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Study to assess the impacts of different classification approaches for hazard property "H 14" on selected waste streams Interim report

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Study to assess the impacts of different classification approaches for hazard property "H 14" on selected waste streamsInterim report

February 2015

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Document information

CLIENT European Commission – DG ENV

REPORT TITLE Interim report

PROJECT NAME Study to assess the impacts of different classification approaches for hazard property "H 14" on selected waste streams

DATE 16 February 2015

PROJECT TEAM BIO by Deloitte (BIO), INERIS

AUTHORS Ms Arianna De Toni (BIO)Ms Mariane Planchon (BIO)Ms Nada Saïdi (BIO)Mr Pascal Pandard (INERIS)Mr Shailendra Mudgal (BIO)

KEY CONTACTS Shailendra Mudgal+33(0)1 55 61 63 [email protected]

Or

Mariane Planchon+33 1 55 61 67 56mplanchon @bio.deloitte.fr

DISCLAIMER The project team does not accept any liability for any direct or indirect damage resulting from the use of this report or its content. This report contains the results of research by the authors and is not to be perceived as the opinion of the European Commission.

Please cite this publication as:

BIO by Deloitte (2015). Study to assess the impacts of different classification approaches for hazard property "H 14" on selected waste streams – Interim report prepared for the European Commission (DG ENV), in collaboration with INERIS.

2 Study to assess the impacts of different classification approaches for hazard property "H 14" on selected waste streams – Interim report

BIO by Deloitte is a commercial brand of the legal entity BIO Intelligence Service. Since 26 June 2013 the legal entity BIO Intelligence Service is a 100% owned subsidiary of Société Fiduciaire Internationale d’Audit which is owned by Deloitte.

All the employees referred to in this proposal therefore remain available for the execution of the project, via the legal entity BIO Intelligence Service or Deloitte.

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Table of contents1. INTRODUCTION_________________________________________________________7

1.1. Background_____________________________________________________________7

1.2. Objectives______________________________________________________________10

2. PROJECT PROGRESS____________________________________________________11

3. METHODOLOGY________________________________________________________13

3.1. Collecting data on how a sample of Member States perform the assessment of HP 14__________________________________________________________________133.1.1. Selection of countries and data collection by survey________________________133.1.2. Data collection by desk study__________________________________________153.1.3. Reporting data in factsheets___________________________________________15

3.2. Selecting mirror pairs for the assessment___________________________________173.2.1. Selection process___________________________________________________173.2.2. Selection criteria____________________________________________________18

3.2.2.1. SC1: Preference of experts_______________________________________________183.2.2.2. SC2: Availability and quality of data_______________________________________183.2.2.3. SC3: Tonnage of waste production________________________________________203.2.2.4. SC4: Economic importance______________________________________________223.2.2.5. SC5: Potential presence of hazardous substances_____________________________223.2.2.6. SC6: Criticality of waste classification______________________________________23

3.2.3. Global score and selection of mirror pairs________________________________23

3.3. Collecting experimental data on selected waste codes_________________________24

4. RESULTS: STRATEGIES OF SELECTED MEMBER STATES TO ASSESS HP 14___________26

4.1. Member States survey____________________________________________________26

4.2. Full country factsheets___________________________________________________27

4.3. Description of the approaches_____________________________________________274.3.1. General information_________________________________________________274.3.2. Approaches using chemical analysis____________________________________304.3.3. Approaches based on biotests_________________________________________334.3.4. Combined approaches_______________________________________________36

4.4. Costs associated with implementing HP 14 approaches________________________38

4.5. Advantages and limits of the approaches____________________________________384.5.1. Approaches based on chemical analysis_________________________________384.5.2. Approaches based on biotests_________________________________________394.5.3. Combined approaches_______________________________________________39

5. RESULTS: SELECTION OF WASTE CODES FOR THE ASSESSMENT____________________42

5.1. Scores obtained for the selection criteria____________________________________425.1.1. SC1: Preference of experts___________________________________________425.1.2. SC2: Availability and quality of data_____________________________________42

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5.1.3. SC3: Quantity of produced waste_______________________________________435.1.4. SC4: Economic importance___________________________________________455.1.5. SC5: Potential presence of hazardous substances_________________________455.1.6. SC6: Criticality of waste classification___________________________________48

5.2. Selected waste codes____________________________________________________48

6. NEXT STEPS__________________________________________________________50

6.1. Reporting experimental data for the calculations_____________________________50

6.2. Application of the four calculation methods__________________________________516.2.1. Calculating average concentrations_____________________________________516.2.2. Running HP 14 assessment methods and considering the final waste

classification_______________________________________________________51

6.3. Comparative assessment of the different methodologies_______________________52

6.4. Consultation of the stakeholders and organising a stakeholders' workshop_______53

7. ANNEXES 54

Annex 1. First Questionnaire sent to Competent Authorities______________________55

Annex 2. Factsheets________________________________________________________59

Annex 3. Second questionnaire sent to Competent Authorities___________________103

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List of TablesTable 1: Waste production of the EU-28 Member States in 2012, extracted from Eurostat (Generation of waste [env_wasgen], WASTE: Total Waste, HAZARD: Total, Last update: 26/11/2014, Extracted on: 14/01/2015).............................................................................................13Table 2: Example of publications in the waste classification topic of selected Member States (non-exhaustive)...............................................................................................................................14Table 3: Template for the country factsheets....................................................................................16Table 4: Attribution of weights according to biases in data on quantity............................................21Table 5: Score per Member State and weighted average score for SC3 - waste code 06 03 16.....22Table 6: Experts contacted and their contribution (in grey: Member States who did not contribute).........................................................................................................................................26Table 7: National legislation or guidelines for the H14 assessment methods and protocols............27Table 8: Generic concentration limits for individual ecotoxic substances, according to their classification......................................................................................................................................31Table 9: Concentration thresholds for ecotoxic substances, according to their classification...........31Table 10: Conditions rendering the waste hazardous by HP 14 during Step 4, per Member State adapting the DPD for HP 14 assessment................................................................................32Table 11: Standards for preparing waste samples............................................................................33Table 12: Batteries of tests used in Member States using biotests to assess HP 14.......................34Table 13: Tests on Daphnia magna, as used in Member States relying on biotests for the assessment of HP 14........................................................................................................................36Table 14: Comparison between Italy and Germany regarding conditions rendering the waste hazardous by HP 14 during Step 4 of the chemical analyses method..............................................37Table 15: Batteries of tests used in Germany and Italy....................................................................37Table 16: Most produced waste types in the studied Member States...............................................43Table 17: Preliminary selected mirror pairs.......................................................................................48Table 13: Experts contacted and their contribution (in green: Member States who have already contributed, as of February 16th).......................................................................................................50Table 14: Example of table gathering the results of hazard classification for HP 14 for all the waste streams and all the calculation methods.................................................................................52

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List of FiguresFigure 1: Workplan............................................................................................................................12Figure 2: Waste quantities in Germany and attribution of scores.....................................................20Figure 3: Approaches for the assessment of HP 14 in the nine studied Member States..................29Figure 4: Decision tree for the assessment of HP 14 using chemical analyses (based on the DPD)................................................................................................................................................. 30Figure 5: Ranges of costs in Member States for which the information is available.........................38Figure 6: Extract from the Excel sheet which reports results for SC1...............................................42Figure 7: Extract from the Excel sheet which reports results for SC2...............................................43Figure 8: Extract from the Excel sheet which reports results for SC3 (the percentage of waste is indicated as compared to total waste produced in the Member State)..........................................44Figure 9: Extract from the Excel sheet which reports results for SC4...............................................45Figure 10: Extract from the Excel sheet which reports EC50 and NOEC values of potentially ecotoxic substances..........................................................................................................................46Figure 11: EC50 and NOEC of some of the most hazardous pesticides authorised in the EU.........47Figure 12: Extract from the Excel sheet which reports results for SC5.............................................47Figure 13: Extract from the Excel sheet which reports results for SC6.............................................48Figure 14: Calculation/assessment methods for the classification of waste.....................................52

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1. Introduction1.1. BackgroundIn the EU, classification of waste is based on two regulatory texts: Decision 2000/532/EC1 establishing the List of Waste (LoW) and Annex III to Directive 2008/98/EC2 on waste (Waste Framework Directive, or WFD), which defines the properties that render waste hazardous. The LoW is meant to be a reference nomenclature providing a common terminology throughout the European Union, with the purpose to improve the efficiency of waste management activities. Assignment of waste codes has a major impact on the transport of waste, installation permits (which are usually granted for the processing of specific waste codes) or decisions about recyclability of the waste. The LoW thus serves as a common encoding of waste characteristics in a broad variety of purposes, including classification of hazardous wastes.

According to Article 2 of Decision 2000/532/EC, wastes classified as hazardous are those considered to display one or more of the 15 properties (H1 to H15) listed in Annex III to the WFD3. Among them, H 14 describes the ecotoxicological potential or environmental hazards, as an intrinsic property of waste, by indicating whether the waste presents or may present immediate or delayed risks for one or more sectors of the environment.

The LoW comprises 839 waste codes in 20 waste chapters including 405 wastes marked as hazardous (absolute entries) and about 200 wastes in so-called “mirror entries”. Mirror entries consist of pairs of entries of which one waste may be classified as hazardous or non-hazardous according to the type and concentration of the pollutants it contains. The unique basis for differentiating between hazardous and non-hazardous wastes in mirror entries is Annex III to the WFD (i.e. the list of 15 hazardous properties). Wastes classified as hazardous are marked with an asterisk “*” in the LoW. The majority of mirror entries refer to the term “hazardous” or “dangerous” substances with no further description, while some describe hazardous properties or possible triggered exposure threshold or the specific hazardous waste component.

The legislation framework for classifying waste in the EU is closely linked to chemical legislation, namely Directive 67/548/EEC4 (the Dangerous Substance Directive, or DSD) and Directive 1999/45/EC5 (the Dangerous Preparations Directive, or DPD). Attribution of any of the hazardous properties listed in Annex III of the WFD (H1 to H15) must be done in accordance with the criteria laid down by Annex VI to the DSD regarding the terms ‘toxic’ (and ‘very toxic’), ‘harmful’, ‘corrosive’, ‘irritant’, ‘carcinogenic’, ‘toxic to reproduction’, ‘mutagenic’ and ‘eco-toxic’, used for the definition of the DSD R-phrases. If relevant, the limit values listed in Annex II and III to the DPD shall apply. However, the DSD and the DPD are being progressively repealed by Regulation

1 2000/532/EC: Commission Decision of 3 May 2000 replacing Decision 94/3/EC establishing a list of wastes pursuant to Article 1(a) of Council Directive 75/442/EEC on waste and Council Decision 94/904/EC establishing a list of hazardous waste pursuant to Article 1(4) of Council Directive 91/689/EEC on hazardous waste (notified under document number C(2000) 1147), http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32000D0532&from=EN 2 Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste, http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32008L0098&from=EN 3As regards H3 to H8, H10 and H11 of Annex III, one or more of a set of additional characteristics must be displayed in order for the waste to be considered hazardous.4 Council Directive 67/548/EEC of 27 June 1967 on the approximation of laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances, http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:31967L0548&from=en5 Directive 1999/45/EC of the European Parliament and of the Council of 31 May 1999 concerning the approximation of the laws, regulations and administrative provisions of the Member States relating to the classification, packaging and labelling of dangerous preparations, http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:31999L0045&from=en

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1272/20086 on classification, labelling and packaging of substances and mixtures (CLP) and Regulation 1907/20067 on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). In particular, R-phrases will not exist under the CLP Regulation anymore and are replaced by the naming of a hazard class and a signal word.

According to Annex III of the WFD, test methods for assessing the H1 to H15 properties must be done following Annex V to the DSD and in other relevant CEN-notes. However, the REACH Regulation refers to Test Method Regulation (EC) 440/2008, which has taken over all test methods from the Annex V to the DSD. In practice, assessing some of the hazardous properties listed in Annex III is not straightforward. This is particularly true for H 14: although Part C of Annex V to the DSD and Part C of Regulation (EC) No 440/2008 lay down the test methods for the determination of ecotoxicity, no guidelines or recommendations exist for a specific methodology for the assessment of H 14.

As a result, assessment of H 14 is performed in different ways throughout Member States. When the composition of the waste is known, the attribution of the “ecotoxic” property is usually made on the basis of the criteria of the CLP using the summation method, thanks to which the classification of a mixture can be derived from the classification of its components. However, it is difficult to implement this approach for complex mixtures of mainly unknown composition, which is a common situation for wastes: the analytical determination of the composition of waste could be both expensive and technically difficult. In this case, the performance of bio-tests on the mixture itself is generally considered as a relevant approach because it allows integrating the effects of all contaminants including additive, synergistic and antagonistic toxic effects. In addition, reference data (i.e. EC50, LC50, M-factors) are only available for a limited number of chemicals, which can significantly impede using the summation method described in the CLP regulation8. Some Member States evaluate eco-toxicity by biotest or physicochemical analysis, although there is no standardized battery of biotests for waste at EU level. Other Member States use formulae or criteria adapted from other assessment methods, for instance described in their national regulations, in order to determine H 14 properties of waste. The lack of harmonisation of methods for assessing hazardous properties in Member States, including H 14, is one aspect calling for a revision of the legislation relevant to those hazardous properties. In particular, it seems necessary to provide, in the legislation, a specific methodology for assessing the ecotoxicity of waste, in accordance with the methods recommended in the CLP and REACH regulations.

Reflecting scientific and technical progress and ensuring coherence with chemical legislation is the main driver for the launch, in 2008, of the review of the LoW and of the WFD9. Indeed, a Member State stakeholders’ consultation performed by the EU Committee for the Adaptation to Scientific and Technical Progress and Implementation (TAC), identified the following issues:

Problems resulting from the structure of the LoW and the classification procedure;

Problems concerning the classification of hazardous waste and the application of mirror entries;

Problems resulting from the lack of suitable waste codes;

6 Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification, labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006, http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32008R1272&from=en 7 Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC, http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32006R1907&from=en 8J. Römbke, R. Ketelhut& J. Wuttke (2013) Scientific Position Paper: For the European Commission Ecotoxicological Classification of Wastes (Criterion HP 14)9 http://ec.europa.eu/environment/waste/framework/pdf/Technical_proposal.pdf

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Ambiguous classification on account of two or more possible codes;

Problems resulting from unclear or imprecise definitions.

The Commission constituted a dedicated Working Group in order to address these issues, “the Working Group for the amendment of the European waste list”. Work conducted by the WG relates to the review of the hazardous properties listed in Annex III to the WSD (including H 14) and the definition to be included in Article 2 of Decision 2000/532/EC. During their meeting of June 201110, the Working Group agreed that the H-Criteria shall be renamed HP1 to 15 in order to avoid confusions with the H-statements of the CLP Regulation. Therefore, “H 14” will be named “HP 14” from this line on.

Although the governing principle of the review is alignment with CLP, strict alignment, including concentration limits, may not in all cases be appropriate for wastes and lead to changes regarding the amount of wastes being classified as hazardous. This issue concerns HPs 4, 6, 8 13 and 14 and caused disagreements within the Working Group.

In November 2011, it was proposed that specific concentration limits/M-factors according to CLP Annex VI should not be used for waste classification11, but rather that generic concentration limits be provided directly in Article 2 of the LoW. However, in the specific case of HP 14, France was not in favour of deleting the M-factors from the CLP summation method and proposed keeping the M-factors but deleting the categories chronic cat 3 and 4 in the summation.

As no agreement was reached, two options for the assessment of HP 14 were proposed in the Technical Proposal on the review of the Hazardous Properties12. Option 1 is based on aquatic toxicity and does not include M-factors, while Option 2 relies on M-factors. The proposal was submitted for consultation and triggered reactions from the industry, notably regarding the issue of the change of classification of some types of waste.

Scientific and technical work is ongoing to refine and analyse the options for assessing HP 14 under a revised legislation. In 2013, four options were designed on the basis of the work conducted by the Working Group for the amendment of the European waste list. These options take into account proposals from the Commission, France and Austria and aim at fulfilling four criteria for the assessment of HP 14:

Smooth transition to CLP possible;

User-friendly;

Changes compared to status quo; and

Sufficient environmental protection level.

Based on these options, the Commission designed four calculation methods for further evaluation of the impact of a revision of the assessment of HP 14, with regards to the technical feasibility of such a revision, as well as its economic, social and environmental impacts. The potential use of biotests in combination with those methods is also an issue to be addressed for the assessment of HP 14.

1.2. ObjectivesThe objective of this study is to assist the Commission to assess the impacts of changing the criteria for the definition of eco-toxicity for waste, and especially to assess the implications for Member States and industry of the implementation of four different options of calculation methods for HP 14 assessment and waste classification. The following aspects will be studied:

10 Working Group For The Amendment Of The European Waste List, Summary Record Of The Meeting Held On 15 -16 June 201111 Working Group For The Amendment Of The European Waste List, Summary Record Of The Meeting Held On 28 -29 November 201112 http://ec.europa.eu/environment/waste/framework/pdf/Technical_proposal_tc.pdf

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The ability to apply the methodology as a function of the nature and amount of analytical information available;

The degree of correlation with biotest results;

The workability of the methodology;

The cost of implementation of the methodology;

The impact of the classification method chosen for H 14 with respect to the other methods and with respect to the current baseline;

The nature and estimation of costs of possible waste management options for high volume waste streams for which a significant change in the fraction of waste classified as hazardous is to be expected based on the application of the different methods.

The identification of the potential limits of the proposed methodologies is another objective of this study.

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2. Project progressTo date, progress has been made with regard to Tasks 1 and 2 (see Figure 1). The methodology and results of the work under each task are presented in the next chapters of the report.

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Figure 1: Workplan

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Progress

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3. MethodologyThe impact assessment of changing the criteria for the definition of ecotoxicity for waste involves the following tasks:

Task 1: Data collection on how 8 Member States perform the assessment of HP 14 in practice;

Task 2: Identification and data-collection relative to waste codes to be selected for the assessment;

Task 3: Determining the classification of waste types according to the different methodologies proposed;

Task 4: Comparative assessment of the technical, economical and practical impacts of the different methodologies;

Task 5: A stakeholder consultation and a workshop.

The next sections detail the methodology used to perform these tasks. This interim report covers Task 1 & 2.

3.1. Collecting data on how a sample of Member States perform the assessment of HP 14

The current strategies implemented in different Member States to assess HP 14, including relevant legislation and details about the approaches, were reported in country factsheets thanks to a survey of Member States and a desk study.

3.1.1. Selection of countries and data collection by surveyTen Member States were contacted with the aim to gather data on their strategies to assess HP 14:

Austria

France

Belgium

Germany

Italy

Finland

Czech Republic

United Kingdom

Spain

Poland

The relevance of this sample is based on the volume of waste generated and managed in those countries, which belong to the biggest producers of waste in EU-28 (see Table 1); and also based on the involvement of national authorities, researchers or industrial stakeholders from those countries in the topic of hazardous waste classification or ecotoxicological characterisation of waste. The publication of articles and reports regarding ecotoxicity of waste was used as an indicator of the involvement of Member States (for examples, see Table 2).

Table 1: Waste production of the EU-28 Member States in 2012, extracted from Eurostat (Generation of waste [env_wasgen], WASTE: Total Waste, HAZARD: Total, Last update:

26/11/2014, Extracted on: 14/01/2015)

Member State Waste produced (t) in 2012 Member State Waste produced (t)

in 2012Germany 368 022 172 Czech Republic 23 171 358France 344 731 922 Estonia 21 992 343United Kingdom 241 372 727 Ireland 19 807 586Romania 219 309 676 Hungary 16 370 208

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Member State Waste produced (t) in 2012 Member State Waste produced (t)

in 2012Poland 163 377 949 Denmark 16 332 249Italy 162 764 633 Portugal 14 184 456Bulgaria 161 252 166 Slovakia 8 425 384Sweden 156 366 579 Luxembourg 8 397 228Netherlands 123 612 767 Lithuania 5 583 082Spain 118 561 669 Slovenia 4 546 505Finland 91 824 193 Croatia 3 378 638Greece 72 328 280 Latvia 2 309 581Belgium 66 932 665 Cyprus 2 086 469Austria 34 047 465 Malta 1 496 464

Table 2: Example of publications in the waste classification topic of selected Member States (non-exhaustive)

Member State Example of publication

UK University of Birmingham (2014) Health and Safety Guidance Hazardous Waste: Guidance on Assessment GUIDANCE/11/HWGA/14

Hazardous waste Interpretation of the definition and classification of hazardous waste (3rd Edition 2013)

Finland Kati Vaajasaari (2005) Leaching and Biotests as Methods for Classification and Assessment of Environmental Hazard of Solid Wastes. Tempere University of Technology

France Pascal Pandard and Jörg Römbke (2013) Proposal for a “Harmonized” Strategy for the Assessment of the HP 14 Property; Integrated Environmental Assessment and Management — Volume 9, Number 4—pp. 665–672

Pandard P et al. (2006) Selecting a Battery of Biotests for Ecotoxicological Characterization of Wastes. Science of the Total Environment 363:114-125.

Germany J. Römbke et al. (2009) Ecotoxicological characterisation of 12 incineration ashes using 6 laboratory tests; Waste Management 29 2475–2482

H. Moser et al. (2011) Evaluation of biological methods for a future methodological implementation of the Hazard criterion H14 ‘ecotoxic’ in the European waste list (2000/532/EC); Waste Management & Research, 29(2) 180–187

H. Moser and J. Römbke (2009) Ecotoxicological Characterization of Waste- Results and Experiences of an International Ring Test.

UbA (2013) Recommendations for the Ecotoxicological Characterization of Wastes

Austria Participation in the Working Group for the amendment of the European Waste List

Czech Republic Vasahlova et al. (2012) The proposal for changes in evaluation of ecotoxicity of wastes in the Czech legislation

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Member State Example of publication

Italy Participation in the Working Group for the amendment of the European Waste List

Belgium Participation in the Working Group for the amendment of the European Waste List

The contact points in the relevant Competent Authorities of the ten selected Member States were provided by the Commission. They were sent a cover letter from the Commission and a questionnaire aiming at gathering the approaches used in their country to assess the ecotoxicity of representative samples of waste streams. The questionnaire asked the stakeholders to describe the HP 14 approaches implemented in their country, provide some case studies (i.e. examples of application of their method on 1-2 waste streams) and indicate the relevant national legislation about waste hazard classification and HP 14 ecotoxicology assessment. The experts were also asked to provide their preference(s) concerning the waste codes to focus the impact assessment on, in order to help in the selection of waste codes for in-depth data collection (see section 3.1.2 and 3.3). The full questionnaire is reported in Annex 1.

