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Is it Hazardous Waste? - EU and UK

Hazardous waste may come into one of 16 categories, as given below. It is your responsibility to determine whether it counts as hazardous waste or not. In most cases, this can be done by looking for specific Hazard class and statements on the SDS (e.g. EyeDam.1 H318). If specific H codes are found then the classification can be made either by testing, or by determining the proportion by weight of that substance in the waste. In general, our wastes can be assessed by calculation.
In the UK, the GB mandatory classification and labelling list (GB MCL list) has a list of mandatory H codes for specific chemicals, and is referred to in som of the waste classification processes.

Explosive

This has to be tested if the SDS contains any of the categories and statements below. There are some exceptions for peroxides.

Hazard class and categoryHazard statement code
Unst.Expl.H200
Expl.1.1H201
Expl.1.2H202
Expl.1.3H203
Expl.1.4H204
Self-react.AH240
Org.Perox.AH240
Self-react.BH241
Org.Perox.BH241

Oxidising

This has to be tested if the SDS contains any of the categories and statements below. There is a possible exception if the waste is a single substance listed in the (GB MCL list).

Hazard class and categoryHazard statement code
Ox.Gas1H270
Ox.Liq.1H271
Ox.Gas.1H271
Ox.Liq.2H272
Ox.Liq.3H272
Ox.Gas.2H271
Ox.Gas.3H271

Flammable

This has to be tested, or sometimes demonstrated by calculation, if the SDS contains any of the any of the categories and statements below.

Hazard class and categoryHazard statement code
Flam.Gas 1H220
Flam.Gas 2H221
Aerosol 1H222
Aerosol 2H223
Flam.Liq. 1H224
Flam.Liq. 2H225
Flam.Liq. 3H226
Flam.Sol. 1H228
Flam.Sol. 2H228
Self-React CDH242
Self-React EFH242
Org. Perox. CDH242
Org. Perox. EFH242
Pyr. Liq. 1H250
Pyr. Sol. 1H250
Self-heat. 1H251
Self-heat. 2H252
Water-react. 1H260
Water-react. 2H261
Water-react. 3H261

Irritant

This is a possibility if the waste contains any of the categories and statements below. It can be determined by calculation.

Hazard class and categoryHazard statement codeCut-off %Concentration limit %
Skin Corr.1AH3141≥1 and ≤5
Eye Dam.1H318110
Skin Irrit. 2H315120
Eye irrit. 2H319120

For each H code, there is a cut-off level below which a material with that code is not considered, and a total concentration limit which, if met, gives the waste a hazardous category.
Note that the upper limit of 5 is applied to H314 because above this level it is classified as Corrosive (see below).
To do the calculations, follow these steps:

  1. List all substances in the waste, with their percentage by weight
  2. Identify which of the substances have any of the H codes given above, and ignore all other substances
  3. Ignore any substances where their concentration is below the cut-off level
  4. For each H code, add up the percentages by weight of all substances
  5. Compare the totals against the concentration limits above, to see if they count as hazardous waste

For example, see below:

Substance% weightH314H315H318H319
A75xxxx
B15xyxx
C8xyyx
D0.5xyyx

Here only H315 and H318 are of concern.
Substance D is below the 1% cut-off value, so is ignored
For H315 the concentration is: 0 + 15 + 8 + 0 = 22 - this is above the threshold of 20
For H318 the concentration is: 0 + 0 + 8 + 0 = 8 - this is below the threshold of 10
As at least one of the H codes is above the concentration threshold, it is classed as hazardous waste.

If this isn't possible, e.g. some SDS are missing or the proportions are unknown, then it may be determined by pH. If 2≤pH≥11.5 then it is classified as hazardous under category 8 - corrosive.

Specific Target Organ Toxicity / Aspiration Toxicity

These two aspects are assessed in different ways.
For specific target organ toxicity, each substance in the waste is assessed individually, and it is treated as hazardous waste if any one material has any of the contains any of the categories and statements below and exceeds the concentration limit:

Hazard class and categoryHazard statement codeConcentration limit
STOT SE 1H3701
STOT SE 2H37110
STOT SE 3H33520
STOT RE 1H3721
STOT RE 2H37310

For aspiration toxicity, this is dealing with fluids, and so not things like silica dust. If the waste is a fluid, and has a kinematic viscosity at 40°C of ≤20.5mm²/s, then the total proportion of components with Asp.Tox.1 H304 is summed up. If this exceeds 10%, then it counts as hazardous. Note that if the viscosity is unknown, then it is assumed to be under the threshold of 20.5.

Acute Toxicity

For each hazard class and statement, the concentration of each substance exceeding the cut-off level is summed up. If this exceeds the concentration limit, then it is categorised as hazardous waste. Details of the sums are as described in Irritation above.

