- The Competency Initiative and your Training Records
- New Refresher Course
- What is coming soon :
- 1] WAC assessments and
- 2] review of the lab’s TPH test methods
- hwol file – List of labs that can generate the .hwol file and which are working on it
In this newsletter we provide more information about our drive for greater competency and raising the standards of classification across the waste classification industry. This initiative is driven in part by the regulator looking for evidence of competency but more fundamentally because we see still see:
- A lot of classifications that are below par, including;
- classifications based on single samples,
- classifications that have declared a waste hazardous when, with a little more work and thought and/or better testing, the waste could be shown to be non-hazardous.
- Actors stating that they are completing a WM3 assessment on your waste but in reality using simple rules of thumb such as;
- “all the metals are below 1000 mg/kg so your waste is non hazardous” or
- “the metal add up to less than 2500 mg/kg therefore your waste is not hazardous”
- “it’s failed Inert WAC therefore it’s hazardous”
[These are all wrong by the way]
- A waste producer asking their waste management company for a copy of the WM3 assessment that they have just undertaken; the company replies that the WM3 assessment is not available because “we have to charge extra for that.”
Competency & Training Records
We have had many stakeholders welcoming the announcement that we will be adding our Registered User’s training records to their PDF classification reports. As mentioned in previous newsletters, the classification reports will document when a classifier has completed the two day training course (i.e. both the basic and the advanced waste classification courses) within the last 3 years. For those that have completed the advanced course but more than three years ago, they can refresh by repeating the advanced course, or shortly, attend the new, one day Refresher Course that we are putting together (see outline below).
Since we first announced this initiative in February, a number of companies have commissioned our in-house training course to train large numbers of staff – some of the reasons being;
- economies of scale,
- staff’s CPD, and
- that if one of our projects is ever audited by HMRC or the EA, we can show that we have had formal training in both the use of HazWasteOnline and in waste classification.
We will go live with training records on the PDF classification reports from the 1st January 2020. Please know that we only have three more public courses in 2019, two in the UK and one in Ireland, so if you want to be up to date, please book soon as places are filling up.
From Monday 19th August 2019, Registered Users will be able to check their training record [and their colleague’s] by logging into HazWasteOnline, clicking on the Administration tab and selecting Training Record. Please note that this is a Beta version as we are still cross-checking with our older, paper-based training records, which go back to 2010. There will be missing entries for cases where your email address has changed since the training was undertaken; for example because you got married or you changed companies. If you do find any discrepancies or you think the record is missing, please email us at firstname.lastname@example.org with the details so that we can review and update before the 1st January.
For those classifiers who have completed the Advanced Waste Classification course, but it was more than 3 years ago, they can repeat the advanced course, or shortly, attend the new Refresher Course that we are working on.
The Refresher Course (when finished) will comprise two parts:
1] An on-line, multiple choice type assessment to go over the common shortcomings that we see. This would be completed at home, in the days before attending the Refresher Course. We expect that this would take about 30 minutes to complete.
2] A one day course which will be mostly workshop based, looking at real data sets and working through them. The one day course will likely have the following components:
- Brief overview of legislative changes and new guidance (eg packaging, soil sampling) introduced over the previous three years
- Review of the results of the on-line assessment, examples of common mistakes
- Mini workshops where we look at real examples of data from a number of different waste streams
- Review of new functionality added to HazWasteOnline such as processing WAC data, PAH double ratio plots, averaging replicate sample data
- Workshop – multipart exercise where delegates are given the details of a waste stream and have to work out whether it’s hazardous or not – includes desktop study, selection of EWC code, defining test suite, assessing sampling, import and processing replicate lab data using the .hwol file, identification of metal species, identifying the types of the hydrocarbons, data processing
If you are interested in attending the Refresher Course, please let us know and we can look at where and when.
1] WAC – In September, we will be adding the ability to import (via the .hwol file), assess and report WAC data. Effectively, if you have for example, a Job with ten samples of a soil, all classified as 17 05 04 non-hazardous, then the software will look at the Inert WAC and determine whether the soil also passes the inert WAC. On the other hand, if one or more of the ten samples is 17 05 03* hazardous, it will look at the hazardous WAC instead and report accordingly.
This will be a Beta version to allow feedback and will be available in the higher, Professional & Packages Edition of HazWasteOnline.
Three time derogations for certain waste streams and user defined limits will be added in phase 2 of this work.
2] TPH – As part of the .hwol data delivery file initiative with the labs (see list below), we are reviewing and cataloguing all the standard TPH tests that each lab offers to its customers. This project also includes sending each lab a sample of a waste that we are very familiar with and undertaking a selection of hydrocarbon tests to understand what the lab is doing and the different terms that they are using in their quotes, schedule, PDF report and the .hwol file.
Background: The labs offer a number of tests for “petroleum” hydrocarbons, using terms like TPH-CWG, EPH, Total TPH, TPH1, PRO, GRO, mineral oil etc. Unfortunately, one lab’s TPH/EPH/mineral oil test is often not the same as another lab’s and the selection of the wrong test can also lead to outcomes that may not be optimised for waste classification. The main issue for classifiers is that the different tests (of the same stuff) will give different (higher) concentrations of hydrocarbons, thus more likely to lead to a hazardous outcome (And this is not claiming in any way that a particular lab’s TPH test / methodology is wrong but is much more about the classifier’s understanding of which hydrocarbons are actually included in a particular lab’s test.
For example, take the tests for mineral oil. For some labs, this is a “cleaned up” , fractionated result that just gives you the concentration of the aliphatic hydrocarbons only. For another lab, mineral oil is not cleaned-up and instead measures all the solvent extracted hydrocarbons that may be present, including organic compounds such as the aliphatics, aromatics, humic acids and fatty acids etc. The mineral oil concentration measured in the former would be (could be significantly) a lower concentration than the latter.
Neither of these examples, by the way, follows EN 14039, stated in Decision 2003/33 EC (legislation which defines the WAC thresholds and standards for chemical testing for WAC). This standard describes a “cleaned-up” TPH, assessing just the aliphatic and aromatic hydrocarbons in the hydrocarbon range C10-C40.
(We cover all this in the Advanced course).
Labs that can publish .howl files
The current list of labs that support the .hwol data file format is:
- ALS (Deeside)
- Chemtest (Newmarket)
- DETS (South)
- Element (Exova Jones) (Deeside)
- i2 Analytical
If your wish to start importing .hwol data files from one of these labs;
- 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.
Status of labs working on the production of the .hwol file
- Envirolab (Cheshire) – we are reviewing their draft .hwol files so expect them to go live in September
- DETS North (Co, Durham) – almost ready to send us their first draft of the ,hwol file for review
- Chemtech (Co Durham) – trialling their new LIMS – look at production of the .hwol file in Q4
- SOCOTEC (Bretby) – Their new LIMS is live – plan to have ,hwol file ready in Q4
- ELAB (Sussex) – New – August 2019 – sent copy of the .hwol specification
- Concept Life Sciences (Manchester) – on hold while they restructure their business
- ELS (Cork) – not going forwards at this time