A second questionnaire was sent to Member States in order to address data gaps identified during the selection of mirror pairs for further assessment (the selection process and criteria are detailed in section 3.2). This questionnaire, available in Annex 3, also included a section on the collection of experimental data for the next steps of the study (see section 3.3 and 6.1).

3.1.2. Data collection by desk study In parallel, the project team conducted a desk-based search and merged the results of this search with the results of the consultation. The aim of the desk-based search was to gather data on the approaches used in the 10 Member States to assess the ecotoxicity of representative samples of waste streams.

In order to find data about tonnages of hazardous waste, research on websites of Competent Authorities was performed. As such tonnages were often split into categories/codes of waste that were based on the Eurostat EWC-Stat classification system, research has been carried out to convert quantities registered under EWC-Stat categories to LoW categories. Such estimation was used if the consultation does not provide data on hazardous waste tonnage.

Research has also been carried out using keywords in the different national languages to seek document about the approaches used to assess HP 14, and examples of results of such assessments. Literature previously identified was used as primary source of information but also was a starting point to identify new documents relevant for our study (through the listed references). Competent Authorities and national agencies websites have been consulted to find the official documentation on methodology for waste classification (guidelines, pieces of legislation, etc.). Scientific databases – such as Web of Knowledge, PubMed, Science Direct – have been explored using keywords rings to gather scientific articles dealing with biotests on waste.

3.1.3. Reporting data in factsheetsThe data collected on HP 14 assessment by Member States survey and by a desk study was reported in country factsheets. The template for those factsheets is presented below (Table 3).

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Table 3: Template for the country factsheets

NAME OF COUNTRY

National approach to assess H14 (ecotoxicity) of wastes

Type of approach(es) used in the country to assess H14 property of waste

Calculation method with limit value Calculation method without limit value –BiotestsCombined approachOther (choose one or more, please specify)

Name of the method(s)

Variability in H14 assessment methods depending on the waste nature

Specify if some categories of waste are assessed with different approaches

Related legislation and guidelines

Legislation Name of national regulations, decree, etc.

Guidelines Name of national guidance (if available)

Stakeholders involved in the H14 assessment

Name of the institution(s) + type of the institution+ role (funding/performing assessment, etc.)

Waste with highest tonnage

Waste with highest tonnage Name or code of waste + tonnage + share (%)

Hazardous waste with highest tonnage

Name or code of waste + tonnage+ share (%)

Chapter of List of waste with the highest share of hazardous waste

Name or code of waste + tonnage+ share (%)

Percentage of waste considered as hazardous by H14

Share of waste assessed as positive for H14 (% of waste classified as ecotoxic - globally and by category)

Protocol used If biotests are applied (complete if relevant)

Prioritization of tests (aquatic vs terrestrial)

What kind of tests are used in your country

Terrestrial tests

Test organism

Endpoint Test method

Test duration

Expression of results

Threshold value

Leaching/extraction test used

Aquatic tests

Test organism

Endpoint Test method

Test duration

Expression of results

Threshold value

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If calculation methods are used (complete if relevant)

Concentration limits, thresholds, as well as relevant equations

Illustrative examples

Results of the method on X types of waste, to show the diversity of approaches (if relevant)

Qualitative assessment of the method(s)

Advantages

Limits and uncertainties

Approximate cost of the method(s) Variability depending on waste types (%)

Other MS using the same approach (if known)

Additional comments

Expert contacted to elaborate this factsheet

Name of experts (if agree)

References Name of documents used to elaborate the factsheet

Additional information

Links to websites to have additional information, stakeholders websites, etc.

The full factsheets containing all information collected for each countries are reported in section 4.2.

3.2. Selecting mirror pairs for the assessmentThe assessment of HP 14 according to the four classification methods chosen by the Commission is to be performed on a restricted list of mirror pairs. The next sections explain how those pairs were selected.

3.2.1. Selection processThe selection of mirror pairs is based on an extended list provided by the Commission and containing 133 waste codes. Among them, 124 mirror pairs have been identified and the selection process is performed on these 124 waste codes.

The selection process is based on six selection criteria (SC):

SC 1 - Preference of experts

SC 2 - Availability and quality of data

SC 3 - Tonnage of waste production

SC 4 - Economic importance

SC 5 - Potential presence of hazardous substances

SC 6 - Criticality of waste classification

For each SC, waste codes were assigned a qualitative or quantitative value (depending on the criterion). For instance, under SC1, waste codes were assigned the number of experts which expressed their preference. Under SC2, waste codes were assigned sources and various information regarding calculations and biotests. Furthermore, values

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for each SC were translated into scores from 0 to 3, according to different scoring systems depending on the criterion. Details on the methodology for each criterion are presented in section 3.2.2.

A global score is then calculated for each waste code by computing a weighted average of all scores. The weight of each criterion in the global score, as well as the strategy adopted to select codes with the global scores is presented in section 3.2.3.

Data reporting and computing was performed in an Excel file which is attached to this report as a separate document.

3.2.2. Selection criteriaThe rationale for the evaluation of some selection criteria is based on results from the data collection on the strategies of Member States to assess HP 14.

3.2.2.1. SC1: Preference of expertsExperts from ten Member States were asked which waste codes they thought the study should focus on. Each waste code was attributed the number of experts who chose it.

The scoring system is as follows:

Number of experts Score

0 0

1 2 1

3 5 2

≥ 6 3

Results are presented in the Excel sheet named “SC1”.

3.2.2.2. SC2: Availability and quality of dataA desk study was performed in order to evaluate the availability and quality of data related to waste streams classified under the extended list of waste codes:

Exact composition of waste;

Results of biotests;

Protocols.

Generic keywords were used (“ecotoxic + waste + assessment”, “H14 + waste + assessment”, “H14 + waste + classification”) in Google and Google Scholar. The resulting publications and pieces of grey literature were classified according to the waste codes they studied. Publications and reports provided by the Competent Authorities were also included in the sample. A more in-depth study was then performed by using keywords specific to the subchapters of the LoW:

Subchapter Keywords

03 01 (03 01 05)

04 02, 06 05, 07 01, 07 02, 07 03, 07 05, 07 06, 08 01, 10 03, 10 08, 11 01, 12 01, 19 08

06 03

Sawdust + ecotoxic + waste

Sludge + ecotoxic + waste

Metallic oxides + ecotoxic + waste

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Subchapter Keywords

08 03

08 04

10 01

10 02

10 03

10 05

10 06, 10 08

10 08, 10 10, 10 11

10 09, 10 10

10 11, 10 12, 10 13

16 11

17 01

17 03

17 05

17 06

17 08

19 01

19 07

19 10

19 13

Ink + ecotoxic + waste

Adhesive + ecotoxic + waste

Bottom ash + ecotoxic + wasteFly ash + ecotoxic + wasteGas cleaning + ecotoxic + waste

Filter cakes + ecotoxic + wastecooling water treatment + ecotoxic + waste

Flue gas dust + ecotoxic + wasteSlag + ecotoxic + waste

Dross + ecotoxic + waste

cooling water treatment + ecotoxic + waste

Flue gas dust + ecotoxic + waste

Moulds + ecotoxic + waste

Gas treatment + ecotoxic + waste

Lining + ecotoxic + wasteRefractories + ecotoxic + waste

Concrete + ecotoxic + waste

Bituminous + ecotoxic + waste

Soil + ecotoxic + wasteSpoil + ecotoxic + waste

Insulation + ecotoxic + waste

Gypsum + ecotoxic + waste

Bottom ash + ecotoxic + wasteFly ash + ecotoxic + wasteBoiler dust + ecotoxic + waste

Landfill leachate + ecotoxic + waste

Dust + ecotoxic + waste

Soil + ecotoxic + waste

The collected documents were attributed one or more waste codes depending on the waste samples analysed. A few pieces of information (for instance, the name of the samples of interest, or the fact that the protocols were performed according to ISO standards) were also reported in the Excel file.

Although the desk study was not a formal systematic search, it should be representative of the amount of literature (scientific and grey) publically available on the waste codes of the list.

The scoring system is as follows:

Number of publications Score

0 0

1 1

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Number of publications Score

2 3 2

≥ 4 3

The detailed references of the sources are reported in the Excel sheet named “Source index” and the data on availability and quality is reported in the Excel sheet named “SC2”.

3.2.2.3. SC3: Tonnage of waste productionThe quantities of waste produced per Member States and per waste code were retrieved in official documents.

For Member States for which data was available (Germany, UK, Spain, Finland, Belgium), a score was attributed to each waste code according to the logarithmic distribution of the tonnages throughout the set of waste codes (Figure 2). Waste codes for which no stream was produced in the Member State of interest (0 tons) were attributed a score of zero. Those for which no data was available (Czech Republic and Austria) were not given any score (noted “n/a”). This scoring system is illustrated below for Germany:

Figure 2: Waste quantities in Germany and attribution of scores

1,0E+00

1,0E+01

1,0E+02

1,0E+03

1,0E+04

1,0E+05

1,0E+06

1,0E+07

1,0E+08

1,0E+09

Qua

ntity

of w

aste

(ton

s)

Waste codes ranked from the highest to the lowest tonnage

Score: 3

Score: 2

Score: 1

For some Member States (Italy and Poland), quantities were reported under other classifications than the LoW: an extrapolation was therefore necessary:

Country

Type of raw data Method of extrapolation

Italy Total quantities of waste generated (with a distinction between hazardous and non-hazardous waste) per general categories of the LoW (01, 02, 03, etc.)

Disaggregation of the quantity registered under a category into the different category codes:

- For hazardous waste codes: division of the value for total hazardous waste of this category with the number of hazardous

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Country

Type of raw data Method of extrapolation

waste codes in this category- For non-hazardous waste codes: division

of the value for total non-hazardous waste of this category with the number of non-hazardous waste codes in this category

Poland Total quantities of hazardous and non-hazardous waste generated; and share of categories of the LoW within the tonnages of the hazardous and non-hazardous waste

Disaggregation of the total quantity of waste into the different category codes for waste:

- For hazardous waste codes : Multiplication of the total quantity of hazardous waste by the share of each LoW category; and division by the number of hazardous waste code in this category

- For non-hazardous waste codes: Multiplication of the total quantity of non-hazardous waste by the share of each LoW category; and division by the number of non-hazardous waste code in this category

For each waste code, a weighted average of the scores per Member State was calculated, giving the score for SC3. The weights were attributed in the aim to take into account the uncertainties and bias regarding the quantities of waste reported in the Member States. Selection bias was not penalised because the average is computed per waste code, therefore if the quality of the data for one waste code is good, the quality of the selection cannot degrade its score.

Table 4: Attribution of weights according to biases in data on quantity

Bias Weight

Data from selected companies 1 if the selection is representative

0.5 if not

Data from a specific region of the Member State

1

Data for some codes only 1

Data extrapolated from quantities reported under another classification than the LoW

0.5

Old data (< 2009) 0.5

If more than one bias was identified for a Member States, the weights were multiplied.

An example is provided below for waste code 06 03 16. Italy has a bias of extrapolation and data from Poland dates from 2005 and is extrapolated.

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Table 5: Score per Member State and weighted average score for SC3 - waste code 06 03 16

Country FR DE UK ES IT PL FI BE ATScore for SC3

Weight 1 1 1 1 0.5 0.25 1 1 1

Score n/a 2 n/a n/a 2 3 n/a 2 n/a 2,07

Results are presented in the Excel sheet named “SC3”.

3.2.2.4. SC4: Economic importanceThe economic importance was evaluated by the volumes of transboundary shipments and by the inputs of the Competent Authorities13.

The scoring system is as follows:

Data Score

Identified as one of the most exportedORIdentified by Italy AND Finland

3

Identified by Italy or Finland only 2

Belongs to one of the main categories of waste which are shipped

1

No data available n/a

Results are presented in the Excel sheet named “SC4”.

3.2.2.5. SC5: Potential presence of hazardous substancesThe identification of hazardous substances potentially contaminating waste, was done thanks to a desk-based search and to the Competent Authorities’ experience with hazardous waste.

Scores were attributed with regards to the level of hazard linked to the identified substances. The level of hazard was evaluated thanks to EC50 and NOEC values, which were retrieved through the INERIS portal of hazardous substances (http://www.ineris.fr/substances/fr/homepage/search), or the USEPA ECOTOX portal (http://cfpub.epa.gov/ecotox/quick_query.htm)14 if the substance is not in the INERIS inventory. When more than one value of EC50 or NOEC was available, the lowest one was chosen.

For some waste codes, the potential presence of pesticides was reported, without naming specific active ingredients. Therefore, a desk-based search was conducted to determine the level of hazard of the most dangerous pesticides for the environment (worst-case approach):

Step 1: Selection of pesticides having at least two "1" in Group 3 "Environmental toxicity" (except bees15) of the PAN International List of Highly Hazardous Pesticides - June 2014 (http://www.panna.org/sites/default/files/PAN_HHP_List_2014.pdf)

13 In practice, only Italy and Finland provided inputs on this matter.14 The USEPA portal was used if the INERIS portal did not provide the requested information.15 Bees are not an exposed species when pesticides are in waste

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Step 2: Selecting only pesticides authorised in the EU (http://ec.europa.eu/sanco_pesticides/public/?event=activesubstance.selection&language=EN)

Step 3: Reporting EC50 and NOEC values, for selected pesticides for which such information is available. The values are presented in sheet “Hazard of various substances”, tables under the name “pesticides”.

The sheet “Hazard of various substances” of the Excel file also reports available EC50 and NOEC values for metals, inorganics (except metals), pesticides and organics (except pesticides).

The scoring system is as follows:

Order of magnitude of EC50 and NOEC of substances Score

10-4 / 10-3 (e.g. metals, pesticides) 3

10-2 / 10-1 (e.g. tars) 2

1 or more 1

No data available n/a

Results are presented in the Excel sheet named “SC5”.

3.2.2.6. SC6: Criticality of waste classificationThis was evaluated according to a VITO study16 which identified a few waste codes for which waste streams classified under one code of a mirror entry are likely to shift to being classified under the other code. The inputs from Member States were also considered.

The scoring system is as follows:

Change of classification Score

No 0

Maybe 1.5

Yes 3

No data available n/a

When more than one source is available for a waste code, the priority is set this way:

“yes” wins over the other possible impacts;

“maybe” wins over “no”.

Results are presented in the Excel sheet named “SC6”.

3.2.3. Global score and selection of mirror pairsThe global score is calculated for each waste code by computing a weighted average of all scores obtained for SC1 to SC6. The weights are the following:

Selection criteria Weight

SC1 316 Impact of the new List of Waste on the Flemish waste policy

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SC2 3

SC3 2

SC4 1

SC5 1

SC6 2

For each waste code:

Global score=∑iscore (SCi ) .weight (SCi)

∑iweight (SCi)

for all i such asscore (SCi)≠n/a

Since a weighted average pulls all indicator values toward the mean, the glob al score is rescaled to extend through the full range of values (0–3):

For each waste code:

Normalised global score=3.(Global score (waste code )−min (Global score)max (Global score )−min (Global score) )

All waste codes with a normalised global score higher than 1.5 are selected. If the mirror entry of a selected code is not included in the list, the mirror pair is nonetheless chosen.

3.2.4. Taking into account the Commission and Member States’ inputs

The Commission and Member States’ experience with the LoW lead to their suggesting additional codes to the selection performed with the process detailed in the previous sections. It was taken into account as described below:

Member States’ contribution

Some Member States (Austria, Belgium and the UK) shared a list of waste streams relevant, in their experience, for assessing ecotoxicity. A list of mirror pairs was attributed to the proposed waste streams, except for those which referred to absolute entries. Then, only mirror pairs appearing in the original extended list of the Commission were kept. Of those, the pairs chosen with the selection process described in section 3.2.1 were removed.

The resulting list was further trimmed:

Only pairs from the most mentioned streams were kept (gas cleaning, sludge, C&D waste); and then

Only pairs in which both entries have a score above 1 made the final cut.

European Commission’s contribution

Pairs proposed by the Commission were included.

3.3. Collecting experimental data on selected waste codesThe team collected the data necessary to perform the calculations required to apply the four different methodologies for waste classification, along with all ecotoxicology test results about the previously selected mirror pairs. The data collection was done by a new

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consultation in the sample of Member States (see the questionnaire in Annex 3), and by analysing the publications found during the desk study (see section 3.1.2).

The scope of the data collection is to obtain information on:

Current hazard classification of each waste mirror pairs (to establish the baseline against which to determine impacts);

Exact composition of the waste:

o Nature of each component;

o Hazard statement codes according to CLP of each component (ex: H420, H400, H410, H411, H412, H413, etc.);

o Exact concentration and M factor of each component that are classified H420 or H400, H410, H411, H412, H413;

Results of ecotoxicity tests:

o Test strategy (number of tests, prioritisation, etc.);

o Way of expressing results (ECx, LID, etc.);

o Threshold values for classifying wastes as hazardous;

Protocols of sampling, preparation of samples, analyses and test:

o For composition:

Specify whether chemical analysis was performed on solid material or on leachates;

Sampling time;

Sample preservation ;

Transport and storage of samples (including time of conservation);

Pre-treatment of samples ;

Preparation of waste eluates (including pH adjustment if performed);

Storage of waste eluates ;

Leachant;

Analytical methods.

o For ecotoxicity tests:

Sampling time;

Sample preservation ;

Transport and storage of samples (including Time of conservation);

Pre-treatment of samples ;

Preparation of waste eluates (including pH adjustment if performed);

Storage of waste eluates ;

Organism [e.g. Daphnia magnamagna]

Time of conservation before performing test :

Preparation of waste eluates (including pH adjustment if appropriate)

Storage of waste eluates (including time and conditions)

Test method

Control/dilution medium

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The Member States were sent a blank Excel database for them to fill in with the requested data (separate document to this report).

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4. Results: strategies of selected Member States to assess HP 14

4.1. Member States surveyTen Member States were sent a questionnaire via email (see Annex 1), in the aim to document the approaches used in their country to assess the ecotoxicity of waste streams. The list of contacts and their contribution is reported in Table 6 below.

Table 6: Experts contacted and their contribution (in grey: Member States who did not contribute)

Member State Experts contacted Expert(s) who contributed

Austria Franz Mochty, Lebensministerium

Sonja Loew, Lebensministerium

Sonja Loew

Belgium Inge van Engeland, Leefmilieu

Evi Rossi, OVAM

Didier Gohy, SPW

Evi Rossi

Czech Republic Alena Marasova, MZP

Gabriela Bulkova, MZP

Jan Marsak, MZP

Jaromir Manhart, MZP

Jaromir Manhart

Finland Eevaleena Häkkinen, Ympäristöministeriö Eevaleena Häkkinen

Germany Joachim Wuttke, UBA

Martin Kaimer, UM Baden-Württemberg

Walter Adebahr, UM Baden-Württemberg

Susanne Hempen, BMUB

Joachim Wuttke

Walter Adebahr

Spain Fabrellas Begona

José Delgado Alfaro

Margarita Ruiz Sáiz-Aja

Margarita Ruiz Sáiz-Aja (and colleagues)

UK Chris Hall

Robert McIntyre

Robert McIntyre

France Pauline Ardaine Langeron

Christine Cros

Pauline Ardaine Langeron

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Member State Experts contacted Expert(s) who contributed

Poland Krystyna Panek-Gondek

Magdalena PERLIŃSKA

Andrzej Jagusiewicz

Roman Jaworski

None

Italy Daniela Conti

Andrea Paina

Stefania Balzamo

Maria Belli

Loredana Musmeci

Daniela Conti

Andrea Paina

Stefania Balzamo

As a result, factsheets were drafted for the following countries:

Austria

France

Belgium

Germany

Italy

Finland

Czech Republic

United Kingdom

Spain

The next sections detail and analyse the information reported in those factsheets.

4.2. Full country factsheetsThe factsheets are available in Annex 2.

4.3. Description of the approaches

4.3.1. General information The nine Member States have either national legislation, guidelines or both, describing methods to assess HP 14 in their jurisdictions (Table 7). Italy and Austria passed laws introducing the criteria assigning HP 14 to waste but did not issue guidelines17. In Spain, the Ordinance determining the methods for assessing HP 14 is accompanied by appendices providing guidance. In the other countries (France, Germany, Finland, UK and Belgium), where no legislative instrument exist, guidelines are however available.

Table 7: National legislation or guidelines for the H14 assessment methods and protocols

Member State Legal instrument Guidelines

Austria Fed. Law Gaz No. 522/1973 as amended by Fed Law Gaz III No. 36/2001

Belgium OVAM (2004) Europese afvalstoffenlijst EURAL Handleiding

Czech Republic Decree No 376/2001 Coll. on evaluation of hazardous properties of waste

Instructions for waste ecotoxicity evaluation (Bulletin of Ministry of Environment (No.4, 2007)

17 In Italy, although there are no official guidelines or specific protocols, studies detailing the assessment of HP 14 were published (see the “References” section of the Italian factsheet)

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Member State Legal instrument Guidelines

Finland Dahlbo, H. 2002. Jätteen luokittelu ongelmajätteeksi – arvioinnin perusteet ja menetelmät (Classification of waste as hazardous waste – the basis and methods for evaluation). Environment Guide 98. Finnish Environment Institute. Helsinki. Finland. 160 pp. (In Finnish)

Ympäristöministeriö, Tilastokeskus, Suomen ympäristökeskus. Jäteluokitusopas 2005 (Waset Classification Guide 2005). Tilastokeskus, Käsikirjoja 37. Helsinki 2005. (In Finnish)

France FNADE (2003) Methodological Guide - Waste Classification for a good direction of waste to appropriate storage centres – Appendix 3

INERIS (2013) Guide de classement des déchets selon leur dangerosité suivant le Code de l’Environnement et la réglementation SEVESO II (partie applicable aux déchets). Rapport d’étude N°INERIS- DRC-12-125740-06310A, 66 pp.

