As a follow-up to an earlier post (Classifying Waste Wood), the Environment Agency for England has re-issued their Regulatory Position Statement (RPS 207) with an extension of the time expiry until 30 September 2019.
The RPS applies to businesses who:
- produce waste wood
- transport waste wood
- keep waste wood
- process waste wood
- control waste wood – if you are a dealer or broker
- use waste wood
- dispose of waste wood
It allows treated or mixed waste wood (including chipped waste wood and wood fines), which could be classified as hazardous or non-hazardous and has not been assessed and classified in line with the Technical Guidance WM3: Waste Classification – Guidance on the classification and assessment of waste, to continue to be classified as non-hazardous.
Under this RPS, the term “treated waste wood” is any waste wood, processed wood or wood fuel that contains, in any quantity, wood that’s been preserved, varnished, coated, painted or exposed to chemicals.
As with all Environment Agency RPS, if you follow its conditions, you do not need to apply for a hazardous waste classification for treated or mixed waste wood. However, if you cannot comply with its conditions then you must apply for a hazardous waste classification for treated or mixed waste wood. See the Environment Agency’s guidance on how to Classify different types of waste.
RPS 207 Conditions
The waste wood must be destined for:
- an Industrial Emissions Directive (IED) Chapter IV compliant permitted incinerator or co-incinerator
- the manufacture of board
This includes the waste wood you are storing or pre-treating for these purposes.
If you are going to use treated or mixed waste wood for any other purpose, you must do both of the following:
- assess and classify it in line with the Technical Guidance WM3: Waste Classification – Guidance on the classification and assessment of waste before it is moved from the premises where it is produced or held
- demonstrate that any processed waste derived from it (including chipped wood, wood fuel and wood fines) is derived solely from waste wood inputs that have been assessed and classified in line with the Technical Guidance WM3: Waste Classification – Guidance on the classification and assessment of waste
You must not assign a waste classification to the outputs from wood processing, or move it or send it anywhere unless you have done both of the above activities
Waste Transfer Note
The Waste Transfer Note must include your description of the waste wood as “unassessed waste wood, including treated wood, for IED Chapter IV compliant incineration or co-incineration or board manufacture only”.
As this RPS does not apply to waste wood that is known and is classified as hazardous, such as:
- railway sleepers
- telegraph poles
- wood treated with creosote
Any waste movement of the above hazardous waste wood (or unsegregated wood containing the above hazardous wastes) must be moved as “hazardous waste” using a consignment note.
Time Expiry of RPS
RPS 207 is time-limited and is proposed to be withdrawn on 1 October 2019 to allow the waste wood industry time to:
- deliver a code of practice which meets the legal requirements to assess and classify waste wood as approved by the Environment Agency
- implement compliance with that code of practice
After 1 October 2019, all unassessed waste wood must be classified as hazardous including any waste wood that has entered the waste management system and/or has been stockpiled under this RPS.
A copy of the Environment Agency’s Regulatory Position Statement 207 is freely available here