WM2 – Interpretation of the definition and classification of Hazardous Waste

Posted in Advice, Company News, by admin
3rd Edition 2013


WM2 was revised last summer it has become apparent that the many people in the waste industry are still unaware of how soils contaminated with asbestos should be classified for waste disposal purposes. WM2 now provides a specific example about how soil and other construction and demolition waste containing or contaminated with asbestos should be assessed.

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Example 17 on page A59 of WM2 says that:
“If the waste contains, in addition to any dispersed fibres, any asbestos in identifiable pieces they must be assessed as set out below. This would also apply to any dispersed fibres produced by deliberately breaking up such identifiable pieces.
Where the waste contains identifiable pieces of asbestos (i.e. any particle of a size that can be identified as potentially being asbestos by a competent person if examined by the naked eye), then the asbestos must be assessed separately. The waste is hazardous if the concentration of asbestos in the pieces alone is 0.1%. The waste is regarded as a mixed waste (see example 1) and classified accordingly. The following codes should be assigned to the asbestos waste as appropriate:
  • 17 06 05* Construction material containing asbestos MH
  • 17 06 01* Insulation material containing asbestos MH
  • 17 06 05* would normally be used in preference to 17 06 01* for the asbestos in asbestos contaminated soil and stones.”
Example 1 on page A37 says that:
“If more than one separately identifiable waste is present then more than one list of waste code will be required. The general principle is that if 3 items of waste (one each of types A, B and C) are placed in a single container, then that container contains 3 wastes. Each of which must be separately assessed, described and coded.”
Example 17 says that if the concentration of asbestos in the pieces alone is > 0.1% then the waste is hazardous. All asbestos containing materials likely to be identifiable by the naked eye contain more than 0.1% of asbestos. There is no threshold indicated for this so currently a single piece of asbestos would be sufficient to classify several hundred tonnes of soil as hazardous. We have queried this with the Environment Agency and had confirmation that this is the correct approach to waste classification. We also queried what size the piece of asbestos would have to be and was told that a piece the size of a 5p would be large enough. If there are visible pieces of asbestos then the waste must be classed as hazardous on that basis alone. The waste would then have two EWC codes, one for the soil, probably 17 05 04 or 17 05 03 depending on any other contaminants in the material and one for the asbestos. For asbestos from asbestos cement sheets then the code would normally be 17 06 05.
It is important to note that, even if your laboratory results show less than 0.1% of asbestos in any soil samples, the soil should be classed as hazardous if there are any visible pieces (larger than a 5p) of asbestos containing material. In practice it is not practicable to pick over a soil to remove all pieces of asbestos containing material bigger than a 5p piece although based on considerations of occupational exposure it may well be advisable.
Mechanically screening a contaminated soil may deliberately break up such identifiable pieces and WM2 explicitly states that you would still have to classify the soil as hazardous. Significantly reduce your hazardous waste costs by using Ecofficiency for contaminated soil removal and asbestos testing services.

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