Following five years of work to clarify which waste wood items are potentially hazardous, the Wood Recyclers’ Association (WRA) has welcomed plans by the Environment Agency to withdraw RPS 250 on September 1st.
Introduced in July 2021, Regulatory Position Statement (RPS) 250 currently allows potentially hazardous ‘amber’ waste wood items from the construction and demolition (C&D) waste stream to be moved and processed as non-hazardous.
However, from 1 September 2023, the Environment Agency has confirmed this will be withdrawn. This means that a small number of items from pre-2007 buildings will automatically be classified as hazardous and will not be able to be sent to wood recyclers.
Instead, they will require specialist hazardous waste disposal, unless they are sent for a simple test to demonstrate that they are not.
The move comes after the WRA successfully worked in partnership with UK regulators over five years to gather evidence to drastically narrow down the list of potentially hazardous C&D amber items to just ten, as part of its Waste Wood Classification Project.
These 10 items, all from pre-2007 buildings, are: Barge boards; external fascia; soffit boards; external joinery; external doors; roof timber; tiling cladding; tiling battens; timber frames and timber joists.
The WRA’s efforts in spearheading this work were applauded this month by the Environment Agency’s Howard Leberman at the WRA’s Spring meeting, where he also confirmed the withdrawal of the RPS.
Julia Turner, executive director of the WRA, said: “We are delighted that the work we’ve carried out has provided clarity that the majority of waste wood is non-hazardous.
“While we still have a number of items to test, end user testing of C&D material has indicated a hazardous content of less than 1% - representing a tiny proportion (0.08%) of UK total waste wood arisings, at around 4,000 tonnes.
“We believe the potentially hazardous items can be reduced further with more testing and could be easily accommodated by existing hazardous outlets. Therefore this will not impact on the industry’s role of providing recycling and recovery outlets and security for local authorities, waste management companies and biomass plants going forward.”
The withdrawal of the RPS from September will put the onus on the waste producer rather than wood reprocessors to identify, test and classify wood at source, in line with current legal requirements.
The WRA will continue to champion testing and has produced a Quick Guide to support this.
Meanwhile wood recyclers will no longer be able to take this material and have been told they will need to amend their acceptance criteria to add these items to their unacceptable items list and communicate the change to their customers.
By doing so they will avoid the substantial costs and potential stigma of becoming hazardous waste sites for the sake of a very small amount of material. This was a huge fear for the market and could have resulted in a number of companies being unable to continue trading.
It will also ensure that potentially hazardous material is not sent to biomass and panelboard markets which have always said they don’t want any type of hazardous feedstock.
Julia went on to say: “We welcome plans to withdraw RPS 250. Responsibility for finding and testing the small number of potentially hazardous items from in the demolition waste stream will now lie with the waste producer.
“We hope this will incentivise more widescale testing to enable even more items to be deemed non-hazardous in future.
“End users of waste wood – including panelboard and biomass – do not want material that is still classified as potentially hazardous and this will give clarity to both the waste wood supply chain and UK regulators.
“The WRA will continue to encourage sampling and testing of amber items and offer support and training.”
The withdrawal of RPS 250 applies to construction and demolition waste only.
Testing is currently ongoing on potentially hazardous waste wood from households and is expected to confirm that its hazardous content is diminishing and soon likely to disappear altogether.