Technical Guidance WM2

www.environment-agency.gov.uk

Hazardous waste

Interpretation of the definition and classification of hazardous waste

( Second Edition, version 2.1 )
Publishing Organisations
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© Environment Agency 2005 ISBN: 1 84432 454 0

First Published June 2003, Second edition November 2005, Updated October 2006.
An electronic pdf version of this document is available to download from the various Agencies web-sites.

All rights reserved. No part of this document may be reproduced, stored in a retrieval system, or transmitted, in
any form or by any means, electronic, mechanical, photocopying, recording or otherwise without the prior
permission of the Environment Agency.
The Agencies do not accept any liability whatsoever for any loss or damage arising from applying, following or
using any interpretation or information contained in this document, or from relying upon any view contained in
this document.
SEPA, whilst supportive of the technical content of this guidance document, do not necessarily support and are not
bound by the legal interpretations in this guidance, nor that of Environment Agency or other guidance mentioned
within the text.
Statement of Use
This Technical Guidance on hazardous waste has a similar purpose to WM1 Special Wastes: A technical guidance
note on their definition and classification. This document defines hazardous waste for regimes that refer to
hazardous waste. WM1 will continue to be used to provide guidance on the assessment of waste according to the
criteria contained in the Special Waste Regulations as appropriate in England, Wales, Scotland and Northern Ireland.
It is intended as a reference document for use by the waste management industry, producers, and regulators of
hazardous waste. This Technical Guidance has been produced by the Environment Agency, SEPA and the
Environment and Heritage Service. In this document, they are known collectively as “the Agencies”.
A consultation document was released externally by the Agencies in September 2002 and amendments made to the
to version 1.0. The Second Edition updated this document, verion 2.1 implements Approved Supply List changes.
Keywords
Hazardous waste, special waste, European Waste Catalogue, dangerous substances, chemicals
Research Contractor
This guidance is based on work undertaken as Environment Agency R&D Project P1-482 by Enviros and Land
Quality Management Ltd.
Project Team
The following Project Team provided valuable input into the finalisation of this document:
Nick Bethel (Project Manager) Environment Agency Chris Hall Environment Agency
Robin Adams Environment Agency Jonathan Hofton Environment Agency
Gary Bower Environment Agency Bob McIntyre Environment Agency
Terry Coleman Environment Agency Jane Stratford DEFRA
Paula Coopland SEPA Alison Townley NIEHS
Roy Watkinson Environment Agency Gary Walker SEPA
Contents

1. Introduction 3

2. Regulatory Framework 5
2.1 Hazardous Waste Directive (HWD, Council Directive 91/689/EC) 5
2.2 Revised European Waste Catalogue (EWC 2002) 5
2.2.1 Links to other legislation 6

3. Hazardous Waste Assessment Framework 9

3.1 Hazardous Waste Assessment Methodology 9
3.1.1 Step 1: Is the waste a directive waste ? 10
3.1.2 Step 2: Does the domestic legislation contain specific provisions that relate to the waste in
question? 10
3.1.3 Step 3: How is the waste coded and classified on the EWC 2002? 11
3.1.4 Step 4: Is the composition of the waste known or can it be determined? 10
3.1.5 Step 5a: Does the waste contain dangerous substances ? 11
3.1.6 Step 5b: Is there any reason to indicate the waste may be hazardous (e.g. test results) ? 13
3.1.7 Step 6: Does the waste possess any of the hazardous properties H1 to H14 ? 14
3.1.8 Notes on using Table 3.1 24
3.1.9 Other important notes on the use of CHIP3 to assess hazardous waste 25
Appendix A Consolidated European Waste Catalogue
Appendix B Wastes and Potential Hazards for Absolute and Mirror Entries in the
European Waste Catalogue
Appendix C Hazardous Property Assessment
Appendix D Data Sources
Glossary of Terms
Indexes General
Chemical

