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.
