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Good CSR includes classifying hazardous waste properly

Contaminated JP-8 is stored in plastic containers before being put through the filtration equipment. The fuel will be filtered seven times before it can then be made into heating oil. The contaminated JP-8 starts off as a red color; after being filtered, it runs clear. Recycling the fuel so it can be used for heating oil will save the Air Force $4 per gallon. (U.S. Air Force photo by Karen Abeyasekere)

It’s easy to overlook the importance of legal compliance in CSR, which includes classifying hazardous waste properly

So how does classifying hazardous waste properly fit with CSR — Corporate Social Responsibility?

Well, it’s easy really.

At the end of the day, CSR is about behaving responsibly as a business.

One of the reasons why we have a system of classifying and describing waste is so that subsequent downstream handlers of it can do so safely and make the correct decisions about how to deal with it so it doesn’t cause a pollution incident.

Not classifying hazardous waste properly would therefore be irresponsible, because it could cause accident and injury to people and harm to the environment.

However, the published technical guidance is very complex and for waste producers that aren’t familiar with the processes involved, it can easily lead to the wrong conclusions being reached.

One of the most frequent mistakes concerns the use of the ‘List of Wastes’ (LoW) or European Waste Catalogue as it’s also known.

What is the LoW / EWC?

Before explaining the basics, it’s worth understanding what the LoW actually is:

It comprises a pre-determined list of coded entries used to describe all sorts of wastes. It is assembled in 20 Chapters, each of which is grouped by waste source. In some cases — what are known as ‘Absolute Hazard’ entries — the decision to classify wastes as hazardous has already been made for you; in others — ‘Absolute Non-Hazard’ entries — the reverse is true. Then there are what are known as ‘Mirror Entries’ — if your waste contains dangerous substances at or above certain thresholds, you must use a Mirror Entry and describe your waste as hazardous, but if the dangerous substances are absent or below the relevant thresholds, you describe it as non-hazardous.

Still with us?

Then let’s dive into some basics on classifying hazardous waste properly.

The LoW isn’t pick ‘n’ mix

Very often, when attempting to classify hazardous waste properly, waste producers that aren’t overly familiar with how to do so will read through the list of entries and pick one without following the correct process – they go with ‘gut feel’ and what they think is the closest approximation.

This can result in wastes that ought to be classified as hazardous being given a non-hazardous designation in error.

A blog post like this isn’t the right place to get into the finer details, but there is an important takeaway point that waste producers need to understand, so we’re just going to explore that for now: the key steps to finding the correct LoW description and 6-digit code.

1. Consult the LoW to find the Chapter that best describes the source of waste by originating industry and process.

2. First, search Chapters 01-12 and 17-20. It is important to ignore the others for the time being.

3. If you find a relevant Chapter, look for a coded description that fits. If you can’t find one, ignore the generic ‘not otherwise specified’ 99 codes — you can come back to these later if needs be.

4. In the event that you can’t find an appropriate entry in Chapters 01-12 or 17-20, you may now consider Chapters 13, 14 and 15. Again, don’t just plump for the codes with 99 at the end.

5. If you’ve still drawn a blank, it’s time to consider Chapter 16. The same rules apply — try to find an appropriate entry and ignore the 99 codes at this stage.

6. Still not finding a suitable entry? Repeat steps 2-4 but this time consider if a 99 code is appropriate.

7. If, after exhausting the search you still can’t find an appropriate entry, return to Chapter 16 and choose the most applicable 99 code available there.

IF, during your search, you find an entry that sort of describes your waste but is a Mirror Entry, you now have some more work to do in order to determine whether any dangerous substances are present that would render the waste hazardous. This is far too complex to get into here, so we’ll save that for another time.

Otherwise, it’s already been decided for you — either it’s hazardous or it isn’t, and you have no say in the matter.

The point here is that it’s not pick ‘n’ mix — you don’t just jump into the list, or run through each Chapter sequentially from 01-20, stopping once you find an entry that sounds plausible; you have to follow the correct process, in the right order.

Failure to do so may mean you fail in classifying hazardous waste properly.

DIY or DIFM?

So, who should classify hazardous waste?

It is not uncommon to find waste disposal companies telling their customers which LoW / EWC code to use.

You’d think this makes sense because they’re immersed in the topic and so should understand it best.

But, actually, it’s a mistake to rely on your disposal contractor if you’re the waste producer — because the legal duty to accurately describe your waste rests with you.

Always Do It Yourself, avoid abdicating responsibility by asking others “can you Do It For Me?”

That’s not to say you can’t consult your disposal contractors, but don’t let them make the decision for you.

And when you’ve settled on the correct description using the LoW / EWC properly, make certain that the 6-digit code you’ve selected appears in the List of Approved Waste included in the environmental permit of the site you send it to for processing or disposal — if it’s not on their list, it has to go somewhere else.

Remember, legal compliance is essential to good governance which is inherently part of being a responsible corporate citizen. If you’re classifying hazardous waste properly, that’s an example of CSR.

Was this helpful? Have you experienced problems when you try to classify hazardous waste properly? Just remember [email protected]

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