Environment Agecny Hazardous Waste : Interpretation of the definition and classification of hazardous waste (2nd edition v2.1) 1
 List of Abbreviations
LC Lethal concentration
LD Lethal dose
ASL Approved Supply List (current edition) LEL Lower Explosive Limits
ASTM American Society for Testing and MEC Minimum effective concentration
Materials MECA Minimum effective concentration
ATSDR Agency for Toxic Substances in adult
and Disease Registry MECD Minimum effective concentration in
BCF bioconcentration factor developing embryos
BOD biological oxygen demand MFSU Manufacture, formulation, supply
BSI British Standards Institute and use
CAS Chemical Abstract Service MSDS Material Safety Data Sheets
CD-ROM Compact Disk – Read Only Memory NCEC National Chemical Emergency Centre
CDS Chemical Detection System NFPA National Fire Protection Association
CFC chlorofluorocarbon NIOSH National Institute of Safety and Health
CHIP3 Chemicals (Hazards Information and OHMTADS Oil and Hazardous Materials Technical
Packaging) [Regulations] Assistance Data Systems
CIS Chemical Information System PAH polycyclic aromatic hydrocarbon
DIN Deutsche Industrie Normen PCBs polychlorinated biphenyls
DOSE The Dictionary of Substances and PCTs polychlorinated terphenyls
their Effects PETN pentaerythritol tetranitrate
DPD Dangerous Preparation Directive RDX cyclotrimethylene trinitramine
EC European Communities RTECS Registry of Toxic Effects of Chemical
ECB European Chemicals Bureau Substances
EEC European Economic Community SCA Standing Committee of Analysts
EHC Environmental Health Criteria SDSs Safety Data Sheet(s)
EINECS European Inventory of Existing SEPA Scottish Environment Protection Agency
Commercial Chemical Substances SIRI MSDS Safety Information Resources and
EU European Union Material Safety Data Sheets
EWC 1994 European Waste Catalogue 1994 STP Standard temperature and pressure
EWC 2002 Revised European Waste Catalogue 2002 (25°C, 1 atmosphere pressure)
TER transcutaneous Electrical Resistance
FGT Flue Gas Treatment TGBE triethylene glycol mono-N-Butyl ether
HSC Health and Safety Commission TGME triethylene glycol monomethyl ether
HSDB Hazardous Substances Data Bank TSCA Toxic Substances Control Act
HSE Health and Safety Executive UEL Upper Explosive Limits
HWD Hazardous Waste Directive UK United Kingdom
HWL Hazardous Waste List UKEMS UK Environmental Mutagen Society
IARC International Agency for Research on URL Uniform Resource Locator
Cancer USA United States of America
IPCS INCHEM International Programme on USEPA United States Environmental
Chemical Safety Protection Agency
IRIS Integrated Risk Information System WAF Water-accomodated Fraction
ISCS International Chemical Safety Cards WHO World Health Organisation
ISO International Standards Organisation XPS Extruded Polystyrene
IUCLID International Uniform Chemical
Information Database
L/S Liquid to Solid

2 Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd Edition v2.1)
 1

Introduction
This Technical Guidance document has been developed to provide guidance on the assessment and
classification of hazardous waste based on the Hazardous Waste Directivea definition of hazardous waste.
It is intended to provide guidance to all involved in the production, management and control of hazardous
waste and to be a reference document for all legislation related to hazardous waste and its management.
The guidance is structured as follows:
Chapter 1 Introduction
Chapter 2 Regulatory Framework, setting out the legal framework for the definition of hazardous waste
Chapter 3 Hazardous Waste Assessment Framework, outlines the methodology for assessing wastes
based on the EWC
Appendix A European Waste Catalogue, provides guidance on the use of the catalogue
Appendix B Absolute and Mirror Entries, provides guidance on the potential hazards associated with
different hazardous wastes
Appendix C Hazardous Property Assessment, providing guidance on the assessment of each hazardous
property
Appendix D Data Sources, providing users with information on data sources and origin of the information
from different sources

a
Council Directive 91/689/EC

Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd Edition v 2.1) 3
4 Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1)
 2