Hazard class and categoryHazard statement codeCut-off levelConcentration limit
Acute Tox. 1 (Oral)H3000.10.1
Acute Tox. 2 (Oral)H3000.10.25
Acute Tox. 3 (Oral)H3010.15
Acute Tox. 4 (Oral)H302125
Acute Tox. 1 (Dermal)H3100.10.25
Acute Tox. 2 (Dermal)H3100.12.5
Acute Tox. 3 (Dermal)H3110.115
Acute Tox. 4 (Dermal)H312155
Acute Tox. 1 (Inhal.)H3300.10.1
Acute Tox. 2 (Inhal.)H3300.10.5
Acute Tox. 3 (Inhal.)H3310.13.5
Acute Tox. 4 (Inhal.)H332122.5

Carcinogenic

For each substance in the waste, if it has the hazard category and statement in the table below, and the concentration exceeds the concentration limit, then the waste is categorised as hazardous.

Hazard class and categoryHazard statement codeConcentration limit
Carc. 1AH3500.1
Carc. 1BH3500.1
Carc. 2H3511

Corrosive

If the total concentration of substances with hazard class Skin corr. 1A, 1B or 1C, and statement H314, exceeds 5%, then the substance is classified as hazardous. Substances with a concentration of less than 1% may be ignored in this.
If some SDS are missing, or the composition of the waste is not known, then it is considered hazardous if 2≤pH≤11.5.
If the waste is not classified as hazardous in this class, and has hazard class Skin corr. 1A and statement H314, then also look at Irritant above.

Infectious

This only applies to waste codes 18 01 and 18 02, which don't apply to us.

Toxic for Reproduction

For each substance in the waste, if it's concentration exceeds the limit in the table below then the waste is categorised as hazardous.

Hazard class and categoryHazard statement codeConcentration limit
Repr. 1AH3600.3
Repr. 1BH3600.3
Repr. 2H3613

Mutagenic

For each substance in the waste, if it's concentration exceeds the limit in the table below then the waste is categorised as hazardous.

Hazard class and categoryHazard statement codeConcentration limit
Muta. 1AH3400.1
Muta. 1BH3400.1
Muta. 2H3411

Release of an Acute Toxic Gas

This applies if any substances in the waste has Hazard statements EU H029, EU H031 or EU H032 then it can be tested to see if it emits a toxic gas on contact with water or an acid, or (if it also has statements H260 or H261) this can be calculated. If neither of these apply, it is deemed to be hazardous.

Sensitising

For each substance in the waste, if it's concentration exceeds the limit in the table below then the waste is categorised as hazardous.

Hazard class and categoryHazard statement codeConcentration limit
Skin Sens. 1, 1A, and 1BH31710
Resp. Sens. 1, 1A, and 1BH33410

Ecotoxic

Where any substances in the waste have a hazard class and statement as given the table below, the waste will be deemed hazardous if it meets one or more of the 4 criteria given.

Hazard class and categoryHazard statement codeCut-off LevelCriteria
OzoneH42001
Aquatic Acute 1H4000.12
Aquatic Chronic 1H4100.13 and 4
Aquatic Chronic 2H41113 and 4
Aquatic Chronic 3H41213 and 4
Aquatic Chronic 4H41313

Criterion 1

For each substance in the waste with hazard statement H420, if the concentration exceeds 0.1% then the waste is classed as hazardous.

Criterion 2

For all substances with Hazard statement H400 and concentrating exceeding the cut-off, the total concentration is summed up. If it exceeds 25%, then the waste is deemed hazardous.

Criterion 3

For all substances with Hazard statement H410, 411 or 412 and concentrating exceeding the cut-off, a weighted total concentration is calculated as below. If the result exceeds 25, then the waste is deemed hazardous.

100.Σc (H410)) + 10.Σc (H411) + Σc (H412) ≥ 25

where, for example, Σc (H412) means the sum of all concentrations with Hazard statement H412 and concentration above the cut-off.

Criterion 4

For all substances with Hazard statement H410, 411, 412 or 413 and concentrating exceeding the cut-off, a weighted total concentration is calculated as below. If the result exceeds 25, then the waste is deemed hazardous.

Σc (H410)) + Σc (H411) + Σc (H412) + Σc (H413) ≥ 25

Waste Capable of Exhibiting a Hazardous Property Listed Above not Directly Displayed by the Original Waste

If the waste contains substances with Hazard statements EU H001, EU H019, EU H044 or H205 then it will be classified as hazardous unless the waste is in such a form that it will not under any circumstance exhibit explosive or potentially explosive properties.

Persistant Organic Pollutants

This doesn't apply to our materials.