Here at The Waste Group, we get annual inspections from the Environment Agency (EA). These inspections are obviously to make sure that we are complying with our environmental permit and that we are not doing anything that we are not supposed to be doing.
Classification of trommel fines
With our latest visit from the EA, one of the main bug bears was to do with the classification of trommel fines. To be totally honest, I was a bit lost with this one. Turns out that I don’t know it all! So the question from the EA was, “what measures have been put on place to identify whether trommel fines are hazardous or non-hazardous?”.
Basically the EA have issued a new letter that was (Apparently!) sent out to all waste produces of trommel fines. The letter stressed the importance of classification and stressed the following;
“only when a waste assessment, carried out in accordance with WM3 guidance, shows the waste does not display any hazardous properties, can the non-hazardous mirror waste codes be assigned (19 12 12)”
The letter did also state that the EA “will request to see copies of your waste assessments during future compliance visits”. Wish I got that letter!
Here is a link to the technical guidance WME from our friends in government if you have a spare day to read it.
What does this mean in reality?
The short version, is that you now need to get regular tests done to prove that your trommel fines are non-hazardous. The WM3 document does provide a comprehensive account of how waste should be classified.
Due to all of this, we have now changed our testing regime to reflect the changes requested by EA. On our annual inspection, we were also asked for details of our fines process from cradle to grave. This details our sampling regime of the fines, how we test, how often we test, what we are testing for and how we assess the results.