Regulatory Framework
This chapter sets out:
• the legal framework for the definition of hazardous waste as defined by the Hazardous Waste
Directive; and
• how the definition is derived and how it is linked to EU legislation.
2.1 Hazardous Waste Directive (HWD, Council Directive 91/689/EC)
The aim of the HWD is to provide a precise and uniform European-wide definition of hazardous waste
and to ensure the correct management and regulation of such waste. The starting point of the HWD
is to identify which wastes are deemed to be hazardous.
Article 1(4) of the HWD defines hazardous waste as wastes featuring on a list drawn up by the
European Commission, because they possess one or more of the hazardous properties set out in the
HWD. There are 14 hazardous properties set out in Annex III of the HWD and they are detailed in
Table 2.1.
In 1994 a comprehensive list of all wastes, hazardous or otherwise, was produced pursuant to Council
Directive 75/442/EEC (as amended by 91/156/EEC). This list is known as the European Waste
Catalogue (EWC 1994, Commission Decision 94/3/EC).
Council Decision 94/904/EC then identified which of the wastes on EWC 1994 are deemed to be
hazardous, based on the properties set out in the HWD. The resulting list of wastes was called the
Hazardous Waste List (HWL) and was the list defining hazardous waste required by Article 1(4) of the
HWD.
The EWC is subject to periodic review in accordance with Article 1(4), second indent. After several
years of debate among the EC countries the EWC 1994 and HWL were updated and combined. This
resulted in a revised European Waste Catalogue (EWC 2002, Commission Decision 2000/532/EC).
2000/532/EC was subsequently amended by Commission Decisions 2001/118/EC, 2001/119/EC and
Council Decision 2001/573/EC.
2.2 Revised European Waste Catalogue (EWC 2002)
The EWC 2002 is intended to be a catalogue of all wastes, grouped according to generic industry,
process or waste type.
The EWC 2002 differentiates between non-hazardous and hazardous by identifying hazardous waste
entries with an asterisk (*).
Details of how to use the EWC 2002 and the steps that should be followed to identify a waste in the
catalogue and whether that waste is hazardous are given in Commission Decision 2001/118/EC. A
Hazardous Waste Assessment Framework is set out in Chapter 3, which outlines the methodology for
assessing wastes based on the EWC 2002.
A consolidated version of the EWC 2002 (incorporating Commission Decision 2000/532/EC and its
subsequent amendments) and a description of how to use the catalogue are set out in Appendix A.

Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1) 5
 2.2.1 Links to other legislation
The EWC 2002 links the classification of certain hazardous waste to the concentrations of “dangerous
substances” within the waste. It defines “dangerous substances” as substances classified as dangerous
in Directive 67/548/EEC and its subsequent amendments.
Directive 67/548/EEC is the European Council Directive on Dangerous Substances that specifies
the hazard classification, packaging and labelling requirements for dangerous substances supplied in the
European Union.
In addition, the EWC 2002 derives threshold concentrations for certain hazardous properties from the
Directive 88/379/EEC, the European Council Directive on Dangerous Preparations, and its subsequent
amendments. Directive 88/379/EEC specifies the hazard classification, packaging and labelling
requirements for dangerous preparations supplied in the European Union.
The requirements of Directive 67/548/EEC and Directive 88/379/EEC are implemented in the UK
through the Chemicals (Hazard Information and Packaging for Supply) Regulations 2002b, which are
known as CHIP3. Details of how CHIP3 relates to the classification of hazardous waste are set out in
the Hazardous Waste Assessment Framework in Chapter 3 .
Where hazardous waste is to be transported it also needs to be classified in accordance with the
requirements of Directives 94/55/EC and 96/49/EC regarding the transport of dangerous goods by road
and rail (respectively), and the regulations which implement them in the UK. Guidance on the transport
of dangerous goods can be obtained from the Health and Safety Executive.
2.2.2 Domestic Legislation
The implementation of the Hazardous Waste Directive and the European Waste Catalogue in England ,
Northern Ireland, Scotland and Wales may differ. Further guidance on each regulatory regime is
published by the Agencies on their respective websites.
This document provides the common technical basis for the definition of Hazardous Waste in the United
Kingdom.

b
SI 2002 No. 1689, HMSO London, ISBN 0 11 042419 0

6 Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1)
Table 2.1 Hazardous Properties (Hazardous Waste Directive Annex III)1

