31 May 2018 by Joshua Doherty

Waste wood at CA sites ‘will be non-hazardous’

EXCLUSIVE: Waste wood from civic amenity sites is likely to be deemed as non-hazardous as part of the industry’s investigation into waste wood classification, which will report to the Environment Agency.

Howard Leberman said the Agency has based its assessment on the German model

That’s according to Howard Leberman, senior advisor for waste treatment & storage at the Environment Agency, who was speaking at the North East Recycling Forum quarterly conference in Gateshead last week.

Mr Leberman is also team leader for the national leads on non-hazardous waste, biowaste and fire prevention.

The comments came as Mr Leberman was explaining that the European Commission had asked the UK to examine why approximately 0.2% of its waste wood was classified as hazardous, while in Germany, by comparison, it is 15%.

“As with any waste which could be hazardous or non-hazardous, there is a legal requirement to carry out the WM3 assessment, which is quite complicated, in order to make the demonstrations that mixed waste wood is either hazardous or non-hazardous,” Mr Leberman explained.

He added: “Once you can classify this, you can legally deal with it and move it off-site, consigning it as hazardous or under a transfer note if non-hazardous. Industry has never actually carried out a WM3 assessment and most of it is moved as non-hazardous.

“That might be right, we know what hazardous looks like with railway sleepers and telegraph poles, for example. But when we start moving timbers, some of which may have had chemical treatments applied which are invisible to the naked eye, it could be a problem. Wood subject to chemical treatments however doesn’t necessarily mean that the wood is hazardous.”


The Environment Agency issued a regulatory position statement (RPS) in November last year, which meant that those handling waste wood could continue with current practise, giving time to the Wood Recyclers Association and their working group to complete its investigation into hazardous waste wood arisings.

This was on the condition that the waste wood from mixed sources must be destined for IED Chapter IV compliant boilers and the board manufacturing industry; the right end use for chemically treated waste wood.

Previously, there had been concerns that the EA’s proposal to record mixed waste wood at the front end of the wood recycling and recovery process would be “catastrophic” (see letsrecycle.com story).

At present, officially after 1 November this year (2018) all unassessed waste wood from mixed sources will have to be classified as hazardous and handled accordingly. This will include any waste wood that has entered the waste management system or has been stockpiled.

German model

CA sites wood

The majority of waste wood at CA sites will be classified as non-hazardous under the German model

Mr Leberman explained that the current approach widely used, of just looking at wood and saying this isn’t hazardous, or is – which is effectively the current UK industry practise for classifying wood – is actually “against the law”. This was leading to hazardous waste wood being used where it shouldn’t and this is why industry’s review which will report to the Agency, is “important”.

The Agency official added that in Germany, his counterparts had come up with a waste wood type approach , which allowed the industry there to visually determine what was or was not hazardous.

This would allow the industry to say, according to Mr Leberman, that “if it looks like a door, it’s a door, and if it’s a door, on balance it will be non-hazardous. If it looks like fence post, it is, and so on.”

He added that the investigation has so far found that, on balance, waste wood at civic amenity sites under this method is likely to be non-hazardous, except for very small quantities which won’t affect the classification. Industry is now undertaking a sampling and testing programme in order to support the technical justifications.

Final stages

The RPS which the EA published in November 2017 will last for one year to allow industry to investigate and report on whether hazardous waste wood is actually an issue. Mr Leberman confirmed that the work has now shifted to demolition waste.

“I don’t know what’s going to come out of that,” he explained.

There had been concerns that the EA’s proposal to record mixed waste wood at the front end of the wood recovery process would be ‘catastrophic’

Mr Leberman added: “But these demolition jobs, carried out by contractors who are professional, should see them doing their homework before they undertake a demolition activity and know what they’re dealing with.”

He continued: “So there is going to be changes to the grading system and how waste wood is assessed. But actually, I don’t think is going to be massive implications for the wood sector, other than what you should actually do and know already.

“But what this does is provide information and evidence to demonstrate what is hazardous, as opposed to ‘we’ve always done it this way and it has never been a problem’. Well, it’s never been a problem because it’s never actually been looked at, which doesn’t necessarily mean there isn’t a problem there.”

When quizzed by a local authority delegate at the NERF conference, Mr Leberman also confirmed that the Agency would re-visit the new classification regularly when new information becomes available.


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