SOCOTEC Sludge, Water, Opinion

SOCOTEC says the withdrawal of RPS 211 will affect utilities.

The Environment Agency (EA) is set to withdraw Regulatory Position Statement (RPS) 211 – which applies to businesses that deal with excavated waste – at the end of the month. Until then, up to ten cubic metres of waste from unplanned utility installations and repair works can be disposed of as non-hazardous waste, without the need for classification to prove it is non-hazardous.

After withdrawal, companies will have to classify their waste – no matter what the volume. If they do not do so, the waste will by default be classified as hazardous, attracting higher gate fees and tax rates for disposal.

To comply, those that excavate waste for the utilities industry should deliver an EA-approved protocol for the classification and assessment of excavated utilities waste, and implement compliance with the legal requirement to correctly classify and assess this waste.

To comply with EA waste classification guidance –WM3 – there should always be an assessment stage, particularly when dealing with material of unknown origin or constituents, to accurately classify contaminants in waste or soil. An EA-approved protocol will be required, so you should produce a sampling plan to outline the number of samples and sample density required to accurately and efficiently classify waste in line with guidance. An environmental consultancy can help you with this.

Waste classification is a two-stage process: representative samples of the soil are subject to laboratory analysis, then the data is used to classify the material as either hazardous or non-hazardous waste.

If the material is classified as non-hazardous, there are two potential landfill disposal routes. If the material passes inert WAC testing, it may be disposed of at an inert landfill. If the material fails inert WAC testing, or no WAC testing is carried out, it should be disposed of at a non-hazardous landfill.

Material classified as hazardous will require hazardous WAC testing before disposal. If it exceeds hazardous WAC criteria it cannot be disposed of in a landfill without treatment. In some cases such as clean natural materials, it may be possible to dispose of the soil directly as inert waste without carrying out testing and classification.

Depending on the level of contaminants present, it may be possible to reduce a preliminary hazardous classification to non-hazardous.

Experts can assess the data and potentially amend the classification using statistics, based on the site history, or through knowledge of chemistry. It may also be possible to delineate the area of hazardous material from surrounding non-hazardous material to reduce the volume of soil requiring disposal at a hazardous landfill.

For more information about classifying waste, visit