H1 “Explosive”: substances and preparations which may explode under the effect of flame or which
are more sensitive to shocks or friction than dinitrobenzene.
H2 “Oxidising”: substances and preparations which exhibit highly exothermic reactions when in
contact with other substances, particularly flammable substances.
H3A “Highly Flammable”
- liquid substances and preparations having a flashpoint of below 21°C (including extremely
flammable liquids), or
- substances and preparations which may become hot and finally catch fire in contact with air at
ambient temperature without any application of energy, or
- solid substances and preparations which may readily catch fire after brief contact with a source
of ignition and which continue to burn or to be consumed after removal of the source of
ignition, or
- gaseous substances and preparations which are flammable in air at normal pressure, or
- substances and preparations which, in contact with water or damp air, evolve highly flammable
gases in dangerous quantities.
H3B “Flammable”: liquid substances and preparations having a flashpoint equal to or greater than
21°C and less than or equal to 55°C.
H4 “Irritant”: non-corrosive substances and preparations which, through immediate, prolonged or
repeated contact with the skin or mucous membrane, can cause inflammation.
H5 “Harmful”: substances and preparations which, if they are inhaled or ingested or if they
penetrate the skin, may involve limited health risks.
H6 “Toxic”: substances and preparations (including very toxic substances and preparations) which, if
they are inhaled or ingested or if they penetrate the skin, may involve serious, acute or chronic
health risks and even death.
H7 “Carcinogenic”: substances and preparations which, if they are inhaled or ingested or if they
penetrate the skin, may induce cancer or increase its incidence.
H8 “Corrosive”: substances and preparations which may destroy living tissue on contact.
H9 “Infectious”: substances containing viable micro-organisms or their toxins which are known or
reliably believed to cause disease in man or other living organisms.
H102 “Toxic for reproduction”: substances and preparations which, if they are inhaled or ingested or if
they penetrate the skin, may produce or increase the incidence of non-heritable adverse effects
in the progeny and/or of male or female reproductive functions or capacity.
H11 “Mutagenic”: substances and preparations which, if they are inhaled or ingested or if they
penetrate the skin, may induce hereditary genetic defects or increase their incidence.
H12 Substances and preparations which release toxic or very toxic gases in contact with water, air or
an acid.
H13 Substances and preparations capable by any means, after disposal, of yielding another
substance, e.g. a leachate, which possesses any of the characteristics listed above.
H14 “Ecotoxic”: substances and preparations which present or may present immediate or delayed
risks for one or more sectors of the environment.

1
See Appendix C for Hazardous Property Assessments.
2
EWC 2002 states that “Toxic for reproduction” is considered to be in line with the hazardous property H10 “Teratogenic” in the HWD.

Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1) 7
8 Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1)
 3

Hazardous Waste Assessment

Framework
This chapter provides a practical approach to classifying hazardous waste by:
• outlining the methodology for assessing wastes based on the EWC 2002; and
• highlighting where to find more detailed advice in the Technical Guidance Note.
3.1 Hazardous Waste Assessment Methodology
There is a series of steps involved in determining if a waste is hazardous or non-hazardous. These
steps are set out in a flowchart in Figure 3.1. The flowchart is cross-referenced to sections within the
text that explain the issues underlying each decision and where to find more detailed advice in
theTechnical Guidance Note.

Figure 3.1 Hazardous Waste Assessment Methodology

Step 1 – Is the Waste a Directive Waste ?

N No H
Yes
O Step 2: Does the domestic legislation contain
specific provisions that relate to the waste in A
N question?

This should be determined prior to

- proceeding to step 3 Z
H A
Neither
A Absolute
nor
Step 3 – How is the waste coded and
classified on the EWC 2002 ?
Absolute Entry

Z
Mirror
Mirror Entry R
Yes No
Step 4 - is the composition of the waste
A known or can it be determined ? D
R No
Step 5a: Does the waste
contain dangerous O
D substances1 ?

Yes
O Step 5b: Is there any reason to
indicate the waste may be U
hazardous (e.g. test results) ?
No
U Yes S
No Yes
S Step 6: Does the waste possess any of the
hazardous properties H1 to H14 ?

