April 19, 2018
CIWM Call to Action
Wood Waste Project
The CIWM Construction and Demolition Waste Group is working with the NFDC on a project supported by the Environment Agency (EA) in England looking at what waste wood should be disposed of as hazardous waste.
The EA issued a Regulatory Position Statement (RPS) in September 2017 which allowed ‘treated’ waste wood that had not been assessed and classified in line with the WM3 hazardous waste technical guidance, to continue to be classified as non-hazardous, as long as it was destined for an Industrial Emissions Directive (IED) Chapter IV compliant permitted incinerator or co-incinerator or the manufacture of board. This RPS was due to be withdrawn at the end of September 2018, however due to the complicated nature of this project, the EA have extended this RPS to the end of September 2019. This will give the waste wood industry time to do both of the following:
After 30 September 2019 all unassessed waste wood must be classified as hazardous.
Having to assess and test each timber component to WM3 prior to demolition or strip out would impose significant additional cost on demolition and refurbishment contractors, and have a significant impact on construction programmes, so agreeing a workable code of practice for the industry is of high importance. Initial studies are showing that carcassing timber and external joinery removed from buildings constructed prior to 2008, as well as contaminated timber from industrial sources, are most likely to be classified as hazardous. However we believe internal joinery and most sheet materials will be classified as non-hazardous.
The key treatments identified as hazardous include creosote, typically used for the treatment of fencing, telegraph poles and railway sleepers, and copper chromium arsenic (CCA) treatments which have typically been used for carcassing timber and external joinery. However a number of other hazardous treatments have also been used in the past including Tributyltin oxide (TBTO), Pentachlorophenol (PCP), Dieldrin, Lindane and Permethrin.
All of the above treatments, except for creosote, were phased out by 2007, however their replacements still contain copper organics, organic solvents and waterbased organic chemicals which are hazardous, and work is currently ongoing to assess whether these treatments were used in concentrations that would classify the treated wood waste as hazardous. The Wood Recyclers Association (WRA) are carrying out similar testing on fencing and decking.
To help refine our understanding, we are looking for contractors provide samples of carcassing timber (floor plates, timber frame components, floor joists, roof timbers, tiling battens, etc.) and external joinery (windows, doors and fascia, soffit and barge boards) from buildings constructed from 1950 through to 1979, so that independent laboratory testing can be carried out to confirm whether they still contain hazardous treatments in concentrations likely to make wood waste from these component hazardous, and this work is ongoing.
If you can help please contact Green Compass and we will liaise with the National Federation of Demolition Contractors.(NFDC) For further details please visit the NFDC website: https://demolition-nfdc.com/nfdc-members-wood-waste-project-alert/
It is clear that changes will need to be made to the way the construction, demolition and refurbishment industries deal with their wood waste once the wood waste RPS is withdrawn. The code of practice currently in development will assist with this by detailing the waste wood components that are likely to contain significant concentrations of hazardous substances for them to be classed as hazardous waste, and which components can be disposed of as non-hazardous waste. This will allow demolition contractors to dispose of wood waste and be confident that this is being done in accordance with the regulations.