- We will be adding a classifier’s training status to their Classification Reports
- Audit Review service
- What to do if you have measured the concentration of iron in your soil
- Assessing lead paint on articles such as steel windows or I beams
- WAC update
- DETS (south) joins our list of labs able to offer our .hwol data delivery format
- AGS publish guidance on the sampling of soils for waste classification
- We are moving – New postal address from 1st April 2019
We are frequently asked whether the person named on a HazWasteOnlineTM report has had any formal training, in both the use of the software and in waste classification; a question usually asked because the classifier hasn’t always made the best classification. Some of the simpler limitations in practice include; not applying a moisture correction, sticking with worst case substances, using elemental metals (see iron below), incorrect use of conversion factors, leaving classifications as Potentially Hazardous and missing supporting information.
To help address these issues, improve knowledge and move closer to creating a competent person status, we are planning to:
- add the classifier’s training status to their classification report by including information stating which HazWasteOnlineTM course (either Part 1 or Part 2, where completed) classifiers have undertaken in the last 3 years. Classifiers will be expected to take a one day refresher course every 3 years to keep up with changes and continue their professional development. We are planning to start publishing training status on reports later this year. If you need to check which course(s) you have completed and when, please get in touch.
- Provide an audit service to our customers whereby we login with you and review a selection of your classifications to identify areas where improvements to practice might be made and to discuss any problems that you might have. The service will be conducted by telephone or web meeting and can look at and discuss any aspect of the projects present in a company’s HazWasteOnlineTM project. The cost will be £150 for up to an hour of meeting time.
If you have any comments or thoughts on these initiatives, please get in touch.
Metals in soils – Iron (Fe)
Some classifiers find that, for one reason or another, iron has been included in the suite of metals tested when characterising a soil for waste classification. Depending on the geology, iron concentration in an uncontaminated soil may vary from less than 10,000 mg/kg to more than 100,000 mg/kg. To include the iron results in a classification, the classifier has to:
- decide which form (species) of iron is present in their soil
- then determine if the chosen species of iron is present in HazWasteOnlineTM and if so, is it suitable for the form of the iron in their soil, or
- if the desired iron species isn’t present in HazWasteOnline, how does the classifier a) research the necessary hazard statements b) work out the conversion factor and c) add the substance to HazWasteOnlineTM
This discussion isn’t going to cover every aspect of the points outlined above, in particular the third bullet which is covered more thoroughly in the Advanced training course.
Let’s imagine a simple scenario;
- a greenfield site near Gloucester
- samples from a (surplus) soil that will be excavated as part of a road widening scheme
- concentrations of iron varying from 26,000 to 38,000 mg/kg
As the soils are stained red and underlain by red Triassic mudstones, it is reasonable to assume that the iron is in the form of the mineral hematite which has the molecular formula Fe2O3 (iron(III) oxide; CAS 1309-37-1). Converting the amount of iron to iron(III) oxide generates concentrations of between 3 and 5% iron(III) oxide. This range of concentrations mirrors the range of concentrations documented in the British Geological Survey’s G-Base survey of UK soils for this area (i.e. one of your lines of evidence).
Searching HazWasteOnline’s database finds two entries for iron(III) oxide, both with green dots (a green dot next to a substance indicates a substance that has been defined by HazWasteOnline, usually because it is not in the CLP), one of which is labelled “(worst case)” and is hazardous at only 1%, the other, not labelled worst case and hazardous at 20%. Why the difference and which one might be best utilised to help characterise the soils?
Typically green dot entries are worst case entries because HazWasteOnlineTM does not know anything about a) the form of the substance (solid, dust, grade 1,2,3, nanoparticles, amorphous etc.) or b) the nature of the waste stream that might contain that substance. It is up to the classifier (assuming the concentrations they have are high enough to trigger a hazardous outcome in the first place) to decide whether the worst case green dot substance is suitable for their particular waste or whether they can research and justify a different, less worse case entry and add that to their HazWasteOnline project.
In the case of iron(III) oxide, HazWasteOnlineTM has both a worst case (sourced mainly from the ECHA C&L database) and a less worse case based on a 2015 REACH compliant Safety Data Sheet from Sigma Aldrich. The former might be considered for iron(III) oxide particles produced in a factory (i.e. fine dust and hence hazard statements H318 Eye Damage and H372 STOT respiratory tract) reflecting the hazards fine particles pose to the eyes and respiratory system, the latter might be more suitable for a soil where the iron is not in the form of discrete particles but is amorphous and disseminated throughout the soil.
Assessing hazardous paint on articles such as steel windows or I beams
We have been asked a number of times over the last year or two about the classification of metal articles such as steel framed windows or I beams with potentially hazardous coatings of for example, paint containing lead. Many workers have taken a worse case approach, presuming that where the analysis of the surface paint finds hazardous levels of one or more substances in the paint, then the whole article has to be classified as hazardous.
Our opinion is that it is the window frame or beam (plus paint) that is being disposed of, not the paint alone, so the mass of the whole article has to be taken into account when determining whether the whole article should be classified as hazardous or non-hazardous.
