorporate an updated definition, and assessment criteria, for Hazardous Property Ecotoxic (HP 14). As a consequence, the UK Environment Agencies technical guidance document ‘Waste Classification: Guidance on the classification and assessment of waste (WM3) has been revised. The amendments made are statutory with some minor complimentary cosmetic changes.

Consignment Notes

When hazardous waste is moved it must be accompanied by correctly completed paperwork called a consignment note. The note must be prepared before it’s moved.

Guidance on how to complete a consignment note is available on the Environment Agency web site.

Premises registration is not required in England but for premises in  Wales you need to register with Natural Resources Wales.

In Scotland hazardous waste is called special waste and guidance regarding can be found at the Scottish Environment Protection Agency.

Guidance for Northern Ireland is available at the Department of Agriculture, Environment and Rural Affairs.

Consignment Note Codes

You must create a consignment note code and enter it onto the consignment note. The format for the consignment note code must be ‘XXXXXX/YYYYY. The:

  • ‘XXXXXX’ is the first 6 letters/numbers (not symbols or spaces) of the name of the company entered in part A2 of the consignment note and must be followed by ‘/’
  • ‘YYYYY’ is exactly 5 numbers or letters (not symbols or spaces) you choose

For example, CJTILE/A0001. Each code can only be used once from the address in part A2. You must change the ‘YYYYY’ to create a different code each time waste is consigned from that premises.

Note: If your company name has less than 6 letters/numbers you must assign the letter ‘Q’ to remaining characters.

You must also assign an additional letter at the end of the consignment note code for certain types of consignment. Add:

  • a ‘V’ to waste removed from ships – ‘XXXXXX/YYYYYV’
  • an ‘F’ to fly-tipped waste – ‘XXXXXX/YYYYYF’
  • a ‘D’ to waste moving under a consignee return derogation – ‘XXXXXX/YYYYYD’
  • a ‘P’ to continuous piped waste, see further information

Additional letters are also assigned to rejected loads. See the EA guidance on rejected loads.

For more information on completing a consignment note please visit the Environment Agency web site.