Exploring the RPS 250 Withdrawal and Waste Wood Classification: What It Means for You

Introduced in 2021, this statement allowed for the transportation and processing of potentially hazardous waste wood from construction sites. Its elimination by the Environment Agency will bring alterations in the classification and disposal of such waste. This change will particularly affect practices with structural timbers and wooden elements from pre-2007 buildings. Let's explore what these changes mean for you.

What is a Regulatory Position Statement?

A Regulatory Position Statement (RPS) is a document issued by the Environment Agency to provide clarification on how certain regulations and requirements should be interpreted and applied. It often applies to specific sectors, such as the waste wood industry in the case of RPS 250, and can have a time limit, after which it may be withdrawn. An RPS can affect how businesses operate within their respective sectors, such as how they handle, store, and dispose of certain materials. It is vital for your business to stay informed about any RPS relevant to your operations to ensure compliance with regulatory standards.

A number of businesses have been affected by these changes to RPS 250, and understanding the acceptance criteria for proper waste wood classification is key.

Understanding the RPS 250 and its role

The RPS 250, introduced in 2021, has played a significant role in the waste wood sector, particularly in the construction and demolition (C&D) industry. It allowed the movement and processing of potentially hazardous waste wood, which could include items like structural timbers and wooden elements from buildings constructed before 2007.

The RPS 250 withdrawal, effective from 1 September 2023, denotes a shift in the regulations governing the classification and disposal of such waste wood. This change has potentially far-reaching impacts on waste wood handling practices, affecting both waste generators and recyclers. Therefore, understanding the RPS 250 and its impact is important to adapting to a new regulatory environment. 

Why has the Environment Agency decided to withdraw RPS 250?

The Environment Agency's decision to withdraw RPS 250 has been driven by an ongoing commitment to evolving environmental standards. As part of a wider effort to address climate change and protect natural resources, the agency continually reviews and updates its position statements.

The conclusion of a five-year research period clarifying which waste wood items are potentially hazardous led to this decision. From 1 September 2023, certain items from pre-2007 buildings are now deemed as hazardous and no longer accepted at wood recycling sites. This withdrawal aims to ensure waste wood handling regulations align with current environmental standards.

What does the withdrawal of RPS 250 means for waste wood classification?

The withdrawal of RPS 250 marks a significant shift in the waste wood classification system, particularly affecting wood sourced from buildings constructed before 2007. This alteration results in the automatic classification of such wood as hazardous unless proven otherwise, directly influencing recycling practices.

Specific wood types, previously deemed suitable for recycling, will now be designated as hazardous. This includes structural timbers, wooden tiling battens, and other external joinery from buildings predating 2007.

Furthermore, wood types identified as hazardous will no longer be accepted at recycling sites unless they undergo thorough testing to confirm their non-hazardous status. The responsibility for conducting these tests rests with waste generators and recyclers, necessitating more stringent testing procedures.

This change mandates a reassessment of waste management protocols, requiring companies to sort and categorise their materials more rigorously for accurate classification and disposal of waste wood. While introducing additional steps and potential costs to the waste wood recycling process, the withdrawal of RPS 250 is anticipated to affect only a "small amount of material," as indicated by the Wood Recyclers Association (WRA). 

How is the Environment Agency planning to manage waste wood post-withdrawal, and what are the implications for the C&D sector?

In the aftermath of RPS 250 withdrawal, the Environment Agency has adopted a more stringent approach to waste wood management. This involves implementing regular testing requirements and stricter definitions of waste wood.

As part of this strategy, the Environment Agency has introduced RPS 291, permitting potentially hazardous 'amber' waste wood items to be stored and processed as non-hazardous if tested at least quarterly. Consequently, waste generators, such as the C&D sector, and recyclers are tasked with demonstrating the non-hazardous nature of waste wood. This approach aims to create a culture of responsible waste management while aligning with the latest environmental standards.

These changes impact waste handling procedures and potentially lead to increased costs associated with waste management in the C&D sector.

Waste management compliance and the role of WRA test suites

Starting from 1 September, 2023, the use of the WRA 02 test suite is mandatory for determining the appropriate disposal protocol for potentially hazardous C&D waste wood materials. This means that, by default, all waste wood resulting from demolition activities will be categorised as hazardous unless subjected to analysis to confirm otherwise. This change will lead to an increase in testing within the waste wood sector, affecting a number of businesses in the industry.

The WRA 02 test suite is specifically designed to facilitate this process. This suite, a concise and cost-effective method compared to full WM3 testing, is to be carried out on potentially hazardous waste wood items. This includes external timbers treated with weather-resistant chemicals and pre-2007 wood, potentially painted with lead-containing paint.

As for wood received at Household Waste Recycling Centres (HWRCs), the WRA 01 test suite comes into play. It allows potentially hazardous waste wood to move as un-assessed, non-hazardous material, provided it's destined for compliant biomass or for the manufacture of panel board.

For both scenarios:

• Testing should be conducted by recognised test houses
• Data should be captured and shared to maintain transparency and accountability.

Understanding these testing requirements is essential to comply with the post-RPS 250 regulations and ensure responsible waste management.

Why is it important to characterise waste wood correctly?

Correct waste wood characterisation has a direct impact on how it is managed, recycled, or disposed. Following the RPS 250 withdrawal, categorising waste wood correctly is even more pertinent. Mischaracterisation could lead to non-compliant disposal or unnecessary hazardous waste procedures. Similarly, assuming all waste wood is hazardous can lead to unnecessary testing and costs. Therefore, accurate characterisation of waste wood is crucial to:

• Ensure compliance with new regulations
• Minimise costs by avoiding unnecessary testing
• Enable appropriate recycling or disposal methods
• Prevent environmental harm caused by incorrect disposal.

This reliance on correct characterisation increases the importance of understanding and implementing the new waste wood management strategies post-RPS 250 withdrawal.

How we can support your waste wood classification needs

As a member laboratory of the WRA, we work collaboratively with the WRA's technical development teams to provide a reliable method for preparing samples and a sequence of testing for precise material characterisation.

Our support for waste wood classification includes a nationwide field sampling service, where skilled technicians collect samples from potentially hazardous wood pieces, adhering to your requirements and industry standards.

Samples are securely transferred to our specialist renewable energy laboratory for analysis, with the option for on-site analysis for faster results. Utilising a standardised methodology, we sort and categorise samples in preparation for recording, followed by analysis in our UKAS accredited chemistry laboratory. 

The resulting report, including an interpretive characterisation of the material as hazardous or non-hazardous along with the appropriate waste code, is issued promptly in the form of a straightforward lab certificate.

We cater to clients in biomass power generation, waste management, demolition, brokers, consultancy firms, and local authorities, offering additional services such as assistance in developing ISO-compliant sampling plans, providing sampling training for site operatives, and conducting site-lab audits.