Let’s look at the issue.
In the List of Waste, disposal of these metal articles falls under Chapter 17 Construction and Demolition Wastes, section 17 04 metals (including their alloys) and mirror entries 17 04 09* metal waste contaminated with hazardous substances and 17 04 05 iron and steel. In WM3, the mirror hazardous entry also comes with Note ‘q’ which says:
- The term ‘metal waste contaminated with’ indicates that the metal itself is not considered in the assessment while hazardous substances in paints, coatings or other contamination are considered. Metal elements in alloys in massive form are generally excluded from assessment by the List of Waste.
Referring back to the legislation, Decision (EU) No 2014/955, which updated the List of Waste has the statement says:
- The concentration limits defined in Annex III to Directive 2008/98/EC (i.e. the revised waste framework directive) do not apply to pure metal alloys in their massive form (not contaminated with hazardous substances) unless the alloy is a specific hazardous entry in the LoW enumerated with an asterisk (*)
Steel is an alloy of iron and carbon and has the non-enumerated entry 17 04 05 in the List of Waste.
Taking these statements together, they are saying that 1) you don’t need to test the steel (alloy) for hazardous substances (unless somehow the body of the steel has been contaminated) but 2) you do need to test the paint to determine whether it contains hazardous substances and whether these are at hazardous concentrations. Once this step has been completed and taking the worst case where the paint does contain hazardous levels of one or more substances, the classifier then has to determine whether the whole article is hazardous.
One way to do it is to measure the mass of an identical, paint-free beam (a baseline assessment) and repeat with the equivalent paint covered beam(s). Note that if you were to remove the hazardous paint from the steel (to get a paint-free beam for example), the removed paint would be a separate, hazardous waste stream and have to be disposed of accordingly.
Estimations for the mass of an unpainted I beam (density 7700 kg/m3, length 1m, flange width 0.1m, web height 0.2m, thickness 10mm) versus the same I beam with an extra 1mm thick covering of paint (density 3000 kg/m3 ) indicates an increase in mass of ~7% for the painted beam. This is effectively a “dilution” factor of >10x for any hazardous levels of lead or other hazardous substances in the paint (i.e. if you have 2500 mg/kg of lead in the paint, this would be equivalent to approximately 250 mg/kg for the whole painted beam).
A similar approach was published in the Chemical Industry Association’s guidance” The assessment and classification of waste packaging” published in July 2017 for assessing residues in packaging e.g. for a residue of dry paint left in a paint can.
It should be noted that the waste receiver will need to see the assessment and still be informed about the hazardous nature of the paint as it can impact their recovery process and the health and safety of workers.
We are still on track to release the new WAC interface in a few months time making it easier for you to see if your waste is suitable for disposal at an inert, stable non-reactive or hazardous landfill. We already process the WAC data present in a .hwol file but at this time, we don’t present it in HazWasteOnlineTM.
This new user interface will allow you to both review your WAC data but also assess it against the WAC criteria for the various classes of landfill. It will be country specific so for example, Irish customers will have the relevant Irish WAC while UK customers will have the relevant UK WAC (Yes they are different) including the 3x derogations for some waste streams at certain hazardous landfills.
Our longer term plan is to use the WAC data on the soluble metals for example, to help the classifier rule out certain metal species. For example, if WAC has copper that is <0.1 mg/kg, then your 2000 mg/kg of copper in your solid results is very unlikely to be the soluble copper sulphate.
DETS (south) joins the list of labs that can publish .hwol files
We are pleased to announce that DETS’ Rose Lane Laboratory in Kent is now able to deliver the .hwol data file format for the rapid and auditable input of chemistry data into a Job in HazWasteOnlineTM.
If your favourite lab is DETS or is on the list below and you want to start importing .hwol data files;
- simply ask the lab for the .hwol file along with your normal deliverables.
- send Support (email@example.com) a copy of the .hwol file and the PDF report
- Support will check the file and then call you to guide you through the importation of your first .hwol file.
The current list of labs that support the .hwol data file format is:
- ALS (Deeside)
- Chemtest (Newmarket)
- DETS (South)
- Exova Jones (Deeside)
Concept Life Sciences are almost ready to publish .hwol files; we are just working with them to sort out a technical issue that we encountered when testing some of their deliverables.
Envirolab, SOCOTEC and Chemtech are in the process of commissioning their new Lab Information Management System (which has to be done first) and/or working towards providing the .hwol format so expect to see them coming on board in 2019.
Sampling frequency for soils
We have been helping The Association of Geotechnical & Geoenvironmental Specialists (AGS) with some new, much needed guidance for the sampling and testing of soils. The guidance is called “Waste Classification for Soils – A Practitioners’ Guide” and was published on 13th February 2019. The aim of the guide is to provide a simplified process for the sampling and classification of waste soils on straight forward sites and is intended as supplementary guidance to the WM3 guidance published by the UK Environment Agencies.