Germany German AVV (Abfallverzeichnisverordnung) (technical guide)

Guidelines on the Application of the Waste Catalogue Ordinance

Italy - Legislative decree 152/2006 (part IV). It replaces the legislative decree 22/97.

- Law 28/2012 .This law has introduced the criteria for H14 assessment into the legislative decree 152/2006 (see point 5, Annex D part IV)

Spain ORDEN de 13 de octubre de 1989 por la que se determinan los métodos de caracterización de los residuos tóxicos y peligrosos

ORDEN MAM/304/2002, de 8 de febrero - Anejo 2 (“no contiene en la actualidad disposiciones respecto a las características H1, H2, H9 y H12 a H14”)

ORDEN de 13 de octubre de 1989 por la que se determinan los métodos de caracterización de los residuos tóxicos y peligrosos –Appendice IV and A

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Member State Legal instrument Guidelines

UK Environment Agency (2013) WM2: Hazardous waste Interpretation of the definition and classification of hazardous waste (3rd Edition 2013), 147 pp.

University of Birmingham (2014) Health and Safety Guidance - Hazardous Waste: Guidance on Assessment GUIDANCE/11/HWGA/14, 32 pp

The assessment approaches adopted in the nine Member States can be qualified as:

Based on chemical analysis; or

Based on biotests; or

Based on chemical analysis and biotests (so-called combined approaches).

The following map (Figure 3) shows the types of approaches adopted by the nine Member States.

Figure 3: Approaches for the assessment of HP 14 in the nine studied Member States

Type of approach

Not included in the sample

Biotests

Chemical analysis

Combined

Austria, Belgium, Finland and the UK rely solely on chemical analysis to determine the ecotoxic property of waste. It is worth mentioning that Finland and the UK allow biotests in some cases, but discourage the use of such methods. Their position is discussed in section 4.4. In Czech Republic, France and Spain, the assessment of HP 14 is performed thanks to biotests only, while in Italy and Germany a tiered approach including chemical analysis is in place.

The following sections (4.3.2 and 4.3.3) describe and compare the approaches based on chemical analysis (whether used alone or in combination with biotests) and those based on biotests (whether used alone or in combination with chemical analysis), respectively. Section 4.3.3 focuses on the analysis of combined approaches.

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4.3.2. Approaches using chemical analysisBelgium, Finland, Germany, Italy and the UK base their approach on the DPD, but did not adapt it identically. In Austria, another strategy is used, based on classification according to the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR)18 and on the presence of ozone-depleting substances.

Approaches based on the DPD

The process for assessing HP 14 is common to all Member States adapting the DPD for this purpose and is described in the decision tree below (Figure 4). These Member States rely on the first versions of the DPD, which do not include M-factors.

Figure 4: Decision tree for the assessment of HP 14 using chemical analyses (based on the DPD)

Does the waste containecotoxic substances

assigned R50 to R53, R50-53, R51-53 or R52-53?

Does the waste contain ecotoxic substances at a

concentration at or above the generic

concentration limits?

Does the waste contain two or more ecotoxic substances

above the concentration thresholds?

Is the waste ecotoxicaccording to additivity rules

applied in the Member State?

Does the waste contain ecotoxic substances at a concentration at or above the substance specific

threshold limits?

Haz

ardo

us b

y H

P 1

4

Not

haz

ardo

us b

y H

P 1

4

No

Yes

No

Yes

No

No

Yes

Yes

No

No

Yes

In dashes and italics: a UK-specific step.Italics

In green: Concentrations and equations detailed below the diagram.

Step 1

Step 2

Step 4

Step 3

Step 2’

Wastes which do not contain substances classified as dangerous for the aquatic environment or for the ozone layer according to the DSD R-phrases are not hazardous by HP 14 (Step 1). The relevant R-phrases are the following:

R50: very toxic to aquatic organisms;

R50-53: very toxic to aquatic organisms and may cause long-term effects in the aquatic environment;

R51-53: toxic to aquatic organisms and may cause long-term effects in the aquatic environment;

18 http://www.unece.org/trans/danger/publi/adr/adr_e.html

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R52-53: harmful to aquatic organisms and may cause long-term effects in the aquatic environment;

R52: harmful to aquatic organisms;

R53: may cause long-term effects in the aquatic environment; and

R59: dangerous for the ozone layer.

Substances classified as either one of these R-phrases will be named “ecotoxic substances”. If the chemical analysis of the waste shows that ecotoxic substances are present, one must first determine whether the concentrations of the individual substances are above the generic concentration limits set by the DPD, as presented in Table 8 (Step 2).

Table 8: Generic concentration limits for individual ecotoxic substances, according to their classification

Classification of the substance (DSD)

Generic concentration limits (w/w %)

R50 25

R50-53 0.25

R51-53 2.5

R52-53 25

R52 25

R53 25

R59 0.1

If at least one ecotoxic substance is present in the waste at a concentration at or exceeding the relevant threshold limit, then the waste is hazardous by HP 14. Otherwise the assessment process must continue.

In the next step (Step 3), one must compare the concentrations of ecotoxic substances to concentration thresholds above which they must be taken into account for the assessment (Table 9).

Table 9: Concentration thresholds for ecotoxic substances, according to their classification

Classification of the substance (DSD)

Concentration, thresholds (w/w %)

R50 0.1

R50-53 0.1

R51-53 0.1

R52-53 1

R52 1

R53 1

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Classification of the substance (DSD)

Concentration, thresholds (w/w %)

R59 0.1

If no ecotoxic substances is present at a concentration at or above the relevant threshold, then the waste is non-hazardous by HP 14. Otherwise, additivity rules must be applied to the ecotoxic substances having concentrations above thresholds (Step 4). These rules differ depending on the Member States (Table 10).

Table 10: Conditions rendering the waste hazardous by HP 14 during Step 4, per Member State adapting the DPD for HP 14 assessment

Member State(s) Conditions

Finland, UK and Italy∑ (PR50-53

0.25+

PR51-53

2.5+

PR52-53

25 )≥ 1

Or

∑ ( PR50 + PR50-53 ) ≥ 25

Or

∑ PR52 ≥ 25

Or

∑ ( PR53 + PR50-53 +PR51-53+PR52-53) ≥ 25

Belgium ∑ ( PR 50-53) ≥ 2.5

Or

∑ ( PR51-53 ) ≥ 25

Or

∑ ( PR50 ) ≥ 25

Or

∑ ( PR59 ) ≥ 0.1

Germany19 ∑ ( PR50-53 ) ≥ 0.25

Or

∑ ( PR51-53 ) ≥ 2.5

Or

∑ ( PR52-53 ) ≥ 25

Or

∑ ( PR59 ) ≥ 0.1

19 As implemented in Baden-Württemberg. Other Länder may have different methods.

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Member State(s) Conditions

Where PRX is the total concentration of substances classified as RX, expressed in w/w %.

The British approach adds one step to the process (Step 2’), which considers specific concentration limits reported in Table 3.2 of the CLP regulation. In the UK, where an individual dangerous substance has been assigned a substance specific concentration limit for any ecotoxic R-phrase, which is lower than the generic limit (see Table 8), then the lowest substance specific threshold must be considered for attribution of HP 14.

The Austrian approach

In Austria, ecotoxic classification of waste is performed with reference to the ADR for aquatoxicity and on the content of some hydrocarbons and halons for ozone depletion. A waste is classified as hazardous by HP 14 if it contains:

Environmental hazardous substances due to Class 9, M6 and M7 of the ADR; or

CFCs, CFHCs, HCFCs, HFHCs, FHCs, or halons in amount of more than 2000 mg/kg dry matter.

The approach adopted in Austria does not rely on calculations.

4.3.3. Approaches based on biotests Czech Republic, France, Spain, Germany and Italy use biotests for the assessment of HP 14; Czech Republic, France and Spain rely exclusively on them for the assessment, while Germany and Italy use them in a combined approach with chemical analyses.

Approaches based on biotests involve assays on aquatic and soil organisms in order to evaluate ecotoxicity of waste. Preparing waste samples is a key step for the assessment of ecotoxicity, as test results can be highly variable depending on the protocol. All studied Member States follow standardised protocols (Table 11).

Table 11: Standards for preparing waste samples

Member State Standard Scope Description

Czech Republic

EN 14735 raw wastes or water extracts

Necessary steps to be performed before carrying out ecotoxicity tests on wastes: taking of the sample, transport, storage of wastes and to define preparation.

France EN 12457 - 2 water extracts

Leaching - Compliance test for leaching of granular waste materials and sludge. One stage batch test at a liquid to solid ratio of 10 l/kg for materials with particle size below 4 mm (without or with size reduction)

Germany EN 12457 – 2 water extracts

See France

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Member State Standard Scope Description

DIN 19528 water extracts

Leaching of solid materials - Percolation method for the joint examination of the leaching behaviour of inorganic and organic substances

Italy EN 14735 raw wastes or water extracts

See Czech Republic

Spain EN 12457 - 2 water extracts

See France

While Italy and the Czech Republic have adopted a standard encompassing raw waste and water extracts, the other Member States have opted for a specific standard on leaching solid materials.

Biotests performed to assess HP 14 aim at evaluating acute or chronic toxicity; furthermore, threshold values were established to determine which conditions made waste hazardous. The batteries of tests differ among Member States (Table 12).

Table 12: Batteries of tests used in Member States using biotests to assess HP 14

Aquatic tests Terrestrial tests

Member State Organism Standard Organism Standard

Czech Republic Daphnia magna

Sinapis alba

Desmodesmus subspicatus

Poecilia reticulata

ISO 6341

Czech guidelines

ISO 8692

ISO 7346-2

None

France (initial strategy)20

Daphnia magna (acute)

Vibrio fischeri

Pseudokirchneriella subcapitata

Ceriodaphnia dubia

Brachionus calyciflorus

ISO 6341

ISO 11348-3

NF EN ISO 8692

NF ISO 20665

NF ISO 20666

E. fetida (acute)

Lactuca sativa

ISO 11 268-1

ISO 11269-2

France (hybrid strategy combining initial strategy and German strategy)

Daphnia magna (acute)

Vibrio fischeri

Pseudokirchneriella subcapitata

ISO 6341

ISO 11348-3

NF EN ISO 8692

E. fetida (avoidance)

Avena sativa / Brassica rapa

Arthrobacter globiformis

ISO 17512-1

ISO 11269-2

ISO/DIS 18187

20 According to the FNADE guidance, which is not regulatory-sanctioned

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Aquatic tests Terrestrial tests

Member State Organism Standard Organism Standard

Spain Vibrio fischeri

Daphnia magna

ISO 11348

ISO 6341

None

Germany Daphnia magna (acute)

Daphnia magna (chronic)

Vibrio fischeri

Pseudokirchneriella subcapitata / Desmodesmus subspicatus

Lemna minor

ISO 6341

ISO 10706

ISO 11348-1/2/3

NF EN ISO 8692

ISO 20079

E. fetida

E. fetida (chronic)

Brassica rapa

Arthrobacter globiformis

Folsomia candida (chronic)

ISO 17512-1

ISO 12 268-1

ISO 11269-2

ISO/DIS 18187

ISO 11267

Italy Daphnia magna (acute)

Vibrio fischeri

Pseudokirchneriella subcapitata and Desmodesmus subspicatus

ISO 6341

ISO 11348

ISO 8692

France and Germany consider both aquatic and terrestrial organisms for assessing waste ecotoxicity. In those countries, a tiered approach is used, where aquatic tests are prioritised and terrestrial tests are performed only if aquatic tests are inconclusive. In Spain, Italy and the Czech Republic, only aquatic tests are performed. Nevertheless, in Italy and the Czech Republic, members of the scientific community recommend the use of terrestrial tests in the assessment of HP 1421.

Among all biotests summarised in Table 12, standardised test on Daphnia magna (acute) is the only test which is performed in all Member States. Nevertheless, others tests are used by more than two Members States such as: the inhibition of light emission of Vibrio fischeri and the algal growth inhibition test. Regarding Daphnia magna, threshold values differ among Member States (as shown in Table 13).

Table 13: Tests on Daphnia magna, as used in Member States relying on biotests for the assessment of HP 14

Standard Test duration Expression of results Threshold value

France ISO 6341 24h or 48h EC50 10% (v/v)

21 Italy: Balzamo S., Finocchiaro G., Frizza G., Conti D., Martone C., Cadoni F: Proposta di una batteria minima di biosaggi per valutazioni di ecotossicità ambientale mediante analisi statistica multivariata. Comunicazione orale prensentata an Convegno: “Ricerca e applicazione di metodologie ecotossicologiche in ambienti acquatici” (20-22 ottobre 2010)Czech republic : D. Sirotková, M. Kulovaná, S. Vosáhlová, J. Hofman, V. Kočí, M. Záleská, Novelization of czech approaches to ecotoxicity evaluation of hazardous wastes

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Standard Test duration Expression of results Threshold value

Spain 750 mg/L22

Germany

48h

10% (v/v)

Italy 10% (v/v)

Czech Republic

10mL/L22 (i.e. 1% v/v)(

Spain set values in mg/L and the Czech Republic in mL/L, while the other countries prefer % (v/v); furthermore, Italy chose a higher threshold than France and Germany for Daphnia magna.

The overall description of strategies using biotests, as well as the focus on the one test the studied countries have in common (Daphnia magna), clearly show the heterogeneity of approaches based on biotests.

4.3.4. Combined approachesIn Germany and Italy, assessment of HP 14 follows a tiered approach and is dependent upon the type of information available for the waste itself and for its components. If the composition of the waste sample can be sufficiently known through chemical analysis, then classification according to HP 14 is done following the method described in section 4.5.1 (see Figure 3 and Table 10). If the composition of the waste is unknown or complex, biotests are applied. The testing strategy includes a test battery with terrestrial and aquatic tests, as described in section 4.3.3 (see Table 12 and Table 13).

Germany and Italy adopted the same strategy for assessing HP 14 with chemical analysis, although the equations and limit values for a combination of ecotoxic components are different (Table 14).

Table 14: Comparison between Italy and Germany regarding conditions rendering the waste hazardous by HP 14 during Step 4 of the chemical analyses method

Italy Germany19

∑ (PR50-53

0.25+

PR51-53

2.5+

PR52-53

25 )≥ 1

Or

∑ ( PR50 +PR50-53 ) ≥ 25

Or

∑ PR52 ≥ 25

Or

∑ ( PR53 + PR50-53 +PR51-53+ PR52-53) ≥ 25

∑ ( PR50-53 ) ≥ 0.25

Or

∑ ( PR51-53 ) ≥ 2.5

Or

∑ ( PR52-53 ) ≥ 25

Or

∑ ( PR59 ) ≥ 0.1

22 Thresholds set in mg/L and mL/L are inseparable from the waste preparation protocols. They are associated to the L/S ratio of the leaching procedure and have only a meaning expressed in terms of the leachate itself

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Italy Germany19

Where PRX is the total concentration of substances classified as RX, expressed in w/w %.

Furthermore, the German battery of biotests is more comprehensive than the Italian one, with more organisms being tested before concluding on waste ecotoxicity (Table 15).

Table 15: Batteries of tests used in Germany and Italy

Aquatic tests Terrestrial tests

Member State Organism Standard Organism Standard

Germany Daphnia magna(acute)

Daphnia magna(chronic)

Vibrio fischeri

Pseudokirchneriella subcapitata and Desmodesmus subspicatus

Lemna minor

ISO 6341

ISO 10706

ISO 11348-1/2/3

NF EN ISO 8692

ISO 200795

E. fetida (acute)

E. fetida (chronic)

Brassica rapa

Arthrobacter globiformis

Folsomia candida

ISO 17512-1

ISO 12 268-1

ISO 11269-2

ISO 10187

ISO 11267

Italy Daphnia magna (acute)

Vibrio fischeri

Pseudokirchneriella subcapitata and Desmodesmus subspicatus

ISO 6341

ISO 11348

NF EN ISO 8692

Heterocypris incongruens

Folsomia candida

Cucumis sativium, Lepidium sativus, Sorgum saccaratum

Ostracodotoxkit F method

ISO 267

UNICHIM 1961

However, Italy’s tiered approach follows the strategy described in the ADR for the determination of ecotoxicity of waste.

4.4. Costs associated with implementing HP 14 approachesCosts associated with chemical analyses and biotests vary depending on the country and the amount of tests necessary to reach a conclusion regarding the hazardous nature of the waste. Thus, costs related to chemical analyses range from 100€ to 2,000€ per sample and costs related to biotests range from 400€ to 5,000€.

Strategies using only chemical analyses are globally less expensive than those using only biotests. Combined approaches do not seem to cost more than individual approaches, based on data from Italy (where chemical analyses cost from 100€ to 1,000€ and the biotests battery 800€). Ranges per country are shown in Figure 5.

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Figure 5: Ranges of costs in Member States for which the information is available

Range of costs (€) – Biotests

Not included in the sample, or no information

100 – 500

Range of costs (€) – Chemical analyses

500 – 1,000

1,000 – 3,000

3,000 – 5,000

100 – 500

500 – 1,000

1,000 – 3,000

3,000 – 5,000

France is the Member State in which assessing HP 14 is the most expensive if the whole test battery is performed, followed by Belgium (Flanders) where chemical analyses using AFNOR XP X30-489 are 1,900 € per sample. The Member States where assessing HP 14 is the least expensive are Austria and the UK. In Austria, no specific costs are associated with assessing HP 14 because tests are performed for transportation of waste anyway.

4.5. Advantages and limits of the approaches

4.5.1. Approaches based on chemical analysisApproaches based on chemical analyses are easy and satisfactory for well-defined waste samples. In particular, strategies based on the DPD are clear and align directly with chemical risk phrase classification systems. Non-inclusion of M-factors makes it possible to apply concentration thresholds of 0.1% and 1% and thus exclude minor concentrations of substances from the assessment: if M-factors are applied, thresholds would be of 0.1%/M or 1%/M and would be exceeded by a lot of substances, then raising concerns that it might be impossible to prove that a waste is not ecotoxic using this approach. The Austrian strategy, partly based on classification according to the ADR, is easier to apply than DPD-based approaches and costs less because the classification according to the ADR is required anyway if the waste is transported. Among Member States which base their approaches on chemical analysis only, the British strategy is the most complete. It extends concentration limits to specific values reported in the CLP regulation, thus including more recent legislation and providing a more finely tuned approach to waste classification with chemical analysis. An additional advantage of approaches based on chemical analysis is their lower cost compared to approaches based on biotests.

Limited information and uncertainties regarding the composition of waste is the main limit of approaches based on chemical analysis. Methodologies provided in the DPD and the CLP are meant for mixtures with known composition and their applicability for the assessment of waste, which includes the assessment of mixtures with unknown composition, has not been evaluated. In particular, the heterogeneity of waste samples, with high content of anions, alkaline earth metals and silica, can make determination of composition difficult. Furthermore, suitable methods to identify organic substances in waste are lacking and approaches based on chemical analysis often underestimate the

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share of potentially ecotoxic organic components. Additionally, the application of worst-case scenarios when the composition of waste is not sufficiently known leads to an overestimation of the waste hazard. Thus, assessments using chemical analyses may not reflect the actual ecotoxicity of waste.

4.5.2. Approaches based on biotestsBiotests mirror well the effects of all bioavailable contaminants, including their potential interactions (additive, synergistic and antagonistic), as well as pollutants in complex matrices, which cannot be determined by chemical analysis. Furthermore, aquatic ecotoxicity tests are sensitive to many water soluble substances, thus being relevant to the assessment of wastes and addressing the main limit of ecotoxicity assessment with chemical analysis.

The lack of legally-fixed and harmonised threshold values is the main drawback and barrier to assessing HP 14 using biotests. There is a need to collect sufficient experimental data to conclude definitely on the suitability of proposed threshold values. Furthermore, threshold values set in mg/L or mL/L can lead to confusion in the interpretation, as it can be unclear whether concentrations are expressed in terms of the amount of residue of departure or in terms of the leachate (an order of magnitude difference between the two interpretations [x 10]). Finland, which allows biotests as a means for assessing HP 14 if information on the chemical composition of the waste is insufficient, highlights that they are not applied in practice because no threshold values has been set. In the UK, the scope for assessing waste with biotests is also very limited, for another reason: UK holds the view that animal testing of solid wastes is of little or no scientific value and raises ethical concerns. Those concerns are also stressed by Italy as a limit to biotests. Nevertheless, it should be highlighted that test species are not in the scope of the directive 2010/63/EU on the protection of animals used for scientific purposes, with the exception of fish (Poecilia reticulata used in Czech Republic).

Another limit exist when the battery of biotests only includes aquatic tests (Spain and the Czech Republic): toxicity on soil ecosystems is not evaluated when assessing HP 14. One last limit is the high cost of the most complete test batteries: for instance, costs are of 3,000 – 5,000€ in France. However, it should be stressed that these costs could be significantly reduced by performing limit tests at the threshold concentration.

4.5.3. Combined approachesCombined approaches address some limits of the two individual approaches (chemical analysis and biotests) and have then a good complementarity. When determining the composition of the waste is possible, conclusions on ecotoxicity can be drawn from chemical analysis, so that testing on biological organisms is not necessary. If the waste sample is too complex for its composition to be well-defined, the use of biotests can nevertheless allow the assessment of ecotoxicity. Furthermore, combined approaches have recently been investigated by researchers as a promising alternative to the status quo regarding the assessment of HP 14 in the EU23.

However, some disadvantages remain. There are no harmonised threshold or limit values and no harmonised test batteries, as shown in Table 14 and Table 15 in section 4.3.4. Furthermore, it has been noticed in the UK that the results of the two approaches (chemical analysis and biotests) are often different and lead to different classification of the waste.

23 Pascal Pandard and Jörg Römbke (2013) Proposal for a “Harmonized” Strategy for the Assessment of the HP 14 Property, Integrated Environmental Assessment and Management — Volume 9, Number 4—pp. 665–672

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5. Results: selection of waste codes for the assessment

5.1. Scores obtained for the selection criteria

5.1.1. SC1: Preference of expertsExperts mainly supported the selection of construction and demolition waste, in particular soil, stones and dredging spoils as well as bituminous mixtures, coal tar and tarred products. Wastes from incineration and pyrolysis of waste were also favoured.

