Change in the waste criterion HP 14
Some of the numbers of the hazardous properties redefined with the amendment correspond to the old classification (formerly listed as H (hazardous), now listed as HP (hazardous property)). However, significant changes have also occurred with the properties HP 5, HP 13, HP 14 and HP 15.
When classifying wastes such as bottom ash from household waste incineration plants, frequently only the hazard-relevant property HP 14 (hazardous to the environment or ecotoxic) is to be considered critical.
With the passing of Regulation (EU) 2017/997 in June 2017, an algorithm was defined for determining the property HP 14. If the most unfavourable case is considered (worst case approach), based on the total content of toxic elements, this can result in a change in classification from previously non-hazardous waste to hazardous waste, so that careful checking is strongly recommended.
Practical guidelines have been drawn up for various industries (e.g. practical guidelines on the classification of bottom ash ("Praxisleitfaden zur Einstufung von Rostaschen" published by ITAD). These are intended to be used as the basis on which the hazardous properties (HP) of waste are determined. In these guidelines the total content of toxic heavy metals is used for classification as HP 4 to HP 8 and HP 10 to HP 13. Based on the practical guide named in the example, the fractions of heavy metals soluble in the aqueous eluate and thus considered to be bioavailable, should be used for the classification as HP 14.
bifa is currently conducting factually founded waste classifications according to the new rules for companies in different industries. These also include considerations regarding the best-suited sampling, analytical determinations and comparisons of various practical guidelines and implementation aids.
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Dr. Karsten Wambach