Demolition contractors are being reminded to carry out testing on certain types of waste wood from pre-2007 buildings as a matter of urgency, to help identify the true extent of hazardous material in the UK.
The National Federation of Demolition Contractors (NFDC) has reissued advice to its members to carry out testing on waste wood from demolition projects in order to avoid misclassification of the waste.
In an email to its members, NFDC Chair Howard Button has said: “Following a recent meeting with the Environment Agency the NFDC implore you to carry out testing on your waste wood to identify whether it is hazardous.
“Misclassifying hazardous waste wood is illegal. Classifying all wood as hazardous is costly. We need you to sample and test your wood so we can understand what is hazardous and what is not.”
The reminder follows the publication of two sets of Waste Wood Assessment Guidance produced by the NFDC and the Wood Recyclers’ Association (WRA) in September for their respective members, to help them follow the correct procedures when handling waste wood following the four-year-long Waste Wood Classification Project.
The Guidance documents were produced in response to the EA publishing two new Regulatory Position Statements (RPS), one for waste wood coming from Household Waste Recycling Centres (HWRCs) and one for waste wood coming from demolition sites.
The RPSs came into force on August 1st allowing for mixed loads of waste wood in England to be processed by operators for use in panel board manufacturing and Industrial Emissions Directive (IED) Chapter IV compliant biomass boilers.
This has meant that HWRCs are able to carry on operating as normal, with no additional administrative costs, while the WRA continues to test fence posts and decking (the two types of wood under scrutiny from HWRCs) over the next two years. They hope this will prove that hazardous content is declining even further than the 0.06% already reported, and that by 2023 will no longer be there.
For demolition contractors, the potentially hazardous items are structural timbers, external joinery and tiling battens from pre-2007 buildings. These have to be segregated, tested and consigned by demolition contractors under the new RPS250. If skip operators and transfer stations are unable to segregate, they can consign the whole load as hazardous, but should give an estimated percentage of the potentially hazardous items contained in that load.
A load such as this can still be taken by wood recyclers/reprocessors and blended with other waste wood as long as it is destined for large-scale biomass or panel board but may incur additional costs. In the long term the overall cost of disposal of these items will increase, due to the additional paperwork and / or permitting needed to manage them.
New Positions in Wales and Scotland
In Wales and Scotland, Natural Resources Wales (NRW) and the Scottish Environment Protection Agency (SEPA) have issued separate positions following the work carried out by the waste wood classification project. They follow similar principles to those in the EA RPSs, but do not require potentially hazardous demolition waste wood items to be segregated, tested and consigned. These positions are also pending the results of further testing by the WRA and NFDC.
Two sets of Guidance updated
The two sets of closely aligned guidance documents from the WRA and National NFDC have been updated to reflect the recent additions from NRW and SEPA, and the WRA has also revised its Frequently Asked Questions document to reflect further questions asked by members and others in the waste wood industry since September. Its Guidance and the FAQs can be accessed from its website www.woodreyclers.org
RPS Information
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 Industrial Emissions Directive (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.
Background to the Waste Wood Classification Project
The WRA, the CIWM Construction & Demolition Forum, and the National Federation of Demolition Contractors (NFDC) have been working together on the Waste Wood Classification (WWC) project since September 2017.
The aim of the project is to ensure that waste wood in the UK is properly classified at its origin and is processed into appropriate end markets. It has also identified which waste wood items are hazardous and is researching to what extent these are still in circulation.
Work so far has included detailed sampling and testing plans as well as large-scale laboratory testing of the materials of concern, which took place throughout 2019 and 2020. The materials involved were:
- Fence posts and decking from household sources
- Structural timbers, tiling battens and external joinery from pre-2007 buildings from demolition sources
The laboratory testing of the wood showed that there were insignificant amounts of hazardous content in fence posts and decking from the household stream (0.06%) and that this is diminishing and is not likely to exist at all from 2023. The testing also proved that all construction and the majority of demolition waste wood was non-hazardous.
Testing will continue on all of the above for the next two years.