Figure 6: Extract from the Excel sheet which reports results for SC1

Waste code Waste descriptionNumber of experts who expressed their preference

Member State(s) Score

17 05 03* soil and stones containing hazardous substances 6 AT, UK, IT, DE, ES, BE 3

17 05 04 soil and stones other than those mentioned in 17 05 03 6 AT, UK, IT, DE, ES, BE 3

17 01 06* mixtures of, or separate fractions of concrete, bricks, tiles and ceramics containing hazardous substances 5 AT, FI, UK, DE, BE 2

17 01 07 mixtures of concrete, bricks, tiles and ceramics other than those mentioned in 17 01 06 5 AT, FI, UK, DE, BE 2

17 05 05* dredging spoil containing hazardous substances 4 AT, UK, DE, BE 2

17 05 06 dredging spoil other than those mentioned in 17 05 05 4 AT, UK, DE, BE 2

19 01 11* bottom ash and slag containing hazardous substances 4 FI, UK, IT, BE 2

19 01 12 bottom ash and slag other than those mentioned in 19 01 11 4 FI, UK, IT, BE 2

19 01 13* fly ash containing hazardous substances 4 FI, UK, IT, BE 2

19 01 14 fly ash other than those mentioned in 19 01 13 4 FI, UK, IT, BE 2

The full results can be found in sheet “SC1” of the separate Excel file.

5.1.2. SC2: Availability and quality of dataThe types of waste for which the most data on ecotoxicity is available are soil from demolition waste and ashes from incineration of waste. Furthermore, collected literature was mainly related to biotests and few occurrences of work on chemical analysis was found.

Figure 7 below shows an example of how information is reported.

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Figure 7: Extract from the Excel sheet which reports results for SC2

Waste code Waste description

Waste code Waste description Data Source Quality Data Source Quality

[10]AVAILABLE IN [10] [10]

water extract = according to CEN standardstest = according to ISO and AFNOR standards

[3] [2]

High quality: repeatability and reproducibility assessed under ISO standard5725

‐1

AVAILABLE IN [2] [2]

all procedures according to ISO standards

[12]

ISO and ASTM procedure when possible; otherwise protocols tested in previous publications

AVAILABLE IN [12] [12]

leaching protocol established in the Spanish legislation (MOPU, 1989).

Results of ecotoxicological testsProtocols of sampling, preparation of

samples, analyses and test

EC50(Eisenia fetida)EC50(lactuca)

EC50(vibrio fisheri)EC50(daphnia)

EC50(ceriodaphnia)EC50(peudokirchneriella)

EC50(Brassica)EC50(enchytraeus)EC50(arthrobacter)EC50(lemna minor)

EC50(pseudomonas putida)EC50(salmonella)EC50(brachionus)

03 01 04*

03 01 05

sawdust, shavings, cuttings, wood, particle board and veneer containing hazardous substances

sawdust, shavings, cuttings, wood, particle board and veneer other than those mentioned in 03 01 04

The full results can be found in sheet “SC2” of the separate Excel file.

5.1.3. SC3: Quantity of produced wasteData was collected for Germany, UK, Italy, Austria, the Belgian region Flanders, the Spanish region Catalonia and Finland. It was not possible to attribute French waste quantities to waste codes, because available data was reported according to a classification which did not allow for an extrapolation of data, as could be done in Italy and Poland. Moreover, thanks to a desk study, Polish tonnages of waste were collected and used in assessing SC3 even if Poland was not initially chosen in the Member States sample.

The highest tonnages were reached for construction and demolition waste, specifically soil and stones as well as concrete and bricks (Table 16). For some Member States, there are biases in the determination of the highest tonnages, for instance when data could only be collected for a specific region or only for some types of waste.

Table 16: Most produced waste types in the studied Member States

Member State Reporting year Highest tonnage Potential bias

Germany 2011 17 05 04

106,015,300 t

-

UK 2012 17 05 03*

284,915 t

-

Spain (Catalonia)

2013 17 01 07

47,806 t

Data for industrial waste only

Data for a region and not the whole Member State

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Member State Reporting year Highest tonnage Potential bias

Italy 2013 17 01 07

2,346,782 t

Extrapolation based on data not reported by waste code

Poland 2005 03 01 05

1,215,150 t

Extrapolation based on data not reported by waste code

Not recent data

Finland 2012 06 05 03

153,959 t

Only data for operations that are licensed by state authorities. Hence data is not available by waste code on wastes that are produced by facilities that are authorized and supervised by municipalities.

Belgium (Flanders)

2012 17 05 04

960,826 t

Data per waste code of selected companies: every two years, OVAM selects about 8000 companies (statistically relevant selection per economic sector and dimension) who are obliged to report the amount and type of waste produced.

Data for a region and not the whole Member State

Austria 2009 17 05 04

23,500,000 t

-

The biases highlighted in Table 16 were taken into account when scoring, as shown in Table 4.

Figure 8 below shows an example of how information is reported in the Excel file:

Figure 8: Extract from the Excel sheet which reports results for SC3 (the percentage of waste is indicated as compared to total waste produced in the Member State)

Waste code Waste descriptionQuantity (t) or

qualitative indicationPercentage of

wasteSource Score

04 02 19* sludges from on-site effluent treatment containing hazardous substances

04 02 20 sludges from on-site effluent treatment other than those mentioned in 04 02 19

104,80 0,000584007[34) 2

06 03 15* metallic oxides containing heavy metals

06 03 16 metallic oxides other than those mentioned in 06 03 15

06 05 02* sludges from on-site effluent treatment containing hazardous substances

990,59 0,005520145[34) 2

06 05 03 sludges from on-site effluent treatment other than those mentioned in 06 05 02 153958,60

0,85794706[34) 3

07 01 11* sludges from on-site effluent treatment containing hazardous substances 20,64

0,000115018[34) 1

07 01 12 sludges from on-site effluent treatment other than those mentioned in 07 01 11 158,30

0,00088214[34) 2

Tonnage in Finland

The full results can be found in sheet “SC3” of the separate Excel file.

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5.1.4. SC4: Economic importanceWaste types identified as the most economically important with the methodology presented in section 3.2.2.4 are soil and stones from construction or demolition activities, as well as solid waste resulting from the iron and steel industry, and fly ashes from incineration or pyrolysis of waste.

Figure 9 below shows an example of how information is reported in the Excel file:

Figure 9: Extract from the Excel sheet which reports results for SC4

Waste code Waste description Info Source Score

19 01 11* bottom ash and slag containing hazardous substances

Economically important in IT Q-IT 1

19 01 12 bottom ash and slag other than those mentioned in 19 01 11

Economically important in IT Q-IT 1

10 02 07* solid wastes from gas treatment containing hazardous substances

Second most exported hazardous waste in the EU (282 098 tonnes) [9] p.19 3

17 05 03* soil and stones containing hazardous substances

First most exported hazardous waste in the EU (686 640 tonnes)Economically important in IT

[9] p.19Q-IT 3

19 01 13* fly ash containing hazardous substances

Fifth most exported hazardous waste in the EU (207 736 tonnes)Economically important in IT

[9] p.19Q-IT 3

03 01 04* sawdust, shavings, cuttings, wood, particle board and veneer containing hazardous substances n/a

The full results can be found in sheet “SC4” of the separate Excel file.

5.1.5. SC5: Potential presence of hazardous substancesAppendix B of the UK EA report “Hazardous Waste: Interpretation of the definition and classification of hazardous waste” (2nd edition v2.1)24 and Finnish inputs gave insight into the dangerous substances that may be associated with a particular hazardous waste entry. The Austrian Competent Authority provided, per hazardous waste code, a list of possible pollutants which could trigger the criterion HP 14. The Austrian inputs allowed to have a more detailed knowledge of potential pollutants.

The EC50 and NOEC values of these individual hazardous substances (or categories), retrieved through the US EPA or INERIS portals, are reported in the sheet “Hazard of various substances”.

24 UK Environment Agency (2006) Appendix B of Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1)

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Figure 10: Extract from the Excel sheet which reports EC50 and NOEC values of potentially ecotoxic substances25

MetalsElement EC50min (mg/L) SourceHg 0,0007 INERISCd 0,0034 INERISCu 0,011 INERISAs 0,011 INERISPb 0,026 INERISCr(VI) 0,03 INERISZn 0,032 INERISNi 0,06 INERISTi 0,01 INERISU 0,04 INERISBe 0,1 INERISSb 1,77 INERISBa 14,5 INERISMo 29 INERISPbO2 0,01 INERIS

For the waste codes for which the potential presence of pesticides was reported, as the specific active ingredients were not specified, the level of hazard of the most dangerous pesticides for the environment was searched (see section 3.2.2.5). The results of the step-by-step process is described below:

Step 1: Selection of pesticides having at least two "1" in Group 3 "Environmental toxicity" (except bees) of the PAN International List of Highly Hazardous Pesticides - June 2014 26

Amisulbrom

Azocyclotin

Bromethalin

Bromoxynil heptanoate

Bromoxynil octanoate

Cadusafos

Chlorantraniliprole

Chlorfluazuron

Copper (II) hydroxide

Cyhexatin

DDT

Dimoxystrobin

Etofenprox; Ethofenprox

Fenbutatin-oxide

Fluazolate

Flufenoxuron

Flumetralin

Halfenprox

Isopyrazam

Lufenuron*

Pirimicarb

Propargite

Prothiofos

Pyridalyl *

Quinoxyfen

Tebupirimifos

Tolfenpyrad

Tri-allate

Step 2: Selecting only pesticides authorised in the EU 27

Amisulbrom

Bromoxynil heptanoate

Bromoxynil octanoate

Chlorantraniliprole

Dimoxystrobin

Etofenprox; Ethofenprox

Isopyrazam

Lufenuron

Pirimicarb

Pyridalyl

Quinoxyfen

Tri-allate

25 The values reported in the table were obtained testing soluble compounds of these elements. They may not reflect the true toxicity of the waste, as availability and solubility of these compounds can depend on the waste.26 http://www.panna.org/sites/default/files/PAN_HHP_List_2014.pdf27 http://ec.europa.eu/sanco_pesticides/public/?event=activesubstance.selection&language=EN

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Copper (II) hydroxide

Step 3: Reporting EC50 and NOEC values, for selected pesticides for which such information is available.

The values are presented in sheet “Hazard of various substances”, tables under the name “pesticides” (Figure 11).

Figure 11: EC50 and NOEC of some of the most hazardous pesticides authorised in the EU

Substance EC50min (mg/L) SourceBromoxynil heptanoate  0,031 USEPABromoxynil octanoate  0,0042 USEPAChlorantraniliprole 0,0071 USEPAEtofenprox 0,00012 USEPAPirimicarb 0,0065 USEPAPyridalyl 0,0042 USEPAQuinoxyfen 0,028 INERISTri-allate 0,0062 USEPA

Substance NOECmin (mg/L) SourceCopper (II) hydroxide 0,00003 INERISEtofenprox 0,0037 USEPAPyridalyl 0,208 USEPAQuinoxyfen 0,00636 INERISTri-allate 0,01 USEPA

The most hazardous pesticides have EC50 and NOEC of 10-4 / 10-3 mg/L, which is why wastes containing pesticides were given a score of 3 (following a worst-case approach).

Figure 12 below shows an example of how information on the presence of hazardous substances is reported in the Excel file:

Figure 12: Extract from the Excel sheet which reports results for SC5

Waste code Waste description List of potentially hazardous substances Source Score

03 01 04*

sawdust, shavings, cuttings, wood, particle board and veneer containing hazardous substances

oil, varnishes and gluesPb, As, Cd, Cr, Hg, Cu, Zn, formaldehyde, boric acid, PCP, PCB, PAH (creosotes), oil-borne preservatives; Lindane (γ-HCH); quaternary ammonium compounds, Cu-azoles, fluorides

[6]Q-AT 3

04 02 19* sludges from on-site effluent treatment containing hazardous substances

Chemical products used during the cloth finishing, dyeing and washing processes:perchloroethylene, acids and alkalis (including metallic complexes), organic solventsHeavy metals (esp. Cr III), azo-dies, tensides (alcyl aryl sulfonates), hydrocarbons/oils, Naphthalene/chlorophenols, Glutaraldehyde

[6]Q-AT 2

06 03 15* metallic oxides containing heavy metals

nickel; copper; zinc; arsenic; cadmium; antimony; tellurium; mercury; thorium; lead; Sb, Be or their compounds (e.g. As oxide)

[6]Q-AT 3

06 05 02* sludges from on-site effluent treatment containing hazardous substances

Heavy metals, Ni, Pb, Cu, Cd, Cr, Zn, etc., maybe CaO Q-AT 3

The full results can be found in sheet “SC5” of the separate Excel file.

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5.1.6. SC6: Criticality of waste classificationThe VITO study allowed to have information on the criticality of 11 waste codes. The Italian28, Finnish29 and Austrian30 representatives gave inputs on 2, 4 and 64 waste codes respectively.

Information on criticality was reported in sheet “SC6” of the separate Excel file (example in Figure 13).

Figure 13: Extract from the Excel sheet which reports results for SC6

Waste code Waste description

Countries performing calculation methods in which waste streams classified under one code of a mirror entry are likely to shift to being classified under the other code

Rationale Source Score

03 01 04* sawdust, shavings, cuttings, wood, particle board and veneer containing hazardous substances n/a

03 01 05 sawdust, shavings, cuttings, wood, particle board and veneer other than those mentioned in 03 01 04

BE-YesAT-Maybe

Data collection on waste composition and assessment with calculation methods

Presence of traces of heavy metals especiallyCu-salts - H410, formaldehyde, fluorides Lindane -H410

[31]Q-AT 3

04 02 19* sludges from on-site effluent treatment containing hazardous substances n/a

04 02 20 sludges from on-site effluent treatment other than those mentioned in 04 02 19

AT-Maybe

MaybeGlutaraldehyde -H400 Naphthalene - H410Hydrocarbons - water pollutant Q-AT 1,5

The most “critical” codes were from chapter 19 (wastes from waste management facilities) and chapter 7 (wastes from organic chemical processes). Only one code was attributed the score of 0 (no change foreseen): 17 08 02 (“gypsum-based construction materials”)

5.2. Selected waste codesPairs selected thanks to the process described in section 3.2.1 are the following 14 (see also sheet “Selected pairs”):

Table 17: Preliminary selected mirror pairs

03 Wastes from wood processing and the production of panels and furniture, pulp, paper and cardboard

03 01 wastes from wood processing and the production of panels and furniture

03 01 04* 03 01 05 sawdust, shavings, cuttings, wood, particle board and veneer

07 Wastes from organic chemical processes

07 01 wastes from the manufacture, formulation, supply and use (MFSU) of basic organic

chemicals

07 01 11* 07 01 12 sludge from on-site effluent treatment

08 Wastes from the manufacture, formulation, supply and use (MFSU) of coatings (paints,

28 Istituto Superiore per la Protezione e la Ricerca Ambientale (ISPRA): Stefania Balzamo, Andrea Paina, Daniela Conti, Cristina Martone, Elisa Raso, Andrea Lanz29 VTT Technical Research Centre of Finland Ltd, Margareta Wahlström30 Federal Ministry of Agriculture, Forestry, Environment and Water Management, Sonja Löw

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varnishes and vitreous enamels), sealants and printing inks

08 01 wastes from MFSU and removal of paint and varnish

08 01 13* 08 01 14 sludges from paint or varnish

10 Wastes from thermal processes

10 01 wastes from power stations and other combustion plants (except 19)

10 01 14* 10 01 15 Bottom ash, slag and boiler dust from co-incineration

10 01 16* 10 01 17 fly ash from co-incineration

10 02 wastes from the iron and steel industry

10 02 07* 10 02 08 solid wastes from gas treatment

10 02 13* 10 02 14 sludges and filter cakes from gas treatment

17 Construction and demolition wastes (including excavated soil from contaminated sites)

17 03 bituminous mixtures, coal tar and tarred products

17 03 01* 17 03 02 bituminous mixtures

17 05 soil (including excavated soil from contaminated sites), stones and dredging spoil

17 05 03* 17 05 04 soil and stones

17 05 05* 17 05 06 dredging spoil

19 Wastes from waste management facilities, off-site waste water treatment plants and the

preparation of water intended for human consumption and water for industrial use

19 01 wastes from incineration or pyrolysis of waste

19 01 11* 19 01 12 bottom ash and slag

19 01 13* 19 01 14 fly ash

19 08 wastes from waste water treatment plants not otherwise specified

19 08 11* 19 08 12 sludges from biological treatment of industrial waste water

19 08 13* 19 08 14 sludges from other treatment of industrial waste water

Waste streams suggested by the Member States and their correspondence are presented in Table 18 below:

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Table 18: Wastes suggested by Member States and the corresponding mirror pairs

Waste stream Mirror pair, identified by its hazardous entry

Most wastes, having hazardous mirror entries -  General toxicity of heavy metals : Hg > Ag > Cu > Zn > Ni > Pb > Cd > As > Cr(III)

Not specific enough for pairs to be attributed

Sewage sludge, non-hazardous industrial sludges, having hazardous mirror entries (e.g. sludges from textile industry, tanning industry, metal industry etc.)

04 02 19*

06 05 02*

07 01 11*

07 02 11*

07 03 11*

07 04 11*

07 05 11*

07 06 11*

07 07 11*

08 01 13*

08 01 15*

08 03 14*

08 04 11*

08 04 13*

10 01 20*

10 01 22*

10 02 13*

10 03 25*

10 08 17*

10 11 13*

10 11 17*

11 01 09*

11 02 02*

12 01 14*

19 08 11*

19 08 13*

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Waste stream Mirror pair, identified by its hazardous entry

Wastes from gas cleaning (filter dusts from metal industries, where there are mirror entries)

10 01 18*

10 03 19*

10 05 03*

10 06 03*

10 08 15*

10 08 17*

10 09 09*

10 10 09*

10 11 17*

All other batteries than those already classified as hazardous – it is likely that they all will fulfil HP14 (they will also fulfil the hazardous property HP15 – new definition: explosive if heated under confinement)

16 06 03*

20 01 33*

Wastes containing zinc oxide (Zinc oxide is classified as aquatoxic !!!) such as zinc ashes, zinc skimmings

10 05 10*

10 05 03*

Tanning liquor not containing chromium VI (but containing glutaraldehyde, salts, chromium III etc.) – will fulfil HP14 in our view

No mirror pairs

Wastes containing high amounts of CaO(Ca(OH)2 (free calcium oxide) such as ashes from wood incineration, ferrous metal slags - effect of high pH on micro-organisms and maybe also effects of salt concentration if ph-moderation is performed

10 03 04*

10 03 29*

(Mineral) construction and demolition waste (heavy metals, PAH in bituminous wastes)

17 03 01*

17 05 03*

17 05 05*

17 05 07*

17 06 03*

17 08 01*

17 09 01*

17 09 03*

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Waste stream Mirror pair, identified by its hazardous entry

filter cake  from tank cleaning (paint, food, textile) and gas cleaning

10 02 13*

10 03 25*

10 08 17*

10 11 17*

11 01 09*

Gas cleaning, see above

sludge (sewage, domestic, Cu, Co, food) See above, and additionally:

Municipal: 19 02 05*

Food: no mirror entry with sludge

Refuse derived fuel No mirror entry

Car shredder (fluff, light fraction) 19 10 03*

soil and residues from soil cleaning 17 05 03*

17 05 05*

17 05 07*

19 13 01*

19 13 03*

19 13 05*

fly ash (wood, sludge) 10 01 16*

19 01 13*

waste blasting material 12 01 16*

kettel ashes Not found in the LoW

construction & demolition waste (asphalt, with and wihout tar, concrete, bitumen, minerals)

See above

digestate No mirror entries

biodegradable (kitchen, garden) waste No mirror entries

sand (from C&D waste) No mirror entries

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Waste stream Mirror pair, identified by its hazardous entry

solvent 04 01 03*

04 02 14*

08 01 11*

08 01 13*

08 01 17*

08 01 19*

08 04 09*

08 04 11*

08 04 13*

08 04 15*

bottom ashes (waste incineration, electricity production)

19 01 11*

dredging spoil 17 05 05*

wood 19 12 06*

20 01 37*

03 01 04*

Metal-containing wastes such as metal treatment sludges and incinerator bottom ashes (from a variety of incinerators)

See above

The list of Member States-suggested mirror pairs which are in the original list of the Commission, and different from the 14 pairs selected earlier, are presented in Table 19. The second column shows which pairs belong to the three main categories proposed by the Member States: gas cleaning, sludge and C&D waste.

Table 19: Pre-selected pairs which are in the original list of the Commission, and different from the 14 pairs selected earlier

Mirror pair, identified by its hazardous entry

Gas cleaning, sludge or C&D waste? (x=yes)

04 02 19* x06 05 02* x07 02 11* x07 03 11* x07 05 11* x07 06 11* x08 03 14* x08 04 11* x10 01 18* x10 03 19* x10 03 25* x10 03 29*10 05 10*

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Mirror pair, identified by its hazardous entry

Gas cleaning, sludge or C&D waste? (x=yes)

10 08 15* x10 08 17* x10 10 09* x11 01 09* x12 01 14* x12 01 16*17 06 03* x17 08 01* x19 10 03*19 13 01*

As described in section 3.2.4, only pairs in which both entries have a score above 1 make the final cut (Table 20).

