Submission on The New Waste Classification Guidelines

AEBN responded to the Department of Environment and Climate Change’s document Waste Classification Guidelines Part 1. Note this document is not being publicly discussed it however, contains a number of issues which prompted AEBN comments and recommendations.

 The key issues raised include:

  •  The need to undertake TCLP, SCC or putrescible waste testing or be deemed as a hazardous waste or a putrecible waste. AEBN recommended that waste generators should have the provision to rely on a written justification based on the knowledge of the processes that generated the waste that the waste would not exceed any TCLP, SCC or putrecible limits.
  • Hazardous waste definitions were inconsistent in relation to pH range and for empty containers
  • A typographical error appears in Table 3 citing apparently the wrong SCC limit.


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