May 2022

Welcome to our May 2022 newsletter. This month we have a number of topics to bring to your attention:

  • Working across European Nations – Which classification engine?
  • NEW – Flag advisory system (FAS) – to help improve classifications

Working between European Nations – Which classification engine?
 

When a customer subscribes to HazWasteOnline, their subscription comes with one classification engine; the choice of engine being normally dictated by the nation in which they work and for EU customers, whether they want to classify wastes contaminated by oil.

A classification engine is used to process the laboratory results and generate a standard PDF classification report; a report that includes the List of Waste code, data and a listing of any hazardous properties that the waste may have. An engine is simply a set of rules that enacts the stipulations contained in a particular technical guidance such as the UK’s WM3 or the EU’s EU/2018/C 124/01. Each time the guidance changes, i.e. the rules change (e.g. thresholds, calculations, cut-offs etc.), a new classification engine is built to reflect the changes in the guidance.

The selection of which engine a customer has is based primarily on;
– the nation in which they work, with the basic assumption that this jurisdiction indicates where the waste will be disposed of, and
– whether or not they have to assess contamination by unknown oils.

However, following Brexit, we have;
– a different regulatory regime for Northern Ireland versus Great Britain (meaning we have to use different chemical data sets), and
– the differences between code designation in the UK’s List of Waste versus the EU’s List of Waste.

Due to these variables, we effectively have to supply four classification engines to meet the needs of customers across Europe.

These engines are summarised in the table below.

Engine nameGuidanceData sourceList of Waste (LoW)
WM3 V1.2.GBWM3MCL ListUK
WM3 V1.1. NIWM3CLP table 3UK
EU WM3 V1.1. NIWM3CLP table 3EU
EU/2018/C 124/01EUCLP table 3EU

The 87 differences between the UK LoW codes and the EU’s LoW codes are tabulated in HazWasteOnline’s Help Wiki (search for ‘Key differences’). As an example, in Chapter 17, there is one difference: 17 06 05* construction materials containing asbestos; is a mirror hazardous entry (MH) in the UK’s technical guidance but an absolute hazardous entry (AH) in the EU’s technical guidance.

With respect to the chemical data, there are already differences between the GB’s MCL list and the EU’s CLP Table 3. For example, in HazWasteOnline, CLP Table 3 includes the updates from ATP17 (Regulation (EU) 2021/849) while the UK’s MCL list does not. This is because the UK regulator, the HSE, has (i) reached different conclusions with respect to some of the hazard properties of the substances in ATP17 and (ii) the HSE hasn’t yet published their equivalent to ATP17.

These differences are only going to increase over time as the UK regulator takes different decisions, at different times, and for different chemicals, to the EU regulator.

EU Classification Engine:
EU/2018/C 124/01

The current technical guidance for the classifictaion of waste in the EU is the Commission notice on technical guidance on the classification of waste – Note 2018/C 124/01.

This engine uses the substance data published in the CLP’s Annex VI, Table 3 (Harmonised Entries) and the designations in the EU’s List of Waste.

The EU guidance has the same rules and thresholds as WM3; however, there are a few differences with respect to List of Waste code designations and no help for unknown oils.

WM3 Classifictaion Engines:
WM3 v1.2.GB

This engine is based on the current WM3 V1.2.GB technical guidance and should be used for the classification of waste that will be disposed of in England, Scotland or Wales.

This engine uses the substance data published in the HSE’s Mandatory Classifictaion and Labelling list (MCL List) (Mandatory Entries) and the designations in the UK’s List of Waste.

WM3 v1.1.NI

This engine is based on the current WM3 v1.1.NI technical guidance and should be used for the classifictaion of waste that will be disposed of in Northern Ireland.

This engine uses the substance data published in the CLP’s Annex VI, Table 3 (Harmonised Entries) and the designations in the UK’s List of Waste.

EU WM3 v1.1.NI

This engine follows the WM3v1.1.NI technical guidance and can be used for the classification of wastes that will be disposed of in EU countries.

This engine uses the substance data published in the CLP’s Annex VI, Table 3 (Harmonised Entries) and the designations in the EU’s List of Waste.

Most of our EU customers use this WM3 based engine rather than the EU engine because it allows them to deal with potential hydrocarbon contamination (“TPH”) in their waste.

Changing engines / working in two jurisdictions

Classifiers working in different jurisdictions will need more than one Classification Engine. For example:

– If you’re working and disposing of waste in Northern Ireland, you would have the WM3 V1.1.NI engine, but if you have to send a waste to GB (England, Scotland or Wales), you would also need to subscribe to the WM3 v1.2.GB engine.

– If you are working and disposing of waste in GB, you would need the WM3 v1.2.GB engine, but if you have to send a waste to Poland, you would also need to subscribe to the EU WM3 v1.1.NI engine (or EU/2018/C 124/01 engine).

– If you are working and disposing of waste in the Republic of Ireland, you would have the EU WM3 v1.1. NI engine, but if you have to send a particular waste to Northern Irleand, you would need to subscribe to the WM3 v1.1.NI engine.

Flag Advisory System (FAS)

As those of you who have been on our training courses know, the classifictaion of waste is not as simple as typing the laboratory results into HazWasteOnline and clicking go. There are a multitude of rules, exceptions and steps (plus learning the software) that have to be processed in order to produce a reasonable classification. Whilst we provide training courses, telephone and email based support, YouTube videos and guidance in our Wiki to help classifiers, we see many errors in classifications that are not being caught and in some cases can lead to miss classifications.

To help mitigate some of these mistakes and provide another way to learn, we have built the Flag Advisory System (FAS) which provides in-line support in a given Job that can be used to help improve classification. 

Where one or more potential issues are identified for a given determinand, a flag is placed in the column adjacent to the unit column:

There are three severity’s for the flags:

  •   Advisory
  •  Common mistakes that may need fixing
  •  Significant issue that needs to be addressed

Clicking on the flag opens a pop-up window which both documents one or more issues and offers advice as to how to deal with them.

While the full list of FAS can be found in the Wiki, a few examples are given below:

  • Met-03: No conversion factor – reflects the case where the classifier has a non-speciated metal compound in their Job (e.g. vanadium pentoxide) but hasn’t entered a conversion factor (the CF is required to convert the amount of metal to the amount of the metal compound). Note that if the classifier creates their own user-defined metal compound, the presence or absence of a CF is not currently checked by the FAS.
  • TPH-02: More than one petroleum group – reflects the case where the classifier has entered “TPH” concentrations against two or more petroleum groups e.g. ‘TPH (C6 – C40) petroleum group’ and ‘diesel petroleum group’; this is not permitted by the guidance.
  • Cr-01: Cr(VI) Balance -This flag will be present for all metal chromates listed in a job. Its purpose is to advise the classifier as to whether they have enough chromium(VI) to “make” each listed metal chromate. For example, if there were 29 mg/kg of chromium(VI) and 370 mg/kg of zinc in the form of zinc chromate; clicking on the red flag generates a pop-up window that for each metal chromate provides a series of yes/no answers to three questions. These answers can be used by the classifier to guide the actions that they might want to take.
  • Further, clicking on the [Info] link (last column) will pop-up a second window that displays the three questions and the data and calculations performed to answer each of the questions.
  • So looking up the Yes, No, No answers in the Action table (above) helps the classifier decide what to do. In this example scenario, the Action says there isn’t enough chromium(VI) so they should consider changing the zinc species to the next one in the speciated list.    

We will be adding more flags over time, especially as we intergrate other data in the .hwol file with the Job.

If you find an issue with a particular flag. or have suggestions for improvements, please let us know.

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