Table 20: Final selection of Member States-suggested waste streamsMirror pair, identified by its hazardous entry

Score of hazardous entry

Score of non-hazardous entry

Final selection

04 02 19* 0,97 1,1906 05 02* 1,35 1,30 x07 02 11* 0,78 1,1907 03 11* 0,75 1,1407 05 11* 0,87 1,2307 06 11* 0,70 1,1408 03 14* 0,86 0,7408 04 11* 0,73 0,7410 01 18* 0,93 0,8610 03 19* 1,28 1,47 x10 03 25* 0,74 1,0310 08 15* 0,85 0,7810 08 17* 0,92 1,0310 10 09* 0,78 0,7011 01 09* 1,36 1,21 x12 01 14* 1,31 1,19 x17 06 03* 1,31 1,25 x17 08 01* 0,93 0,97

The 10 selected codes are completed with the following entries proposed by the Commission:

The pair 19 10 03* / 19 10 04

The pair 19 12 11* / 19 12 12

The triplet 15 01 10* / 15 01 01 / 15 01 02

Therefore, the final list of selected codes is the following (45 codes):

Table 21: Final list of selected codes

03 Wastes from wood processing and the production of panels and furniture, pulp, paper and cardboard

03 01 wastes from wood processing and the production of panels and furniture

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03 01 04* 03 01 05 sawdust, shavings, cuttings, wood, particle board and veneer

06 Wastes from inorganic chemical processes

06 05 sludges from on-site effluent treatment

06 05 02* 06 05 03 sludges from on-site effluent treatment

07 Wastes from organic chemical processes

07 01 wastes from the manufacture, formulation, supply and use (MFSU) of basic organic

chemicals

07 01 11* 07 01 12 sludge from on-site effluent treatment

08 Wastes from the manufacture, formulation, supply and use (MFSU) of coatings (paints,

varnishes and vitreous enamels), sealants and printing inks

08 01 wastes from MFSU and removal of paint and varnish

08 01 13* 08 01 14 sludges from paint or varnish

10 Wastes from thermal processes

10 01 wastes from power stations and other combustion plants (except 19)

10 01 14* 10 01 15 Bottom ash, slag and boiler dust from co-incineration

10 01 16* 10 01 17 fly ash from co-incineration

10 02 wastes from the iron and steel industry

10 02 07* 10 02 08 solid wastes from gas treatment

10 02 13* 10 02 14 sludges and filter cakes from gas treatment

10 03 wastes from aluminium thermal metallurgy

10 03 19* 10 03 20 flue-gas dust

11 Wastes from chemical surface treatment and coating of metals and other materials; non-ferrous hydro-metallurgy

11 01 wastes from chemical surface treatment and coating of metals and other materials

11 01 09* 11 01 10 sludges and filter cakes

12 Wastes from shaping and physical and mechanical surface treatment of metals and plastics

12 01 wastes from shaping and physical and mechanical surface treatment of metals and

plastics

12 01 14* 12 01 15 machining sludges

15 Waste packaging; absorbents, wiping cloths, filter materials and protective clothing

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not otherwise specified

15 01 packaging (including separately collected municipal packaging waste)

15 01 10* 15 01 01 15 01 02

paper and cardboard packaging, plastic packaging

17 Construction and demolition wastes (including excavated soil from contaminated sites)

17 03 bituminous mixtures, coal tar and tarred products

17 03 01* 17 03 02 bituminous mixtures

17 05 soil (including excavated soil from contaminated sites), stones and dredging spoil

17 05 03* 17 05 04 soil and stones

17 05 05* 17 05 06 dredging spoil

17 06 insulation materials and asbestos-containing construction materials

17 06 03* 17 06 04 insulation materials not containing asbestos

19 Wastes from waste management facilities, off-site waste water treatment plants and the

preparation of water intended for human consumption and water for industrial use

19 01 wastes from incineration or pyrolysis of waste

19 01 11* 19 01 12 bottom ash and slag

19 01 13* 19 01 14 fly ash

19 08 wastes from waste water treatment plants not otherwise specified

19 08 11* 19 08 12 sludges from biological treatment of industrial waste water

19 08 13* 19 08 14 sludges from other treatment of industrial waste water

19 10 wastes from shredding of metal-containing wastes

19 10 03* 19 10 04 fluff-light fraction and dust

19 12 wastes from the mechanical treatment of waste (for example sorting, crushing,

compacting, pelletising) not otherwise specified

19 12 11* 19 12 12 other wastes (including mixtures of materials) from mechanical treatment of waste

It should be mentioned that construction and demolition wastes (Chapter 17) can be very complex to characterise, both chemically and via biotests, due to their heterogeneity and often rather massive form. High variability in any analytical data collected in following work (see Next Steps), is to be expected.

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6. Next steps6.1. Reporting experimental data for the calculationsThe process for collecting experimental data was launched.

The nine Member States who answered the first questionnaire were sent a database via email for them to fill with data on composition of waste and biotests results. The list of experts contacted and their contribution is reported in Error: Reference source notfoundTable 22 below. Sweden was added to the list as Finnish representatives transferred our request to them.

Table 22: Experts contacted and their contribution (in green: Member States who have already contributed, as of February 16th)

Member State

Experts contacted Expert(s) who contributed

Contribution

Austria Sonja Loew, Lebensministerium

Sonja Loew Austria does not have data on chemical analyses or on biotests results

Belgium Reinhilde Weltens, VITO

Reinhilde Weltens

Data from a previous project16 where VITO collected chemical analyses from companies

Czech Republic

Dagmar Sirotková, Centre for Waste Management, VUV

Katerina Polakova, Dagmar Sirotková, Centre for Waste Management, VUV

Finland Eevaleena Häkkinen, Ympäristöministeriö

Margareta Wahlström

Analyses

Sweden - Sara Stiernström

Analyses performed during her PhD

Germany Joachim Wuttke, UBA

Walter Adebahr, UM Baden-Württemberg

Joachim Wuttke

Daniel Laux on behalf of Walter Adebahr

Sent a link to a ‘hidden’ website where data collected during the German-led ring test on HP 14 are available (http://ecotoxwasteringtest.uba.de/h14/)

Sent two studies on HP 14 containing spreadsheets of data

Spain Margarita Ruiz Sáiz-Aja

UK Robert McIntyre

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Member State

Experts contacted Expert(s) who contributed

Contribution

France Edouard van Heeswyck31

Italy Daniela Conti

Andrea Paina

Stefania Balzamo

The answers from Member States are being processed as soon as they are received. For France, INERIS will provide a large amount of data, in addition to any data potentially received from the Environment Ministry.

6.2. Application of the four calculation methods

6.2.1. Calculating average concentrationsThe objective will be to establish the average concentration (and the range of minimum and maximum values) for each relevant chemical and eco-toxicological parameters needed to run equation for each waste type.

For each hazardous component32 of each selected waste mirror code, the average concentration for each relevant chemical and eco-toxicological parameters will be determined by the team using the values of concentration reported in the database during the data collection. The different values, coming from different samples of the same waste type – for example from different MS, will constitute the value range delimited by the maximum and minimum values.

The calculation of the average is quite straightforward but the project team will make sure that only reliable and comparable analytical data enters the calculation. To do so, data of highest quality (from chemical analysis and toxicity test results both generated from the same waste sample and within a similar timeframe, with the less artefacts of analysis or alterations from sample preparation or extended conservation times for example) will be preferred by the team; and outliers will be discarded from the average calculation.

The calculation of the average concentration will be duly documented by the team and presented in an Excel spreadsheet.

6.2.2. Running HP 14 assessment methods and considering the final waste classification

The objective will be to run the four calculation methodologies proposed by the Commission to classify the waste, on the basis of the average chemical concentration determined above for each waste type.

The Commission provided four different assessment/calculation methods to determine the classification of the waste (see Figure 14), based on the comparison of the concentration of hazardous components (exhibiting acute or chronic aquatic toxicity, or ozone depleting properties) with limit concentrations. If the concentration of the hazardous component (individually or in summation with the other hazardous components of the same nature) exceeds the concentration limit, the waste is classified as hazardous the HP 14, if not it is classified not hazardous for HP 14.

31 Edouard van Heeswyck is the successor of Pauline Adriane Langeron, who was contacted for the first questionnaire32 i.e. a component classified as ‘ozone depleting’ or ‘acute aquatic toxic’ or ‘chronic aquatic toxic 1,2,3,or 4’

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Figure 14: Calculation/assessment methods for the classification of waste

Using the average concentrations of each relevant chemical and eco-toxicological parameters determined in the previous subtask, the team will apply the four calculation methods in an Excel spreadsheet. Using the conditional formatting and the IF formulas, the software will automatically determine if the waste if hazardous by HP 14 or not.

The results of hazard classification for HP 14 for each waste code according to each of the 4 calculation methods will be summed up in a table (see Table 23).

Table 23: Example of table gathering the results of hazard classification for HP 14 for all the waste streams and all the calculation methods

Waste Baseline Result for Method 1

Result for Method 2

Result for Method 3

Result for Method 4

Countries where

hazardous

Countries where non-hazardous

Waste 1

Non hazardous

Non hazardous

Hazardous Hazardous

Waste 2

Non hazardous

Non hazardous

Non hazardous

Non hazardous

The waste streams will be classified according to the different HP 14 classification methods, gathered in a table, along with a calculation Excel spreadsheet. These results will feed the sensitivity analysis (comparative assessment of the different methodologies) to be performed next.

6.3. Comparative assessment of the different methodologiesThe four calculation methods allow for possible classifications of the selected waste types, as hazardous or non-hazardous, based on the chemical composition of the waste.

The choice of a final approach requires a comparative assessment of the different calculation methods. To this aim, the purpose of this phase is twofold: on one hand, it intends to provide a critical assessment of each methodology and on the other

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hand, to compare the different methodologies with each other and with the results of ecotoxicological experiments.

The team proposes to conduct the assessment of the calculation methods on three aspects:

Feasibility of the different methods (depending on the complexity of the waste, the available data, etc.)

Appraisal of the scientific relevance of the different methods (reliability, coherence with ecotoxicity tests, etc.); and

Impact assessment of the change of classification of some waste types, due to the different methods (costs, impacts on waste management practices, etc.).

On the basis of the assessment per dimension, the team will provide a global assessment of each calculation method, in terms of advantages and drawbacks. Likewise, the comparison of the methods will be done according to the three dimensions and then globally to provide general conclusions and possible alternative methods. The results of the comparative assessment will be discussed during a workshop.

The conclusions will integrate the results of the workshop’s discussion and feedback. The development of alternative methods should integrate ecotoxicity tests, which address some of the limitations of the calculation methods and receive general acceptance from the scientific community.

6.4. Consultation of the stakeholders and organising a stakeholders' workshop

The goal is to identify and consult experts and stakeholders to provide feedback to the work conducted in this project. Experts and stakeholders’ inputs will be essential for ensuring that the results of the analysis are reliable and the recommendation for an harmonised HP 14 assessment methodology are set up appropriately for its purposes as well as for filling the gaps of missing data. The team will assist the Commission with the preparation of the consultation document.

The workshop has been scheduled on 20 April 2015 in the Commission premises. The steps detailed previously in this section will have been finished at his time.

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7. AnnexesANNEX 1. FIRST QUESTIONNAIRE SENT TO COMPETENT AUTHORITIES______________55

ANNEX 2. FACTSHEETS_________________________________________________59

ANNEX 3. SECOND QUESTIONNAIRE SENT TO COMPETENT AUTHORITIES___________103

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Annex 1. First Questionnaire sent to Competent Authorities1. General information1.1 Your full name and your email address:

_______________________________________________________________________

1.2 Please provide the name of the organisation to which you belong:

______________________________________________________________________

And its type (bold the right answer):

o National authorityo Research instituteo Industryo Other (please specify):

________________________________________________________________

1.3 Your country (bold the right answer):

o AT – Austriao BE – Belgiumo CZ – Czech Republico DE – Germanyo ES – Spain

o FI – Finlando FR – Franceo IT - Italyo PL - Polando UK - United Kingdom

1.4 Type of waste your expertise covers (bold the right answer):

o Allo Specific

Provide a general description of waste categories you cover or waste codes when relevant: _____________________________________________________________

2. Approaches for assessing the H14 property of waste in your country2.1 Type of approach (bold the right answer):

o Calculation method

Approach based on limit values (based on CLP or DPD limits)

Specify protocol details and applicable limit values: __________________________________________________________

Approach not based on limit values

Specify details of the protocol: ___________________________________________________________

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o Approach based on biotesting

Specify protocol details for the approach based on biotesting and applicable limit values: ___________________________________________________________

Type of test

Test organism

Endpoint Test method Test duration

Expression of results

Threshold value

Terrestrial

Aquatic

o Combined approach

Specify protocol details and applicable limit values (e.g. priority given to calculation method or experimental approach? Systematic or partial implementation of biotests? Ecotoxicity based approach applied to all type of waste or to some of them?): ___________________________________________________________

o Other

Specify protocol details: ________________________________________________________

2.2. Please provide sources of information (for example guidelines) for the H14 assessment methods and protocols (a preliminary list – to be reviewed and completed - is available in the attached document named Attachment 1 - Preliminary list of relevant legislation and guidelines): ______________________________________________________________________

2.3. Please provide examples of application of your H14 assessment method on 1 or 2 waste types / waste codes (to be chosen from the list available in the attached document named Attachment 2 - List of waste codes):

______________________________________________________________________

2.4 According to your knowledge, what are the limits and uncertainties of the approach?

______________________________________________________________________

2.5. What are the advantages?

______________________________________________________________________

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2.6. Please provide relevant national legislation or guidelines for the H14 assessment methods and protocols (a preliminary list – to be reviewed and completed - is available in the attached document named Attachment 1 - Preliminary list of relevant legislation and guidelines):

______________________________________________________________________

2.7. Please indicate the stakeholders involved in the assessment:

Stakeholder role Name of stakeholder Type of stakeholder (national authority, research institute, etc.)

FundingPerforming the test(s),Providing waste samplesOther (please specify in comments)

2.8. Please provide examples of costs linked to the H14 assessment methods used in your country:

______________________________________________________________________

3. Proposal for the selection of waste streamsThe project team will test four calculation options on a set of 50 pairs of mirror waste codes (mirror entries), to be selected from the list in the attached document. The following questions aim at prioritising the waste streams to select.

3.1 On which specific waste streams do you think the present study comparing assessing methods for H14 should focus on?

_______________________________________________________________________

3.2 Why? Choose one or more reasons below (bold the right answer):

o Availability and quality of existing datao Criticality of the classification stability (i.e. waste types that are likely to change

their classification (from hazardous to non-hazardous or vice-versa) if the limit values evolve)

o High quantities of waste productiono Economic importance (trade and recycling)o Potential presence of hazardous substanceso Other (please specify):

________________________________________________________________

3.3. Could you please provide us sources of information where we could find the following data?

o Information on quantities produced by specific waste codes: ____________o Hazard classifications assigned: _____________________________o Composition data of specific wastes:_________________________________o Results of ecotoxicological tests: ______________________________________o Protocols of sampling, preparation of samples, analyses and test: ____________

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4. General information about waste streams in your country4.1. What is the share of waste assessed positive for the H14 criteria in your country, globally, and by category of waste if relevant?

_______________________________________________________________________

4.2. What type of waste has the highest tonnage in your country?

Type or category or code of waste

Annual tonnage (metric tonnes)

Share (%)

Among hazardous wasteAmong total waste

5. Additional information5.1 If you have additional comments, please share them below:

_______________________________________________________________________

5.2 Please provide relevant contacts (for example in regional administrations or research centres) and references of documents for an in-depth analysis:

______________________________________________________________________

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Annex 2. Factsheets

AUSTRIA

National approach to assess H14 (ecotoxicity) of wastes

Type of approach(es) used in the country to assess H14 property of waste

Combined approach

Refer to the ADR (UN classification of dangerous goods for road transport) for ecotoxic substances class 9 : M6 and M7, AND have a limit for ozone depleting substances (2000 mg/kg in total)

Variability in H14 assessment methods depending on the waste nature

-

Related legislation and guidelines

Legislation Fed. Law Gaz No. 522/1973 as amended by Fed Law Gaz III No. 36/2

Annex 3 of Abfallverzeichnisverordnung BGBl II (Austrian Ordinance of Waste Classification) 2003/570 idgF

Guidelines None

Stakeholders involved in the H14 assessment

Waste with highest tonnage

Waste with highest tonnage 17 05 04 excav. Soil 23,5 Mio t

17 09 04 C&D waste 6,6 Mio t

19 01 14 filter dust -

10 02 08 gas cleaning(Fe) –

Approx. 53,6 million tons of waste are generated in Austria, thereof approx. 1 million ton of hazardous waste (Data 2009)

From Eurostat:

Waste from construction : 57%, 19.5 Mt

Hazardous waste with highest tonnage

17 05 03*excav, soil haz. 128.260 t

10 02 07 gas cleaning(Fe) 82.823 t

19 01 13* filter dust haz 48.141 t

17 09 03* C&D waste haz -

From Eurostat:

10-11-12 : Inorganic wastes from thermal processes + Inorganic metal-containing wastes from metal treatment and the coating of metals, and non-ferrous hydrometallurgy + Wastes from shaping and surface treatment of metals and

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AUSTRIA

National approach to assess H14 (ecotoxicity) of wastes

plastics (32%, 272.7 kt)

19 : Waste from waste treatment facilities, off-site waste water treatment plants and the water industry (23%, 200.7 kt)

Chapter of List of waste with the highest share of hazardous waste

05 : Wastes from petroleum refining, natural gas purification and pyrolytic treatment of coal (73%, 2.9 kt)

Percentage of waste considered as hazardous by H14

Protocol used

no ecotoxicity tests are applied

Calculation methods are used

Chemical analyses are sufficient for the attribution of H14. H 14 applies for:

environmental hazardous substances due to Class 9, M6 and M7 of the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) (Annex 3 of Austrian Ordinance of Waste Classification2003/570)

wastes with a total yield of hydrocarbons (CFHCs, HCFCs, HFHCs, FHCs, Halons) over 2000 mg/kg DM (see below)

Calculation methods

Combination of hazardous components concentration

Threshold value

ozone depleting substances (hydrocarbons: CFCs, CFHCs, HCFCs, HFHCs, FHCs, Halons)

2000 mg in total /kg DM

Illustrative examples

Qualitative assessment of the method(s)

Advantages classification according to the UN- Regulation on Transport of Dangerous Goods is required anyway if the waste is transported

Limits and uncertainties

Approximate cost of the method(s)

In most cases no additional costs as classification according to the UN- Regulation on Transport of Dangerous Goods is required anyway if the waste is transported

Other MS using the same approach (if known)

-

Additional comments -

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AUSTRIA

National approach to assess H14 (ecotoxicity) of wastes

Expert contacted to elaborate this factsheet

Sonja Loew (Federal Ministry of Agriculture, Forestry, Environment and Water Management)

References Ökopol GmbH (2008) Review of the European List of Waste, 532 pp.

RECORD., 2008, Suivi des travaux européens pour la caractérisation et la classification des déchets par le critère H14 (écotoxicité)

Additional information -

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BELGIUM (Flanders)

National approach to assess H14 (ecotoxicity) of wastes

Type of approach(es) used in the country to assess H14 property of waste

Calculation method with limit value Method based on the DPD (older version, no M-factors)

Variability in H14 assessment methods depending on the waste nature

The Flemish guidelines refer to the responsibility and common sense of the waste producer as concerns test methods. No specific tests for HP14 are mentioned! So Flemish guidelines and legislation focus on the former chemical legislation and its limit values, as concerns HP14.

Related legislation and guidelines

Legislation The Flemish legislation (Vlarema) refers to the test method regulation 440/2008 in general (for those hazardous properties that are defined at European level, so not for HP14)..

Guidelines OVAM (2004) Europese afvalstoffenlijst EURAL Handleiding

Stakeholders involved in the H14 assessment

Name of the institution(s) + type of the institution+ role (funding/performing assessment, etc.)

Waste with highest tonnage

Waste with highest tonnage Construction & demolition waste (3891996 ton, 15.7%

Hazardous waste with highest tonnage

No data regarding the amount of hazardous waste per waste code is available. Per sector: Secondary waste has the highest tonnage among hazardous waste (737,888 tons)

Chapter of List of waste with the highest share of hazardous waste

No available data

Percentage of waste considered as hazardous by H14

-

Protocol used Ecotoxic tests are not applied.

Calculation methods:

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BELGIUM (Flanders)

National approach to assess H14 (ecotoxicity) of wastes

Individual substances

Classification Concentration limits

R50 25

R50-53 0.25

R51-53 2.5

R52-53 25

R52 25

R53 25

R59 0.1

Combination of substances

Classification Concentration threshold to be taken into account

Conditions rendering waste hazardous

R50 0.1 •Sum of R50-53 substances >2.5%

•Sum of R51-53>25%

•Sum of R50 substances>25%

•Sum of R59 substances >0.1%

R50-53 0.1

R51-53 0.1

R52-53 1

R52 1

R53 1

R59 0.1

Illustrative examples -

Advantages Easy to perform on well-defined samples

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BELGIUM (Flanders)

National approach to assess H14 (ecotoxicity) of wastes

Qualitative assessment of the method(s)

Limits and uncertainties The real toxicity is not taken into account.

Waste is a mixture of dangerous and non-dangerous substances, but with the very important difference that the composition of mixtures of chemical substances100 % is known while this is almost never the case for waste. Inorganic analyses provide only element concentrations, but the speciation of the metal is unknown and applying M-factors based on worst-case scenarios lead to overestimating the intrinsic toxicity of metals in the waste.

For complex waste in addition, it is not possible to identify any organic substances, which are not passed on to the ecotoxicity assessment These uncertainties and shortcomings in the knowledge of the composition of waste can easily lead to wrong classification (overestimation of the metal toxicity, underestimation of the share of the organic components).

Approximate cost of the method(s) Variability depending on waste types (%)

AFNOR XP X30-489 is 1900 € per sample.

Ecotox-testing (microtox) : 1000,- per sample

Other MS using the same approach (if known)

None

Additional comments -

Expert contacted to elaborate this factsheet

Evi Rossi (OVAM)

References OVAM (2004) Europese afvalstoffenlijst EURAL Handleiding

Overzicht bedrijfsafvalstoffen en nieuwe grondstoffen 2004-2012 (statistics on waste quantities in Flanders, provided by OVAM)

Impact study Flemish LoW (OVAM)

Additional information .

