Warning Notice - Importing 6F2 For Temporary Works
Are You Potentially Importing a Contaminated Waste on to Your Sites?
A handful of our customers have been caught out recently by recycled aggregate suppliers importing significant volumes of “contaminated” 6F2 into their sites.
We are regularly asked by our customers to remove or relocate 6F2 from their sites which has been used for temporary works. The material is then technically deemed a waste product. The problem occurs when you test the 6F2 from a waste perspective, the results frequently highlight contamination in the material.
A More Considered Approach
A much more considered approach is recommended when importing 6F2 as there is a significant risk for any business from contamination if this is not tested correctly. In my experience I have found that the majority of 6F2 suppliers do not provide chemical test results. Customers must also share the blame and predominantly prioritise purchasing a “cheap” product that meets their budget above a “clean” product. I have also found that 6F2 enquiries appear to be very reactive and customers are simply not prepared to wait to carry out compliance tests on the product.
The WRAP Protocol for Production of Aggregates
The problem, as I see it, is that the WRAP protocol for production of aggregates is based on recovering “inert” granular waste materials. Suppliers are typically importing this type of waste on a continuous basis into their transfer stations from numerous different sources on an inert EWC code. How much of this is actually chemically tested or checked for asbestos content, a very low percentage I would assume, after all, who chemically tests demolition rubble?
Some suppliers, may insist on a WAC test to demonstrate that the granular material is inert (this seems to meet the WRAP protocol requirements and is adopted by many of the leading aggregate suppliers in the UK). The problem with this approach arises if the 6F2 subsequently becomes a “waste”. At this point a chemical test is required to classify the waste material and we are consistently finding issues with 6F2 material containing elevated heavy metals, hydrocarbons and traces of asbestos. When you consider the primary sources from which 6F2 is generated this is hardly surprising (demolition waste, concrete hardstanding’s, colliery spoil, ash & reclaimed asphalt).
This scenario often results in bad feeling between supplier and customer and develops into a stalemate situation. From the customer’s perspective, they see the material as “uncompliant” and want the contaminated 6F2 removing at no cost, after all a contaminated product has been imported onto their site and is considered a liability. Alternatively, from the suppliers point of view they have provided a grading certificate and claim to have followed the WRAP protocol. “If the customer required a chemical analysis they should have requested one when buying the 6F2”.
Don't Take the Risk
We are calling out to all suppliers and customers, don’t take the risk in future, call Ecofficiency on 0800 0305051 and ask to speaking the EcoEnvironmental Department regarding waste classification testing.
Article by Simon Raven of Ecofficiency