WM3 Procedures and Compliance

MTS produce site/contract specific WM3 procedures which set out simple sampling and testing plans for correctly classifying waste.

All companies within the waste industry have to comply with duty of care obligations to classify the waste they produce. Businesses must follow the Technical Guidance WM3: Waste Classification – Guidance on the classification and assessment of waste (1st Edition v1.2.GB). The guidance explains how to assess if the waste displays a hazardous property and how to classify it.

MTS Environmental produce site/contract specific WM3 procedures which comply with the guidance and set out a simple sampling plan and waste assessment for clients to follow. This allows clients to ensure they are following the guidance effectively and conducting sufficient testing on their waste to correctly classify it. Correct classification of waste is essential for not breaching permit conditions, ensuring waste is sent to the appropriate facilities with the correct tax applied and receives the correct further treatment or re-use where possible.

Waste must be classified under the List of Waste codes and assigned to a European Waste Code (EWC). These codes can be absolute codes (hazardous or non-hazardous) which require no further testing or assessment, or they are mirror-entry codes (hazardous or non-hazardous) which do require further testing and assessment to confirm their hazard status.

The WM3 Procedures which MTS produce set out the sampling plan, testing frequency and testing suites needed for materials in a testing matrix. MTS implement a ‘quick check’ method into the WM3 Procedure to be used on a more frequent basis to give a broader range of historical data and allows a faster turnaround of results to increase the confidence in and confirm the classification.

The procedure aims to:

  • develop a sampling procedure that complies with the EA WM3 Technical Guidance
  • identify which hazardous substances or Persistent Organic Pollutants (POPs) are present
  • determine the concentration of hazardous substances or POPs present
  • test directly for certain hazardous properties that are appropriate
  • waste minimisation considerations at design stage in line with the waste hierarchy

The procedure uses the following steps:

  • Step 1 – Check if the waste needs to be classified
  • Step 2 – Identify the code or codes that may apply to the waste
  • Step 3 – Identify the assessment needed to select the correct code (s)
  • Step 4 – Determine the chemical composition of the waste
  • Step 5 – Identify if the substances in the waste are ‘hazardous substances’
  • Step 6 – Assess the hazardous properties of the waste
  • Step 7 – Assign the classification code and describe the hazardous properties on the consignment note

This procedure can be adapted to different sites and materials to highlight the specific requirements needed for the particular operation. MTS Environmental have produced such procedures for numerous companies in different areas of the waste industry including highways depots, waste transfer sites, civic amenity sites, soil and aggregate recycling facilities. Adhering to the WM3 guidance through following the MTS WM3 Procedures allows clients to save money on testing, correctly classify waste which in turn can increase recycling rates. The procedure provides clients with a simple tool to navigate WM3 guidance, and ensure compliance, which can be a very confusing and technical document.