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CZECH REPUBLIC

National approach to assess H14 (ecotoxicity) of wastes

Type of approach(es) used in the country to assess H14 property of waste

Ecotoxicity tests

Variability in H14 assessment methods depending on the waste nature

No

Related legislation and guidelines

Legislation Act on Waste No 185/2001 Coll. on waste

Decree No 376/2001 Coll. on evaluation of hazardous properties of waste

Guidelines

Stakeholders involved in the H14 assessment

Funding/ owner of the waste (government or private)

Performing the tests: accredited laboratory (private)

Providing waste samples: national authority, owner, laboratory (government or private)

Waste with highest tonnage

Waste with highest tonnage

Hazardous waste with highest tonnage

In 2012: 17 05 03*: 406471,6000 t (24,8% of total hazardous waste)

In 2013: 308491,4077t (21,4% of total hazardous waste)

Chapter of List of waste with the highest share of hazardous waste

Percentage of waste considered as hazardous by H14

Protocol used Ecotoxic tests

Leaching: EN 14735

No terrestrial tests

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CZECH REPUBLIC

National approach to assess H14 (ecotoxicity) of wastes

Aquatic tests

Test organism

Endpoint

Test method

Test duration

Expression of results

Threshold value

Sinapis alba

root length

Instructions (Bulletin of Ministry of Environment CR)

3 days EC50 10 ml/l

Desmodesmus subspicatus

growth EN ISO 8692

3 days EC50 10 ml/l

Daphnia magna

mobility

EN ISO 6341

2 days EC50 10 ml/l

Poecilia reticulata

lethal effect

EN ISO 7346-2

4 days EC50 10 ml/l

No calculation methods

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CZECH REPUBLIC

National approach to assess H14 (ecotoxicity) of wastes

Illustrative examples

Waste

Decree No. 376/2001 Coll.

Chemical limits

Ecotoxicity

Exceeded limit

Exceeded limit

Contaminated soil from wood preservation plant

No Yes - algea

Contaminated soil (metals, PAHs, sludge from wastewater treatment plant)

No No

sludge from mechanical industrial wastewater treatment plant

No No

ash from thermal electric power station

No No

Contaminated soil No No

sludge No No

ash Yes - pH No

stabilized waste No No

Qualitative assessment of the method(s)

Advantages Aquatic ecotoxicity tests are sensitive to many water soluble substances. Wastes are usually materials of heterogenic composition. Ecotoxicity tests integrate the effects of all contaminants including additive, synergistic and antagonistic effects. Waste can be evaluated in a relatively short time (within 2 weeks).

Limits and uncertainties All tests are carried out only with water extract (leachate). The results are relevant only for water ecosystems but the hazard for soil ecosystem has not been included. To improve the current state, introduction of terrestrial tests from the EC would be helpful.

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CZECH REPUBLIC

National approach to assess H14 (ecotoxicity) of wastes

Approximate cost of the method(s) Variability depending on waste types (%)

Approx. CZK 11000,- (EUR 410,-)

Other MS using the same approach (if known)

Similar to Spain (only aquatic tests)

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CZECH REPUBLIC

National approach to assess H14 (ecotoxicity) of wastes

Additional comments The Centre for Waste Management, VUV, TGM Praha, conducted research for the Ministry of the Environment aimed at the proposal of a new tests for waste ecotoxicity evaluation from 2005 to 2010. In the research participated national authorities, private organisations and universities.

Real wastes samples were used for research. They were selected partly on the basis of the production volume and also on the basis of their contamination. These wastes were used:

• contaminated soil from staining and impregnation of wood

• contaminated soil – mixed contamination by metal (Zn), traces of PAHs (polyaromatic hydrocarbons) and sewage sludge from wastewater treatment plant

• sludge from mechanical industrial wastewater treatment plant

• fly ash from thermal electric power station (two different samples)

• blast furnace slag

• soil contaminated with trinitrotoluene (two different samples)

• compost for recultivation (two different samples)

• PCBs (polychlorinated biphenyls) contaminated soil

• slag from incinerator

• contaminated sediment

• construction waste

• construction waste fine

• soil contaminated with organic substances

• sludge from the production of organic substances

• stabilized fly ash from coal combustion

• unpolluted soil

The results of research served for the proposal of a new approach for ecotoxicity evaluation for amendment of the Czech Decree No. 376/2001 Coll. on the evaluation of hazardous properties of waste.

New proposal :

Evaluation of ecotoxicity as hazardous property H14 Ecotoxic includes aquatic and terrestrial test sets aiming on complex evaluation of waste ecotoxicity.

Waste is classified as hazardous with hazardous property H14 Ecotoxic, if the observed effect of waste eluate in concentration 100 ml/l or the observed effect of waste in concentration 100 g/kg for at least one of testing organisms exceeds following limits:

aquatic tests with waste eluate in concentration 100 ml/l:

• 20 % inhibition of the mobility of water flea Daphnia magna, ISO 6341

• 25 % inhibition of the growth of fresh water algae Desmodesmus subspicatus, ISO 8692

• 25 % inhibition of the light emission of luminescent bacteria Vibrio fischeri, ISO 11348-2

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streams – Interim report

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CZECH REPUBLIC

National approach to assess H14 (ecotoxicity) of wastes

Expert contacted to elaborate this factsheet

Mr. Jaromír Manhart, [email protected]

Ms. Eva Kubova, [email protected]

References Ministerstvo životního prostředí české republiky (2007) Metodický pokyn odboru odpadů ke stanovení ekotoxicity odpadů

Additional information

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FINLAND

National approach to assess H14 (ecotoxicity) of wastes

Type of approach(es) used in the country to assess H14 property of waste

Calculation method with limit value

Based on recommended limit value for hazardous components (General limit values of DPD Directive without M-factors)

Variability in H14 assessment methods depending on the waste nature

In cases where a substance is classified as ecotoxic in the Chemicals Legislation, the limit values of Chemicals Legislation are used also for evaluation of ecotoxicity of the waste. According to guidance given in 2002, if there isn´t sufficient information available on the chemical composition of the waste, criterion H14 could also be assessed by using ecotoxicity tests. It is recommended to use a combination of several tests. However, no limit values have been set for ecotoxicity tests in relation to H14 evaluation so their usability for classification is very limited. Hence they are not applied in practice for evaluation if H14.

Related legislation and guidelines

Legislation Waste decree of the Finnish Ministry of the Environment 1128/2001

The Finnish waste legislation does not yet refer to any specific test methods or limit values to determine the ecotoxic property of wastes

Guidelines Dahlbo, H. 2002. Jätteen luokittelu ongelmajätteeksi – arvioinnin perusteet ja menetelmät (Classification of waste as hazardous waste – the basis and methods for evaluation). Environment Guide 98. Finnish Environment Institute. Helsinki. Finland. 160 pp. (In Finnish)

Ympäristöministeriö, Tilastokeskus, Suomen ympäristökeskus. Jäteluokitusopas 2005 (Waset Classification Guide 2005). Tilastokeskus, Käsikirjoja 37. Helsinki 2005. (In Finnish)

Stakeholders involved in the H14 assessment

The Finnish Environment Institute, VTT

Waste with highest tonnage

Waste with highest tonnage Mineral waste from mining and quarrying: 52 880 000 t (59%)

Mineral waste from construction: 15 682 000 (17%)

From Eurostat

Waste from Mining and quarrying (58%, 53 Mt)

Hazardous waste with highest tonnage

Mineral waste 561 000 tonnes (53%)

From Eurostat:

10-11-12 : Inorganic wastes from thermal processes + Inorganic metal-containing wastes from metal treatment and the coating of metals, and non-ferrous hydrometallurgy + Wastes from shaping and surface treatment of metals and

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FINLAND

National approach to assess H14 (ecotoxicity) of wastes

plastics (62%, 1Mt)

Chapter of List of waste with the highest share of hazardous waste

05 : Wastes from petroleum refining, natural gas purification and pyrolytic treatment of coal (69%, 22 kt)

Percentage of waste considered as hazardous by H14

Protocol used

Ecotoxic tests can be applied

According to guidance given in 2002, if there isn´t sufficient information available on the chemical composition of the waste, criterion H14 could also be assessed by using ecotoxicity tests (such as: Vibrio fischerii test SFS-EN ISO 11348-3; Daphnia magna test in EC Directive 67/548/ETY annex V method C2; algae test in EC Directive 67/548/ETY annex V method C3, various plant tests etc.). It is recommended to use a combination of several tests.

However, no limit values have been set for ecotoxicity tests in relation to H14 evaluation so their usability for classification is very limited. Hence they are not applied in practice for evaluation if H14.

Calculation methods are used

Limit values for hazardous properties in wastes (waste decree 1128/2001): none, recommended limit value in Finland 0.25 % (N and R51-53 or R50 or R53). This proposed limit value is set on the basis of the classification of chemicals with an ecotoxic property

Combination of hazardous components concentration

Limit value Cut-off value

R51-53 2.5 % 0.1 %

R50, R52 25 % 0.1 %

R50-53 0.25 % 0.1 %

R59 0.1 % 0.1 %

R53, R52-53 25 % 1 %

Additivity according to the DPD formulas (without M-factors)

Illustrative examples

Qualitative Advantages When M-factors are not included it is possible to

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FINLAND

National approach to assess H14 (ecotoxicity) of wastes

assessment of the method(s)

apply cut-off values 0,1 % / 1 %. Hence minor concentrations of elements/substances can be excluded from the evaluation.

(If cut-off would be defined by 0,1% /M for Aquatic Chronic 1, the number of possible hazardous substances present in the waste increases substantially, based on low concentrations of elements and high M-factors, and it may become impossible to prove that a waste is not ecotoxic; the highest M-factor in the CLP at the moment is 1 000 000.)

Limits and uncertainties Since the Chemicals legislation limit values are based on compounds it would be necessary to know the exact composition of the waste. Often there is only limited information on the waste composition, such as concentration of elements. It can be difficult to determine in which form the elements are in the waste.

The current procedures/methodology in CLP are meant for chemicals with known constant composition. The applicability of CLP methods has not been evaluated for waste streams, typically heterogeneous with high content of anions, alkaline earth metals and silica. Also suitable methods for organic substances are often lacking.

Limit values are difficult to apply to non-homogeneous materials and waste articles.

We think that M-factors should not be used in HP 14 evaluation. Today, only a few M-factors given, but it is very likely that new M-factors will be introduced in future. This means that the consequences of M-factors on waste classification are almost impossible to evaluate

Approximate cost of the method(s) Variability depending on waste types (%)

Other MS using the same approach (if known)

Additional comments One goal of this Commission study is to determine the influence of M-factors to the amounts and types of waste to be classified as hazardous. However, at the moment, the M-factors have been defined only to a limited number of substances in Annex VI of the CLP Regulation (mainly for pesticides and nickel compounds).

The work for determining M-factors will continue for several years under Chemicals legislation, based on scientific evidence. Thus the influence of M-

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FINLAND

National approach to assess H14 (ecotoxicity) of wastes

factors to waste management will be severely under-estimated, if the study is solely based on the already existing M-factors in Annex VI. The study should also estimate which substances are likely to have M-factors within the next years and evaluate their influence to classification of wastes as ecotoxic, to give a more truthful picture on the consequences to waste management. For example the future M-factors of metals/metal ions would very likely have a significant influence to the waste classification, and should be included into the study. There is already quite much scientific information available on the LC50-values of metals and metal ions, to give an estimation of the possible M-factors for these substances.

The test methods have a significant influence to the outcome of the tests. It should be specified if CLP test methods or waste specific CEN tests are to be used. For example, solubility of metals could be evaluated by CEN two stage batch test developed for wastes or by transformation/dissolution test developed for Chemicals classification. Also pre-treatment of samples has influence on the outcome of the results and should be specified.

Expert contacted to elaborate this factsheet

Eevaleena Häkkinen (Finnish Environmental Institute)

References Dahlbo, H. 2002. Jätteen luokittelu ongelmajätteeksi – arvioinnin perusteet ja menetelmät

(Classification of waste as hazardous waste – the basis and methods for evaluation). Environment Guide 98. Finnish Environment Institute. Helsinki. Finland. 160 pp. (In Finnish)

Ökopol GmbH (2008) Review of the European List of Waste, 532 pp.

Additional information

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FRANCE

National approach to assess H14 (ecotoxicity) of wastes

Type of approach(es) used in the country to assess H14 property of waste

Ecotoxicity testing –based approach

Combination of solid-phase tests and aquatic tests performed on water extracts from wastes.

Variability in H14 assessment methods depending on the waste nature

In the absence of legislation, two different approaches can be used in parallel, with no special predominance of one on the other :

- Initial “French” approach : documentation analysis of ecotoxic character of chemical substances in the waste, then (if negative) complementary toxicity tests (2 acute toxicity tests and 2 chronic toxicity tests)

- Combined “French and German” approach

Managers of waste treatment centres use the initial “French” approach from the FNADE guidance, whereas DREAL agencies (regional directions for environment, territory planning and housing) recommend since 2013 to use the combined approach.

Related legislation and guidelines

Legislation No specific legislation for H14 assessment

(Decree n°2002-540 of 2002, April 18th on Waste Classification – but no inputs concerning H14, only H3-H8, H10 and H11)

Decree of April 20th, 1994 transcripts the guideline Modified directive 67/548 on classification, packaging, stamping of hazardous components

Guidelines FNADE (2003) Methodological Guide - Waste Classification for a good direction of waste to appropriate storage centres – Appendix 3

MATE. Critères et méthodes d'évaluation de l'écotoxicité des déchets. Paris: Ministère de l'Aménagement du Territoire et de l'Environnement; 1998 [19 pp.].

Stakeholders involved in the H14 assessment

INERIS, ADEME, MEDDE (funding tests)

Laboratories performing ecotoxicity tests (the list is not exhaustive):

• INERIS (Institut National de l’environnement industriel et des risques)

• CARSO (Laboratoire Santé Environnement Hygiène de LYON)

• LIEBE (université de Lorraine

• Centre Technique du bois et de l’ameublement

• POLDEN Insavalor

• Eurofins

• SGS

Waste with highest Waste with highest tonnage Waste from construction : 71%, 246 Mt

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National approach to assess H14 (ecotoxicity) of wastes

tonnage

Hazardous waste with highest tonnage

19: Waste from waste treatment facilities, off-site waste water treatment plants and the water industry (41%, 4 Mt)

17 : Construction and demolition wastes (including road construction) (24%, 2.4 Mt)

Chapter of List of waste with the highest share of hazardous waste

07 : Wastes from organic chemical processes (51%, 1.2 Mt)

05 : Wastes from petroleum refining, natural gas purification and pyrolytic treatment of coal (46%, 51.6 kt)

Percentage of waste considered as hazardous by H14

Protocol used ecotoxic tests are applied

Prioritization of tests: aquatic vs terrestrial)

First step: aquatic tests, then terrestrial tests

Terrestrial tests on solid wastes

(1): “French” approach

(2): “Combined” approach

Test organism

Endpoint

Test method

Test duration

Expression of results

Threshold value

E. fetida (2) Avoidance

ISO 17512-1

48 hours EC 50 10%

E. fetida (1) Mortality

ISO 12 268-1

14 days EC 50 10%

Lactuca sativa (1) or Avena sativa / Brassica rapa (2)

Emergence and growth

ISO 11269-2

14 to 21 days

EC 50 10%

Arthrobacter globiformis (2)

Dehydrogenase activity

ISO/DIS 18187 11267

2 hours EC 50 10%

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National approach to assess H14 (ecotoxicity) of wastes

Leaching/extraction test used NF EN 12457-2

Aquatic tests

(1): “French” approach

(2): “Combined” approach

(3) alternative to the C. dubia reproduction test (FNADE 2003)

Test organism

Endpoint

Test method

Test duration

Expression of results

Threshold value

D. magna (1)(2)

Mobility

ISO 6341 24, 48 hours

EC 50 10%

Vibrio fischeri

(Microtox) (1)(2)

Luminescence

ISO 11348-3

30 minutes

EC 50 10%

Pseudokirchneriella subcapitata (1)(2)

Growth NF EN ISO 8692

3 days EC 20

EC 50

1%

10%

Ceriodaphnia dubia (1)

Reproduction

NF ISO 20665

7 days EC 20 1%

Brachionus calyciflorus (1)

Population growth

NF ISO 20666

48 hours EC 20 1%

No calculation methods are used

Illustrative examples Examples of results of ecotoxicological tests performed on waste eluates (unit: % eluate)

Nature of waste

Code pH or dilution for pH9.5

Microtox test

Daphnia EC50 48h test

Algae EC20 test

Ceriodaphnia EC20 test

Brachionus EC20 test

Mineral 06 05 7.9 No 42.7 0.7 2 0.7

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National approach to assess H14 (ecotoxicity) of wastes

chemistry WWTP sludge

02* or 06 05 03

inhibition

Hydroxy-metal chemistry sludge

06 05 02* or 06 05 03

9 >90 56.5 7 7.6 >80%

Fine chemistry sludge

07 07 11* or 07 07 12

8 3.3 51.9 1.5 0.5 0.6

Organic chemistry sludge

07 01 11* or 07 01 12

7.9 0.09 0.05 0.02 0.006 0.007

Organic chemistry sludge

07 01 11* or 07 01 12

8.2 0.038 0.061 0.058 0.061 0.063

MIDI 19 01 11* or 19 01 12

4.5% 15.2 59.5 2.6 5.1 3.55

Fine particulate matter

10 09 09* or 10 09 10

0.18% 0.4 0.95 0.2 0.08 0.3

Fine particulate matter

10 09 09* or 10 09 10

7.1 15 22.2 8.5 12.9 48.9

Foundry particulate matter

10 02 07* or 10 02 08

11.7 45.7 0.7 2.08 0.84 3.19

Foundry particulate matter

10 02 07* or 10 02 08

5.6% - 100% immobilisation

- - -

Filtration

10 03 19* or

0.18% 0.3 1.5 2.5 0.062 0.4

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National approach to assess H14 (ecotoxicity) of wastes

particulate matter (aluminium)

10 03 20

Soil polluted with lead and lindane

17 05 03* or 17 05 04

13.1 >90 >90 4.96 8.21 42.7

Soil polluted with lead and lindane

17 05 03* or 17 05 04

17.5% - 5% immobilisation

- - -

Soil polluted with lead and lindane

17 05 03* or 17 05 04

15% 11% inhibition

- - - -

MIOM 19 01 11* or 19 01 12

11.5 29.2 91.2 0.8 0.41 1.95

MIOM 19 01 11* or 19 01 12

3.4% - 90% immobilisation

- - -

MIOM 19 01 11* or 19 01 12

0.37% 4% inhibition

- - - -

Qualitative assessment of the method(s)

Advantages The experimental approach allows integrating the effects of all contaminants including additive, synergistic, and antagonistic effects of the components of the waste.

It is more relevant to implement the experimental approach than the summation method when the composition of the waste is known only partially

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National approach to assess H14 (ecotoxicity) of wastes

(which is a common situation for wastes). In addition, toxicity values are only available for a limited number of chemicals, which can significantly impede the use of the summation method.

It is the simplest way to assess HP14 because for calculation method we need to have a common protocol to find all the substances in a waste.

Ecotoxic testing is the best way to assess the ecotoxic hazard. Using calculation method without M-factors is not relevant for this criterion since M-factors are the factors for ecotox.

Limits and uncertainties There is a need to establish a link with regulators that address the management and disposal of hazardous wastes to estimate the impact of the implementation of this experimental approach on the outcome of the wastes classified as hazardous. Therefore, it would seem appropriate to propose a transitional period for the application of these threshold values in order to collect sufficient experimental data at a European level to conclude definitely on the suitability of the proposed threshold values.

The analytical method AFNOR XP X30-489 gives the exhaustive composition of the mineral elements and the organic substances. (Mineral) Elements must be speciated to mineral (and organomineral) substances. This speciation requires expert knowledge.

In most of the case “worst case” classification (with knowledge of the chelistry of the waste, but without speciation) gives evidence for reliable classification.

There is a need to have consistency between results from testing and results from the calculation method on which Commission works.

Approximate cost of the method(s) Variability depending on waste types (%)

3000 – 5000 euros

Other MS using the same approach (if known)

Germany

Additional comments

Expert contacted to elaborate this

Pascal Pandard (INERIS)

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National approach to assess H14 (ecotoxicity) of wastes

factsheet

References - Pandard P, Römbke J. 2013. Proposal for a “Harmonized” Strategy for the Assessment of the HP 14 Property. Integrated Environmental Assessment and Management 9(4): 665–672

- Pandard P, Devillers J, Charissou AM, Poulsen V, Jourdain MJ, Férard J‐F. Grand C, Bispo A. 2006. Selecting a battery of bioassays for ecotoxicological characterization of wastes. Sci Total Environ 363:114–125.

- FNADE (2003) Methodological Guide - Waste Classification for a good direction of waste to appropriate storage centres – Appendix 3

- Eurostat Data Centre on Waste

Additional information INERIS (2013) Guide de classement des déchets selon leur dangerosité suivant le Code de l’Environnement et la réglementation SEVESO II (partie applicable aux déchets). Rapport d’étude N°INERIS- DRC-12-125740-06310A, 66 pp.

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GERMANY

National approach to assess H14 (ecotoxicity) of wastes

Type of approach(es) used in the country to assess H14 property of waste

Combined method

Combination of solid-phase tests and aquatic tests performed on water extracts from wastes, if insufficient ecotoxicity data on individual components of the waste.

Variability in H14 assessment methods depending on the waste nature

The assessment of wastes is aligned on assessment under hazardous-substances legislation (CPD). Waste can thus be classified based on sufficient knowledge of its composition in terms of hazardous substances. Every waste which, based on its (known) composition, is to be classified and labelled in accordance with hazardous-substances law (H1 to H13) is considered hazardous waste.

In addition, if the composition of the waste is unknown or complex, biological test methods may be applied. The testing strategy includes a test battery with terrestrial and aquatic tests, but the proposed limit values have not been discussed in detail and no decision has been made to fix limit values.

Related legislation and guidelines

Legislation No specific legislation for H14 assessment : due to the Federal constitution the Federal States are the responsible authorities to enforce the regulations, if there is no legal instrument in place on national level - what is the case for H14

Closed Substance Cycle and Waste Management Act

Guidelines UbA (2013) Recommendations for the Ecotoxicological Characterization of Wastes

Moser, H. (2008) Handlungsempfehlungen zur ökotoxikologischen Charakterisierung von Abfällen. Entwurf.

