Waste wood handling regulations
Somewhat under the radar, members may not be aware that the regulations for the disposal of waste wood have changed. The Environment Agency (EA) has confirmed the withdrawal of the ‘Regulatory Position Statement (RPS) 250’ is effective from 1st September 2023. This decision will lead to changes in waste wood handling regulations across the construction and demolition industry, although the extent and impact of these changes as yet remain unknown.
Up until now, the EA only considered waste wood to be hazardous if it was creosote treated (Category D). However, they have expanded that category by adding certain pre 2007 treated timber, including:
- Tiling, cladding and battens
- Barge boards, fascia & soffits
- External joinery
- Timber frames and joists
- External doors
- Roof timbers
The long and the short of this is there is now a potential issue for the whole of the construction industry in how they dispose of wood waste. This will be driven by the waste removal companies, who will probably ask the contractor if the waste wood in the skip is treated or untreated, and if you cannot categorically say yes or no, a sample from each property would require testing before disposal.
Who can do the testing for us?
Any UKAS accredited laboratory can do the testing for you. The guidance is indicating that one sample of each type (from the list above) would need to be tested from the same load/skip/site.
Who pays for the testing?
The duty of care sits with the producer of the waste, therefore it should be the producer of the waste who pays for the testing. There appears to be no differential between domestic and commercial clients and the cost is unknown, but will probably depend on the lab undertaking the testing.
What guidance is there?
At present all guidance appears to be originating from the Wood Recyclers Association and is predominately aimed at providing guidance to the waste recycling industry. These rules may well filter back to the disposer (us) quite quickly but as, yet the guidance seems to be pointed at the waste recycling industry rather than those putting stuff in skips. The potential implications to members may be increased disposal costs and extra hazardous waste consignment notes to the skip provider.
So what will be the likely impact to members?
As already mentioned we cannot say at this stage how much this is likely to affect our industry, but it is believed that hazardous waste will only account for 1% of wood waste and it could be argued, that the changes may be overkill and result in too much red tape.
However, this is a situation we will continue to monitor and will report back to member as soon as we have further details or clarification.