German AVV (Abfallverzeichnisverordnung) (guide technique)

Guidelines on the Application of the Waste Catalogue Ordinance

Stakeholders involved in the H14 assessment

Federal Environment Agency Umweltbundesamt UbA (funding, organising, testing, communication)

ECT Oekotoxikologie GmbH (testing)

Waste with highest tonnage

Waste with highest tonnage

Waste from construction : 54%, 197 Mt

Hazardous waste with highest tonnage

19: Waste from waste treatment facilities, off-site waste water treatment plants and the water industry (34%, 6.9 Mt)

17 : Construction and demolition wastes (including road construction) (34%, 6.9 Mt)

Chapter of List of waste with the highest share of hazardous waste

05 : Wastes from petroleum refining, natural gas purification and pyrolytic treatment of coal (59%, 146 kt)

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National approach to assess H14 (ecotoxicity) of wastes

Percentage of waste considered as hazardous by H14

No data available on Federal level.

Protocol used ecotoxic tests are applied

Prioritization of tests: aquatic vs terrestrial)

First step: aquatic tests, then terrestrial tests

Terrestrial tests on solid wastes

Test organism

Endpoint Test method

Test duration

Expression of results

Threshold value

E. fetida Avoidance ISO 17512-1

48 hours EC 50 10%

E. fetida Avoidance ISO 12 268-1

14 days EC 50 10%

Brassica rapa

Emergence and growth

ISO 11269-2

14 days EC 50 10%

Arthrobacter globiformis

dehydrogenase activity

ISO 10187 6 hours EC 50 10%

Folsomia candida

Reproduction

ISO 11267 EC 50 10%

Leaching/extraction test used

DIN 12457-2, DIN 19528

Aquatic tests on eluates

Test organism Endpoint Test method

Test duration

Expression of results

Threshold value

D. magna Mobility ISO 6341 48 hours EC 50 10%

D. magna Mobility ISO 10706 21 days EC 50 10%

Vibrio fischeri (Microtox)

Luminescence inhibition

ISO 11348-1/2/3

30 minutes EC 50 10%

Pseudokirchneriella

Growth ISO 8692 72 h EC 50 10%

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subcapitata and Desmodesmus subspicatus

Lemna minor Growth ISO 20079 EC 50 10%

Calculation methods are used

Classification of the substance

Generic concentration limits (w/w %)

Concentration thresholds (for taking into account the substances in the combination equations)

R50 25 0,1

R50-53 0.25 0,1

R51-53 2.5 0,1

R52-53 25 1

R52 25 1

R53 25 1

R59 0.1 0,1

Combination equations

∑ ( PR50-53 ) ≥ 0.25

Or

∑ ( PR51-53 ) ≥ 2.5

Or

∑ ( PR52-53 ) ≥ 25

Or

∑ ( PR59 ) ≥ 0.1

Illustrative examples -

Qualitative assessment of the

Advantages The most complete battery of ecotoxic tests.

A combination of chemical and biological test methods

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method(s)

should be used for the ecotoxicological characterisation of wastes, since a comparison of the results of chemical analyses with existing threshold values is insufficient to derive the hazards posed by waste. Instead, an evaluation of the environmental hazards of waste is possible only by the use of biological test methods, as only these can mirror the effects of all bioavailable contaminants including their potential interactions as well as pollutants in waste which cannot be determined by chemical analysis.

Limits and uncertainties

Limit values are proposed but not legally fixed.

Approximate cost of the method(s) Variability depending on waste types (%)

Other MS using the same approach (if known)

France

Additional comments

Expert contacted to elaborate this factsheet

Dr. Joachim Wuttke (UbA)

Mr Daniel Laux (Um BWL)

References - UbA (2013) Recommendations for the Ecotoxicological Characterization of Wastes

- UbA (2014) Weiterentwicklung der UBA-Handlungsempfehlung zur ökotoxikologischen Charakterisierung von Abfällen, 170 pp.

- Ministerium für Umwelt und Verkehr Baden-Württemberg (2002) Zuordnung von Abfällen zu Abfallarten aus Spiegeleinträgen - Vorläufige Vollzugshinweise, 48 pp.

- Eurostat Data Centre on Waste

Additional information Römbke J, Moser T, Moser H (2009) Ecotoxicological characterisation of 12 incineration ashes using 6 laboratory tests, Waste Management 29:2475–2482

Wuttke J (2013) Einstufung von HMV-Schlacken im europäischen Abfallverzeichnis. Wissensforum, 20 pp.

Ökopol GmbH (2008) Review of the European List of Waste, 532 pp.

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National approach to assess H14 (ecotoxicity) of wastes

Type of approach(es) used in the country to assess H14 property of waste

Combined approach: chemical specific + toxicity based approach (notably for complex mixtures.)

The approach is the one provided by the “European Agreement concerning the International Carriage of Dangerous Goods by Road” (ADR) for class 9 (Miscellaneous dangerous substances and articles), M6 and M7 (pollutant to the aquatic environment, liquid and solid).

The classification of aquatic environmental hazards is tiered, and is dependent upon the type of information available for the waste itself and for its components.

The tiered approach considers the chemical analysis of waste with determination of the chemical composition and application of the summation method.

When the chemical analysis does not permit to identify the individual chemical species in the waste sample (chemical speciation) and/or to confirm the H14 classification with the biological approach, the following bioassays (Regulation 440/2008/EC) should be applied:

- Algal growth inhibition* (C3 method/OECD TG 201): 72 or 96 h ErC50

and/or

- Daphnia magna acute immobilization test (C2 method /OECD TG 202): 48 h EC50

and/ or

- Fish Acute tests (C1 method/OECD TG 203): 96 h LC50.

The limit values are shown in the table below.

Endpoint Limit values (Regulation 440/2008/EC)

72 or 96 h ErC50 for algae* >1 but ≤ 10 mg/L and/or

48 h EC50 for crustacea >1 but ≤ 10 mg/L and/or

96 h LC50 for fish >1 but ≤ 10 mg/L and/or

* other aquatic plants can be used

To avoid performing complete tests (with at least 5 concentrations) in order to calculate E(L)C50 with algae, daphnids or fish, our procedure provides for a preliminary limit test (100 mg/L). In case of positive results, a full study is conducted.

The waste (250 µm granulometry) sample is prepared as Water-Accomodated Fraction (WAF) (OECD n° 23 2000 Guidance Document on aquatic toxicity testing of difficult substances and mixtures) with a loading rate of 100 mg/L.

Variability in H14 assessment methods depending on the waste nature

When the composition of the waste is known, it is classified as ecotoxic if there are one or several hazardous substances identified by R50, R50-53, R51-53, R52, R52-53, R53 or R59 with concentrations equal or above the limit concentrations fixed by the DPD. When more than one hazardous substance is present the sum method is used to determine the final result. When the composition is unknown,

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National approach to assess H14 (ecotoxicity) of wastes

bioassays are used..

Related legislation and guidelines

Legislation - Legislative decree 152/2006 (part IV). It replaces the legislative decree 22/97.

- Law 28/2012 .This law has introduced the criteria for H14 assessment into the legislative decree 152/2006 (see point 5, Annex D part IV)

- ADR agreement (European Agreement Concerning the International Carriage of Dangerous Goods by Road)

Guidelines Parere ISPRA33/ISS sulla classificazione dei rifiuti ai fini dell'attribuzione della caratteristica di pericolo H14 "Ecotossico" Available at : http://www.iss.it/binary/ampp/cont/Ecotx_rf.pdf

Stakeholders involved in the H14 assessment

National and regional environment/health agencies: ISPRA, APPA, ARPA in 2 working groups.

Stakeholder role Name of stakeholder

Type of stakeholder (national authority, research institute, etc.)

Funding Producers

Control Authorities

Private Organizations

National/Regional Authorities

Performing the test(s),

Laboratories Private and Regional EPA

Providing waste samples

Producers

Control Authorities

Private organization

National Authority

Waste with highest tonnage

Type or category or code of waste

Annual tonnage (metric tonnes)

Share (%)

Among hazardous waste

Wastes from waste management

2,96 Mtonnes in 2012

31,7 of hazardous waste

33 ISPRA is a Public Institute which acts under the vigilance and policy guidance of the Italian Ministry for the Environment and the Protection of Land and Sea (MATTM, Ministero dell’Ambiente e della Tutela del Territorio e del Mare). ISPRA belongs to a national network known as Environmental Agency System. Currently, in Italy there are 21 Environmental Regional (ARPA) and Provincial (APPA) Agencies, which are coordinated by ISPRA. One of the aim of the ISPRA Environmental Metrology Unit is the organization of interlaboratory exercises in order to validate chemical and biological methods and technical procedures (www.isprambiente.org).

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facilities, off-site waste water treatmentplants and the preparation of water (chapter 19 of European LoW)

generated from economic activities

Among total waste

Construction and demolition wastes(chapter 17 of European LoW)

52,48 Mtonnes in 2012

39,1 of total waste generated from economic activities

Percentage of waste considered as hazardous by H14

Share of waste assessed positive for the H14 criteria, globally and by category: information not available at country level

Protocol used Ecotoxic tests are applied

Leaching tests : EN14735Aquatic tests

Test organism Endpoint Test method

Test duration

Expression of results

Threshold value34

V. Fischeri UNI EN ISO 11348

Acute (5-15-30 min)

EC50 <10%

P. subcapitata ; D. subspicatus

UNI EN ISO 8692

Chronic (72h)

EC20, EC50

<20%

D. magna (C2) UNI EN ISO 6341

Acute (48h)

EC50 <10%

Calculation methods are used

When the composition of the waste is known, it is classified as ecotoxic if there are

34 10% and 20% when compared with an eluate prepared following the norm UNI EN 14735:2005:

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one or several hazardous substances identified by R50, R50-53, R51-53, R52, R52-53, R53 or R59 with concentrations equal or above the limit concentrations fixed by the DPD

Classification of the substance

Generic concentration limits (w/w %)

Concentration thresholds (for taking into account the substances in the combination equations)

R50 25 0,1

R50-53 0.25 0,1

R51-53 2.5 0,1

R52-53 25 1

R52 25 1

R53 25 1

R59 0.1 0,1

*P= percentage of weight

Combination of hazardous components concentration

Threshold value

1st step Σ(PR50-53/0,25 + PR51- 53/2,5 + PR52-

53/25 )≥ 1

2nd step Σ(PR50+ PR50- 53) ≥ 25%

3rd step Σ(PR52) ≥ 25%

4th step Σ(PR50-53 + PR51- 53 + PR52-53 + PR53 ) ≥ 25%

Illustrative examples -

Qualitative assessment of the method(s)

Advantages none as declared by CA

Limits and uncertainties 1) The limit values are expressed in mg/L. The

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National approach to assess H14 (ecotoxicity) of wastes

previous standards EN 14735 and 12457-2 are not applicable. Waste samples for ecotoxicity testing should be prepared as independent WAFs (OECD n° 23, 2000 Guidance Document on aquatic toxicity testing of difficult substances and mixtures, paragraph 3.11, pp 36-37)

2) A WAF with loading rate of 100 mg/L has a 10.000:1 L/S ratio.

3) According to ADR, waste samples need to be tested for ecotoxicity have a very small mass (100 mg or less). The problem of waste sample representativeness was studied using Pierre Gy sampling equation:

m= 16π⋅d3⋅s⋅ρd⋅g ⋅ (1 - p )

(CV )2⋅p

s= particles shape; r= particles mean density; d= particles diameter

This equation correlates the mass (m) of (sub)sample with the variability (coefficient of variation, CV) of subsampling. The equation is used to calculate the minimum amount of sample (m) with a specific granulometry (g) keeping the uncertainty within a CV value of 20% (table below).

Granulometry (µm) Waste mass (mg)

250 80-100

125 10

As shown in the table, a particle size reduction to 250 m is needed in order to take a sample of 80-100 mg (CV= 20%).

Nevertheless, a collaborative study organized by ISPRA with 23 Italian laboratories demonstrated that our approach does not provide acceptable repeatability and reproducibility values (Sr% and SR%) with algal test (See: D. Conti, P. De Zorzi, S. Balzamo, S. Barbizzi, S. Rosamilia, C. Martone, A. Pati, T. Guagnini, A. Paina, E. Raso, V. Bellaria (2014) Studio collaborativo ecotossicologico su lisciviato di rifiuto mediante saggi con P. subcapitata e D. magna. In press).

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4) Waste often have low economic value. Evaluation of H14 property should be performed with rapid, easy to perform, convenient and inexpensive tests. Toxicity testing with fish do not have these characteristics. Moreover, the tests with vertebrates raise ethical and economic concerns and many regulatory frameworks (e.g. REACH) principally encourage the use of alternative approaches

5) Chemical analysis and biological tests: the results of the two approaches often are different and lead to different classification of the waste.

The same limits and uncertainties can be also highlighted in case of CLP application.

Approximate cost of the method(s) Variability depending on waste types (%)

Chemical analysis 100-1000 € (depending on number and type of analysis)

Biological methods 800 € (test battery: alga, crustacean and fish)

Other MS using the same approach (if known)

Additional comments

Expert contacted to elaborate this factsheet

Stefania Balzamo – [email protected]; Andrea Paina – [email protected]; Daniela Conti – [email protected]; Cristina Martone – [email protected]; Elisa Raso – [email protected]; Andrea Lanz – [email protected];

References There are no official guidelines or specific protocols for H14 property of waste, but there are the following studies (only in Italian language) concerning the application of ADR approach:

Information on quantities produced by specific waste codes:

Annual publications of ISPRA on production and management of municipal waste and waste from economic activities. Publications are available on ISPRA website at:

http://www.isprambiente.gov.it/it/pubblicazioni/rapporti (available only in Italian language)

Composition data of specific wastes:

Study on fluff-light fraction from crushing of vehicles:

Report ISPRA 2002 http://www.isprambiente.gov.it/contentfiles/00003800/3897-rapporti-02-16.pdf/view (available only in Italian language)

Report ISPRA 2006 http://www.isprambiente.gov.it/contentfiles/00004100/4158-rapporto-veicoli-2007-marzo-2008.pdf/view (available only in Italian language)

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ITALY

National approach to assess H14 (ecotoxicity) of wastes

Procedures and results of ecotoxicological tests:

S. Balzamo, D. Conti, M. Belli et al. (2008) Caratterizzazione ecotossicologica dei rifiuti: risultati italiani del circuito d’interconfronto europeo organizzato dall’Agenzia tedesca per la Protezione dell’Ambiente. Rapporti ISPRA 81/2008.

D. Conti, P. De Zorzi, S. Balzamo, S. Barbizzi, S. Rosamilia, C. Martone, A. Pati, T. Guagnini, A. Paina, E. Raso, V. Bellaria (2014) Studio collaborativo ecotossicologico su lisciviato di rifiuto mediante saggi con P. subcapitata e D. magna. Final Report ISPRA (in press).

Batterie di test per la caratterizzazzione ecotossicologica dei rifiuti: Stato dell’arte ; Parere ISPRA/ISS sulla classificazione dei rifiuti ai fini dell'attribuzione della caratteristica di pericolo H14 "Ecotossico" Available at : http://www.iss.it/binary/ampp/cont/Ecotx_rf.pdf

A. Paina, D. Conti, S. Balzamo, A. Pati, C. Martone (2013) I rifiuti e la pericolosità per l’ambiente (H14): evoluzione normativa e quadro di riferimento. Atti di Giornate di Studio Livorno 5a edizione, “Ricerca e applicazione di metodologie eco tossicologiche in ambienti acquatici e matrici contaminate” Livorno 7-9 novembre 2013 pp. 194-200.

D. Conti, S. Balzamo, A. Paina, A. Pati, C. Martone, V. Bellaria (2013) Valutazione della pericolosità per l’ambiente dei rifiuti (H14): definizione della procedura analitica. Atti di Giornate di Studio Livorno 5a edizione, “Ricerca e applicazione di metodologie ecotossicologiche in ambienti acquatici e matrici contaminate” Livorno 7-9 novembre 2013 pp. 201-207.

D. Conti, P. De Zorzi, S. Balzamo, S. Barbizzi, S. Rosamilia, C. Martone, A. Pati, T. Guagnini, A. Paina, E. Raso, V. Bellaria (2014) Studio collaborativo ecotossicologico su lisciviato di rifiuto mediante saggi con P. subcapitata e D. magna. Rapporto finale ISPRA (in press)

A. Paina, D. Conti, C. Martone, A. Pati, E. Raso e S. Balzamo (2014) La determinazione della pericolosità per l’ambiente acquatico dei rifiuti (H14): definizione della procedura analitica per l’esecuzione di test biologici in accordo con il Regolamento CE 1272/2008. Ecomondo 2014, Rimini 5-8 November 2014, pp. 194-198

Additional information

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SPAIN

National approach to assess H14 (ecotoxicity) of wastes

Type of approach(es) used in the country to assess H14 property of waste

Ecotoxicity tests

Two bioassays of luminescence and inhibition on leaching extracts

Variability in H14 assessment methods depending on the waste nature

Waste from veterinary products follow a different law.

Related legislation and guidelines

Legislation Ley 22/2011, de 28 de julio, de residuos y suelos contaminados

ORDEN de 13 de octubre de 1989 por la que se determinan los métodos de caracterización de los residuos tóxicos y peligrosos

ORDEN MAM/304/2002, de 8 de febrero - Anejo 2 (“no contiene en la actualidad disposiciones respecto a las características H1, H2, H9 y H12 a H14”)

Guidelines ORDEN de 13 de octubre de 1989 por la que se determinan los métodos de caracterización de los residuos tóxicos y peligrosos –Appendice IV and A

Stakeholders involved in the H14 assessment

ATEGRUS (Asociación Técnica para la Gestión de Residuos, Aseo Urbano y Medio Ambiente

INTERLAB

Waste with highest tonnage

Waste with highest tonnage Waste from construction : 22%, 26.1 Mt

Waste from mining and quarrying : 19%, 22.5 Mt

Hazardous waste with highest tonnage

Manufacture industry : 97.7% of hazardous waste generated in Spain (1 345 kt on 1 376 kt), and among them:

- Waste from metal and non-metal industry : 57.8%, 795 kt

- Waste from organic chemistry : 38.3%, 527.34 kt

- Acidic, alkaline and salt waste : 23%, 316.3 kt

From Eurostat data:

10-11-12 : Inorganic wastes from thermal processes + Inorganic metal-containing wastes from metal treatment and the coating of metals, and non-ferrous hydrometallurgy + Wastes from shaping and surface treatment of metals and plastics (36%, 751.6 kt)

19 : Waste from waste treatment facilities, off-site

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SPAIN

National approach to assess H14 (ecotoxicity) of wastes

waste water treatment plants and the water industry (26%, 530.7 kt)

Chapter of List of waste with the highest share of hazardous waste

05 : Wastes from petroleum refining, natural gas purification and pyrolytic treatment of coal (49%, 66.8 kt)

07 : Wastes from organic chemical processes (40%, 414 kt)

Percentage of waste considered as hazardous by H14

Approximately 20%

Protocol used

Ecotoxicity tests are applied

Prioritization of tests (aquatic vs terrestrial)

Only aquatic tests on leaching extracts

Leaching/extraction test used UNE 12457-2

Aquatic tests

Test organism

Endpoint

Test method

Test duration

Expression of results

Threshold value

Vibrio fischeri35

luminescence

UNE 11348

15’-30’ EC50 3000 mg/l

Daphnia magna

mobility

OECD-202

UNE 6341

24-48H CL50/ EC50

750 mg/l

No calculation methods are used

Illustrative examples -

Qualitative assessment of the method(s)

Advantages Spain highlights that there are often problems due to the fact that wastes are complex matrices (coloured, oily, particulates, precipitates, etc.). Considering that often the ecotoxicity test is the only real bioassay performed on waste, as it is by far the cheapest, it seems reasonable to use a

35 Named Photobacterium phosphoreum in the Order of 13/10/1989

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SPAIN

National approach to assess H14 (ecotoxicity) of wastes

test battery. The applied toxicity tests (Daphnia magna, Vibrio fischeri) are relatively economic and simple. The Daphnia test is in general considered to be more ecologically relevant.

Limits and uncertainties Confusion in the interpretation: concentrations expressed in terms of the amount of residue of departure or in terms of the leachate (an order of magnitude difference between the two interpretations [x 10]). Lack of clarity in relation to the scientific support of limits.

Approximate cost of the method(s) Variability depending on waste types (%)

Unknown

Other MS using the same approach (if known)

None.

Similar: France – Uses only Ecotoxicity tests to assess H 14. However, France includes terrestrial tests in its test battery while Spain does not.

Additional comments

Expert contacted to elaborate this factsheet

Joan Parés Gómez, TECNOAMBIANTE SL

References - Jaureguízar J, Dueñas L, John E (2007) Evaluación de metodologías para la caracterización de residuos como peligrosos o no peligrosos, Residuos 101, 18-26.

- ORDEN de 13 de octubre de 1989 por la que se determinan los métodos de caracterización de los residuos tóxicos y peligrosos –Appendice IV and A

- Residuos Industriales en España INE, 2003 (2000)

- Eurostat Data Centre on Waste

Additional information Ökopol GmbH (2008) Review of the European List of Waste, 532 pp.

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UNITED KINGDOM

National approach to assess H14 (ecotoxicity) of wastes

Type of approach(es) used in the country to assess H14 property of waste

Calculation method with limit value

Assessment of H14 based on the composition of the waste with regards to hazardous substances. The UK approach considers only the hazards to the aquatic environment (R50 to R53) and to the ozone layer (R59)

In practice, this is a calculation method based on the Dangerous Preparations Directive. It could also be presented as a combined approach.

UK differs from the DPD in that they do not assign substance specific concentration limits (SCL’s) to all R50-53 substance as set out in Part B of Annex III. They apply only those SCL’s listed in Table 3.2 of the CLP.

Ecotoxicity testing is legally permitted in accordance with Annex VI of the Dangerous Substances Directive. This approach would normally be applied to substances (rather than preparations), can only modify the result of the calculation method for a preparation, and is limited by the need for vertebrate testing. So in practice, ecotoxicity testing of most wastes would not be appropriate where the calculation method can be used instead.

Variability in H14 assessment methods depending on the waste nature

WM2 emphasises the use of compositional data to assess ecotoxicity (as used for the assessment of other hazardous properties) and discourages direct ecotoxicity testing on organisms wherever possible: “A H14 assessment should normally be done by reference to concentration limits of the substances in the waste. There will be a few cases when this is not possible, for example the substances in particularly complex wastes may be difficult to determine exactly. It is then possible to test these wastes for H14”. In those specific cases (when the chemical composition of the waste is unknown or when the waste contains substances whose toxicity is not already known), bioassays can be used and the approach consists of an eluate testing without dilution coupled to an inhibition essay on Daphnia magna’ s mobility (48h) and on algal growth (72h).

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UNITED KINGDOM

National approach to assess H14 (ecotoxicity) of wastes

Related legislation and guidelines

Legislation No specific legislation for H14 assessment

The Hazardous Waste (England and Wales) Regulations 2005

Guidelines Environment Agency (2013) WM2: Hazardous waste Interpretation of the definition and classification of hazardous waste (3rd Edition 2013), 147 pp.

University of Birmingham (2014) Health and Safety Guidance - Hazardous Waste: Guidance on Assessment GUIDANCE/11/HWGA/14, 32 pp.

Stakeholders involved in the H14 assessment

Environmental Service Association ESA, Defra (funding)

Producers of waste (performing the assessment)

WRc (performing the assessment)

Waste with highest tonnage

Waste with highest tonnage

Waste from construction : 41%, 99 Mt

Hazardous waste with highest tonnage

19: Waste from waste treatment facilities, off-site waste water treatment plants and the water industry (30%, 1.9 Mt)

20: Municipal wastes and commercial, industrial and institutional wastes including separately collected fractions (21%, 1.3Mt)

Chapter of List of waste with the highest share of hazardous waste

05 : Wastes from petroleum refining, natural gas purification and pyrolytic treatment of coal (82%, 154 kt)

Percentage of waste considered as hazardous by H14

Unknown

Protocol used

No ecotoxicity tests are applied (the practice is possible in theory, when calculation methods cannot be applied, but is highly discouraged)

Calculation methods are used

Classification of the substance

Generic concentration limits (w/w %)

Concentration thresholds (for taking into account the substances in the combination equations)

R50 25 0,1

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UNITED KINGDOM

National approach to assess H14 (ecotoxicity) of wastes

R50-53 0.25 0,1

R51-53 2.5 0,1

R52-53 25 1

R52 25 1

R53 25 1

R59 0.1 0,1

Combination equations

∑ (R50−53

0.25+R51−53

2.5+R52−53

25)

≥ 100% (=1)

∑ (R50+R50−53) ≥ 25%

∑ R52≥ 25%

∑ (R53+R50−53+R51−53+R52−53) ≥ 25%

Illustrative examplesExample 1: A waste contains 2 substances given R50-53. Substance A = 0.2%, Substance B = 0.9%. Neither substance is given a specific threshold in Annex VI table 3.2. Both substances exceed the generic cut-off values (0.1%).

Using Equation 1: ∑ (R50−53

0.25+R51−53

2.5+R52−53

25) ≥ 1 (

0.20.25

+ 0.90.25

) +0 +

0 = 4.4 ≥ 1 → this waste is hazardous by H14

Example 2: A waste contains 2 substances. Substance C = 18% is given R50; substance D = 12% is given R53. Neither substance is given a specific threshold in Annex VI table 3.2. Both substances exceed the generic cut-off values (0.1% for R50 and 1% for R53).

Using Equation 2:

∑ (R50+R50−53) (18%) + 0% = 18% ≤ 25% → this waste is not hazardous by

H14

Using Equation 4:

∑ (R53+R50−53+R51−53+R52−53) (12%) + 0% + 0% + 0% = 12%≤ 25% →

this waste is not hazardous by H14

Example 3: A waste contains 4 substances. Substance F = 0.09% is given R50-53, substance G =

0.08% is given R51-53, Substances H = 17%, I = 14% are given R53. None of the substances is given a specific threshold in Annex VI table 3.2. Substance F and G are below the generic cut-off values (0.1% for both) so are not included in the

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UNITED KINGDOM

National approach to assess H14 (ecotoxicity) of wastes

calculations. Substances H and I exceed the cut-off values (1%).

Using Equation 4:

∑ (R53+R50−53+R51−53+R52−53) (17% + 14%) + 0% + 0% + 0% = 31%

≥25% → this waste is hazardous by H14.

Qualitative assessment of the method(s)

Advantages The advantages are that as a calculation method

• It can normally be performed using the same sampling and chemical analysis used for other hazardous properties (no additional analysis)

• It does not involve testing on living animals

• It is similar to that used for products, so the classification of a product under the DPD as Ecotoxic can normally be relied upon by small businesses to indicate that H14 is likely to apply when that product becomes a waste. One stakeholder has advocated that the method selected should be as close to the CLP as possible to maximise the simplification this last point provides for customers. As indicated previously, the use of direct testing is limited by the legislative regime and limitations of test methods with respect to difficult materials. However in certain circumstances (particularly for simpler, soluble wastes, or for pure substances) it may have some advantages.

UK points out that the calculation methodology set forth in the national Chemical Regulations (CHIP) and the Dangerous Preparations Directive (DPD) supported by chemical analysis is clear and highly satisfactory. It aligns directly with chemical risk phrase classification systems and therefore with other hazardous properties. UK holds the view that animal testing of solid wastes is of little or no scientific value and generates results of debatable significance. Testing is described as of often poor quality, overlooks key criteria in relevant guidance, and results often suggest that the waste is non-hazardous where that is clearly not the case. UK assumes that in more than one case the analysis appears to have been undertaken principally because chemical analysis would show the waste to be hazardous, so ecotoxicity testing is being used (badly) in an attempt to obtain a different result.

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UNITED KINGDOM

National approach to assess H14 (ecotoxicity) of wastes

Limits and uncertainties Our approach has similar limits and uncertainties to the DPD.

The omission of SCL’s for all R50-53 substances means that the calculation method will underestimate the ecotoxicity of a waste (relative to the DPD) when very ecotoxic substances are present.

The reliability of the calculation method is dependent on

• Appropriate sampling in accordance with CEN 14899 and supporting technical reports,

• Determination of the chemical composition of the components (to a level sufficient to assess H14) by analysis, and

• Correctly identifying the classification of the components using Table 3.2 of the CLP, the REACH registered substances database, and other appropriate datasources.

Appropriate sampling of materials, particularly from processes producing variable and heterogenous batches over time, can be the key factor. This can be a significant part of the cost.

Analysis can be more challenging in complex matrices, and the analytical uncertainties need to be understood before results are interpreted. The balance often has to be found between determining the speciation of the chemical OR using a worst case compound.

Approximate cost of the method(s) Variability depending on waste types (%)

The sampling and chemical analysis of the waste is used to support the assessment of several hazardous properties. The use of the calculation method for H14 would not normally generate a separate (additional) cost.

One stakeholder has advised UK EA that ecotoxicity tests range from £650 to £2000 per test, depending on the OECD test method.

Another has indicated that analysis of chemical compositions is approximately £150 per sample, with the calculation taking about 30 minutes for a competent person. They indicate that ecotoxicity testing is more expensive.

Again, where the method is very close the product legislation – sampling, analysis and calculation may be not be necessary, if the safety data sheet for that product has already completed the assessment. This may reduce

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UNITED KINGDOM

National approach to assess H14 (ecotoxicity) of wastes

cost.

Other MS using the same approach (if known)

Finland

Additional comments The successful assessment of a waste to determine its classification is highly dependent on the reliable and representative sampling of the material. The application of CEN 14899 on waste characterisation and its supporting technical reports is central to this.

One of our stakeholders has made us aware of the CONCAWE aquatic toxicity test procedure in ‘Hazardous classification and labelling of petroleum substances in the European Economic Area -2014’. We would recommend seeking advice from ECHA on the relevance of this to CLP classification of oils (and therefore oil contaminated waste)

When evaluating waste streams for this study we recommend you

- Determine their full composition, and

- Assess all hazardous properties

To determine the impact of H14.

Although a calculation method is most appropriate, this should be supported by ecotoxicity testing where appropriate. This would need to be performed in accordance with the CLP and supporting ECHA guidance on its application. Use of a calculation method similar to that of the CLP would be needed to enable CLP test methods to be used in parallel. The performance of the Ecotoxicity method on difficult substances is an important consideration.

Expert contacted to elaborate this factsheet

Bob McIntyre, UK EA

References - Environment Agency (2013) WM2: Hazardous waste Interpretation of the definition and classification of hazardous waste (3rd Edition 2013), 147 pp.

- Eurostat Data Centre on Waste

Additional information

WRc (2012) Assessment of Hazard Classification of UK IBA, 69 pp.

Ökopol GmbH (2008) Review of the European List of Waste, 532 pp.

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Annex 3. Second questionnaire sent to Competent Authorities36

Information for consolidation of waste codes selectionPlease provide your answers directly in the table included in the next pages (pp4 – 11). The first line of the table shows an example on how to include available data.

1. Economic importance of waste codes

Please specify which waste codes you consider important, regarding the following parameters:

Please report the letter a, b or c in column 3 of the table.

a. Waste to energy recovery (please specify the percentage)b. Waste to material recovery (please specify the percentage)c. High generated volumes (please specify the tons)

2. Potential presence of hazardous substances

Please specify the nature and indicative concentrations of hazardous substances contained in waste streams falling under the listed waste codes.

Please fill in column 4 of the table.

3. Criticality of the waste classification

The new classification methods for HP 14 shall be based on calculations using the presence and the quantities of intrinsically ecotoxic substances in the waste, i.e. those classified under the following CLP H-codes: H420 (ozone depleting), H400 (aquatic acute), H410 (aquatic chronic 1), H411 (aquatic chronic 2), H412 (aquatic chronic 3) and H413 (aquatic chronic 4).

For which mirror entries do you think that waste streams currently classified as non-hazardous are likely to shift to being classified as hazardous (due to a change of classification methods)?

Please write, per code, “Yes” in column 5 in you think the shift as likely and “No” otherwise. Please indicate in column 6 which substances (along with their CLP H-codes) are responsible for this potential shift.

Your opinion on the selected mirror pairs1. Background: the selection process

The selection process is based on six selection criteria (SC):

SC 1 - Preference of experts 36 The list of selected pairs presented in the questionnaire is slightly different from the list reported in section 5.2 of this report. This is because data received in the wake of the consultation with the second questionnaire changed the scores for some waste codes.

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SC 2 - Availability and quality of data

SC 3 - Tonnage of waste production

SC 4 - Economic importance

SC 5 - Potential presence of hazardous substances

SC 6 - Criticality of waste classification

Waste codes are attributed scores for each SC (calculated from data from the first questionnaire to stakeholders and from a desk study) and then a global score is calculated for each waste code by computing a weighted average of all scores:

Selection criteria Weight Selection criteria WeightSC1 3 SC4 1SC2 3 SC5 1SC3 2 SC6 2

After normalisation, all waste codes with a global score higher than 1.5 are selected. If one code of the mirror pair is not included in the list, this mirror pair is nonetheless chosen.

2. Selected pairs

Please find below our first selection of waste pairs, as a categorised list.

03 Wastes from wood processing and the production of panels and furniture, pulp, paper and cardboard03 01 wastes from wood processing and the production of panels and furniture

03 01 04* 03 01 05 sawdust, shavings, cuttings, wood, particle board and veneer

10 Wastes from thermal processes

10 01 wastes from power stations and other combustion plants (except 19)10 01 16* 10 01 17 fly ash from co-incineration10 02 wastes from the iron and steel industry10 02 07* 10 02 08 solid wastes from gas treatment10 02 13* 10 02 14 sludges and filter cakes from gas treatment10 03 wastes from aluminium thermal metallurgy10 03 19* 10 03 20 flue-gas dust17 Construction and demolition wastes (including excavated soil from contaminated sites)17 03 bituminous mixtures, coal tar and tarred products17 03 01* 17 03 02 bituminous mixtures17 05 soil (including excavated soil from contaminated sites), stones and dredging spoil17 05 03* 17 05 04 soil and stones17 05 05* 17 05 06 dredging spoil19 Wastes from waste management facilities, off-site waste water treatment plants and the preparation of water intended for human consumption and water for industrial use19 01 wastes from incineration or pyrolysis of waste19 01 11* 19 01 12 bottom ash and slag19 01 13* 19 01 14 fly ash19 08 wastes from waste water treatment plants not otherwise specified19 08 11* 19 08 12 sludges from biological treatment of industrial waste water19 08 13* 19 08 14 sludges from other treatment of industrial waste water

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Do you think other waste codes should be included in the list? If so, please provide the codes and the reason why they should be included (mention the relevant selection criteria):

Codes to add Reason

Experimental data on selected waste pairsWe need experimental data (chemical composition and results of ecotoxicity tests) of waste samples classified under one or the other code of the selected mirror pairs.

The attached Excel file presents and explains the data we need to perform the assessment. Could you please fill in the tables or provide us with reports/databases containing the requested information?

If you do not have the experimental data yourself, could you please redirect us to people who do:

Contacts: ____________________________________________________________

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Waste code Waste description Economic importance

Potential presence of hazardous substances

Criticality of waste classification

Likely to shift to dangerous?

Rationale for the shift

XX XX XX Example a. (35%)Zinc hydroxide (0.2%)Lead (0.05%)

Yes Presence of As (H410)

03 01 04*

sawdust, shavings, cuttings, wood, particle board and veneer containing hazardous substances

03 01 05

sawdust, shavings, cuttings, wood, particle board and veneer other than those mentioned in 03 01 04

04 02 19*

sludges from on-site effluent treatment containing hazardous substances

04 02 20

sludges from on-site effluent treatment other than those mentioned in 04 02 19

06 03 15*metallic oxides containing heavy metals

06 03 16metallic oxides other than those mentioned in 06 03 15

06 05 02*

sludges from on-site effluent treatment containing hazardous substances

06 05 03

sludges from on-site effluent treatment other than those mentioned in 06 05 02

07 01 11*

sludges from on-site effluent treatment containing hazardous substances

07 01 12

sludges from on-site effluent treatment other than those mentioned in 07 01 11

07 02 11*

sludges from on-site effluent treatment containing hazardous substances

07 02 12

sludges from on-site effluent treatment other than those mentioned in 07 02 11

07 03 11*

sludges from on-site effluent treatment containing hazardous substances

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Waste code Waste description Economic importance

Potential presence of hazardous substances

Criticality of waste classification

07 03 12

sludges from on-site effluent treatment other than those mentioned in 07 03 11

07 05 11*

sludges from on-site effluent treatment containing hazardous substances

07 05 12

sludges from on-site effluent treatment other than those mentioned in 07 05 11

07 06 11*

sludges from on-site effluent treatment containing hazardous substances

07 06 12

sludges from on-site effluent treatment other than those mentioned in 07 06 11

08 01 13*

sludges from paint or varnish containing organic solvents or other hazardous substances

08 01 14

sludges from paint or varnish other than those mentioned in 08 01 13

08 03 12* waste ink containing hazardous substances

08 03 13waste ink other than those mentioned in 08 03 12

08 03 14* ink sludges containing hazardous substances

08 03 15ink sludges other than those mentioned in 08 03 14

08 04 11*

adhesive and sealant sludges containing organic solvents or other hazardous substances

08 04 12

adhesive and sealant sludges other than those mentioned in 08 04 11

10 01 14*

bottom ash, slag and boiler dust from co-incineration containing hazardous substances

10 01 15

bottom ash, slag and boiler dust from co-incineration other than those mentioned in 10 01 14

10 01 16*fly ash from co-incineration containing hazardous substances

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Potential presence of hazardous substances

Criticality of waste classification

10 01 17

fly ash from co-incineration other than those mentioned in 10 01 16

10 01 18*wastes from gas cleaning containing hazardous substances

10 01 19

wastes from gas cleaning other than those mentioned in 10 01 05, 10 01 07 and 10 01 18

10 02 07*solid wastes from gas treatment containing hazardous substances

10 02 08

solid wastes from gas treatment other than those mentioned in 10 02 07

10 02 11*wastes from cooling-water treatment containing oil

10 02 12

wastes from cooling-water treatment other than those mentioned in 10 02 11

10 02 13*

sludges and filter cakes from gas treatment containing hazardous substances

10 02 14

sludges and filter cakes from gas treatment other than those mentioned in 10 02 13

10 03 19*flue-gas dust containing hazardous substances

10 03 20flue-gas dust other than those mentioned in 10 03 19

10 03 23*solid wastes from gas treatment containing hazardous substances

10 03 24

solid wastes from gas treatment other than those mentioned in 10 03 23

10 03 25*

sludges and filter cakes from gas treatment containing hazardous substances

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Potential presence of hazardous substances

Criticality of waste classification

10 03 26

sludges and filter cakes from gas treatment other than those mentioned in 10 03 25

10 03 29*

wastes from treatment of salt slags and black drosses containing hazardous substances

10 03 30

wastes from treatment of salt slags and black drosses other than those mentioned in 10 03 29

10 05 10*

dross and skimmings that are flammable or emit, upon contact with water, flammable gases in hazardous quantities

10 05 11dross and skimmings other than those mentioned in 10 05 10

10 06 09*wastes from cooling-water treatment containing oil

10 06 10

wastes from cooling-water treatment other than those mentioned in 10 06 09

10 08 15*flue-gas dust containing hazardous substances

10 08 16flue-gas dust other than those mentioned in 10 08 15

10 08 17*

sludges and filter cakes from flue-gas treatment containing hazardous substances

10 08 18

sludges and filter cakes from flue-gas treatment other than those mentioned in 10 08 17

10 08 19*wastes from cooling-water treatment containing oil

10 08 20

wastes from cooling-water treatment other than those mentioned in 10 08 19

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Potential presence of hazardous substances

Criticality of waste classification

10 09 05*

casting cores and moulds which have not undergone pouring containing hazardous substances

10 09 06

casting cores and moulds which have not undergone pouring other than those mentioned in 10 09 05

10 09 07*

casting cores and moulds which have undergone pouring containing hazardous substances

10 09 08

casting cores and moulds which have undergone pouring other than those mentioned in 10 09 07

10 09 11*other particulates containing hazardous substances

10 09 12other particulates other than those mentioned in 10 09 11

10 09 13*waste binders containing hazardous substances

10 09 14waste binders other than those mentioned in 10 09 13

10 10 05*

casting cores and moulds which have not undergone pouring, containing hazardous substances

10 10 06

casting cores and moulds which have not undergone pouring, other than those mentioned in 10 10 05

10 10 07*

casting cores and moulds which have undergone pouring, containing hazardous substances

10 10 08

casting cores and moulds which have undergone pouring, other than those mentioned in 10 10 07

10 10 09*flue-gas dust containing hazardous substances

10 10 10flue-gas dust other than those mentioned in 10 10 09

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Potential presence of hazardous substances

Criticality of waste classification

10 10 11*other particulates containing hazardous substances

10 10 12other particulates other than those mentioned in 10 10 11

10 10 13*waste binders containing hazardous substances

10 10 14waste binders other than those mentioned in 10 10 13

10 11 09*

waste preparation mixture before thermal processing, containing hazardous substances

10 11 10

waste preparation mixture before thermal processing, other than those mentioned in 10 11 09

10 11 15*

solid wastes from flue-gas treatment containing hazardous substances

10 11 16

solid wastes from flue-gas treatment other than those mentioned in 10 11 15

10 12 09*solid wastes from gas treatment containing hazardous substances

10 12 10

solid wastes from gas treatment other than those mentioned in 10 12 09

10 13 12*solid wastes from gas treatment containing hazardous substances

10 13 13

solid wastes from gas treatment other than those mentioned in 10 13 12

11 01 09*sludges and filter cakes containing hazardous substances

11 01 10sludges and filter cakes other than those mentioned in 11 01 09

12 01 14*machining sludges containing hazardous substances

12 01 15machining sludges other than those mentioned in 12 01 14

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Potential presence of hazardous substances

Criticality of waste classification

12 01 16*waste blasting material containing hazardous substances

12 01 17waste blasting material other than those mentioned in 12 01 16

16 11 01*

carbon-based linings and refractories from metallurgical processes containing hazardous substances

16 11 02

carbon-based linings and refractories from metallurgical processes others than those mentioned in 16 11 01

16 11 03*

other linings and refractories from metallurgical processes containing hazardous substances

16 11 04

other linings and refractories from metallurgical processes other than those mentioned in 16 11 03

16 11 05*

linings and refractories from non-metallurgical processes containing hazardous substances

16 11 06

linings and refractories from non-metallurgical processes others than those mentioned in 16 11 05

17 01 06*

mixtures of, or separate fractions of concrete, bricks, tiles and ceramics containing hazardous substances

17 01 07

mixtures of concrete, bricks, tiles and ceramics other than those mentioned in 17 01 06

17 03 01* bituminous mixtures containing coal tar

17 03 02bituminous mixtures other than those mentioned in 17 03 01

17 05 03*soil and stones containing hazardous substances

17 05 04soil and stones other than those mentioned in 17 05 03

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Potential presence of hazardous substances

Criticality of waste classification

17 05 05*dredging spoil containing hazardous substances

17 05 06dredging spoil other than those mentioned in 17 05 05

17 06 03*

other insulation materials consisting of or containing hazardous substances

17 06 04

insulation materials other than those mentioned in 17 06 01 and 17 06 03

17 08 01*

gypsum-based construction materials contaminated with hazardous substances

17 08 02

gypsum-based construction materials other than those mentioned in 17 08 01

19 01 11*bottom ash and slag containing hazardous substances

19 01 12bottom ash and slag other than those mentioned in 19 01 11

19 01 13* fly ash containing hazardous substances

19 01 14fly ash other than those mentioned in 19 01 13

19 01 15* boiler dust containing hazardous substances

19 01 16boiler dust other than those mentioned in 19 01 15

19 03 06* wastes marked as hazardous, solidified

19 03 07solidified wastes other than those mentioned in 19 03 06

19 07 02*landfill leachate containing hazardous substances

19 07 03landfill leachate other than those mentioned in 19 07 02

19 08 11*

sludges containing hazardous substances from biological treatment of industrial waste water

19 08 12

sludges from biological treatment of industrial waste water other than those mentioned in 19 08 11

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Criticality of waste classification

19 08 13*

sludges containing hazardous substances from other treatment of industrial waste water

19 08 14

sludges from other treatment of industrial waste water other than those mentioned in 19 08 13

19 10 03*fluff-light fraction and dust containing hazardous substances

19 10 04fluff-light fraction and dust other than those mentioned in 19 10 03

19 13 01*solid wastes from soil remediation containing hazardous substances

19 13 02

solid wastes from soil remediation other than those mentioned in 19 13 01

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