Note:
1
Infectious substances should be considered at this stage of the Hazardous Waste Assessment Methodology

Environment Agency Hazardous Waste: Interpretation of the definition of the classification of hazardous waste (2nd edition v2.1) 9
 3.1.1 Step 1: Is the waste Directive waste?
Directive waste means;
(i) waste as defined in Article 1(a) of Council Directive 75/442/EEC on waste.
(ii) ... is not excluded from the scope of that Directive by Article 2 of that Directive.
if waste is not Directive Waste, it is not hazardous waste .
3.1.2 Step 2: Does the domestic legislation contain specific provisions that relate to the waste in question?
This should be determined prior to proceeding to step 3
Notes on the Application of this guidance to specific waste streams:
• The timing of the implementation of regulatory controls to agricultural waste and mine or
quarry waste differs in England, Northern Ireland, Wales and Scotland. Information on this is
available from each of the Joint Agencies.
• Most radioactive waste is not Directive Waste, but comes under the Radioactive Substances
Act 1993 (RSA). However, if radioactive waste is exempt from the requirements of sections 13
or 14 of the RSA, and has one or more of the hazardous properties, this waste will be classified
as hazardous waste.
• Domestic waste is excluded from the requirements of the HWD. Guidance on what constitutes
‘domestic waste’, and how regulatory controls are applied to it, is available from each of the
Joint Agencies .
• The Secretary of State (SoS), the Welsh Assembly, Scottish Executive or Northern Ireland
Department of the Environment may determine in exceptional cases, that a specific batch of
waste
- displays one or more of the hazardous properties, and is therefore hazardous waste.
- does not display any of the properties listed in Annex III to the Hazardous Waste Directive,
and is therefore non-hazardous waste.
Waste will only be classified after the appropriate organisations have been consulted. We will
publish any decisions made by the Secretary of State under section 62A(1) of the
Environmental Protection Act 1990.
3.1.3 Step 3: How is the waste coded and classified on the EWC 2002?
The EWC 2002 details a series of steps for identifying wastes in the catalogue and the order in
which entries in the catalogue must be considered. The EWC 2002, and an explanation of how to
use it, is set out in Appendix A.
The EWC 2002 consists of 20 chapters that are relate to the process that generated the waste or to
specific waste types. The chapters are given a two-digit number. These chapters must be used in a
certain order of precedence (see Appendix A) .
Each Chapter contains sub-chapters that are identified by four-digits. Within each sub-chapter are a
list of unique six digit codes for each waste e.g.
20 Municipal Wastes (Household waste and similar commercial, industrial and institutional
wastes) Including separately collected fractions.
20 01 Separately collected fractions (except 15 01)
20 01 01 paper and cardboard
The EWC consists to three types of entry
"Absolute entries" : A number of wastes marked with an asterisk (*) are deemed to be hazardous
regardless of their composition or concentration of any “dangerous substance” within the waste.
Such entries have been termed “ absolute entries” and are coloured red in this document for clarity.
"Mirror Entries" : Some wastes have the potential to be either hazardous or not, depending on
whether they contain “dangerous substances” at or above certain thresholds. These wastes are
covered by linked (usually paired) entries, collectively called “mirror entries” that comprise;
• a hazardous waste entry marked with an asterisk (*), coloured blue in this document, and
• an alternative non-hazardous waste entry (or entries) not marked with an asterisk.

10 Environment Agency Hazardous Waste: Interpretation of the definition of the classification of hazardous waste (2nd edition v2.1)
 “Non-Hazardous Entries": Where a waste is not listed in the EWC 2002 with an asterisk, then it is
not hazardous. However where the non-hazardous entry forms part of a “mirror entry” assessment is
required to determine whether the hazardous or non-hazardous waste entry is applicable.
3.1.4 Step 4: Is the composition of the waste known or can it be determined?
One of the simplest methods of identifying whether a “mirror entry” waste is hazardous is to identify
the chemical composition of the waste and then determine if the concentrations of the chemicals
within the waste are sufficient to render the waste hazardous.
The composition of the waste could be identified using:
• knowledge of the process or activity that produced the waste; and/or
• chemical/microbiological analysis of the waste; and/or
• information on the Safety Data Sheets.
It should be noted that chemical analyses (particularly for inorganic substances) do not always
identify the components within a waste, but the individual species such as anions (e.g.. sulphate,
chloride) and cations (e.g. metals). In such cases the waste holder would need to determine
what substances are likely to be present based on the process/activity that produced the waste
and the anions and cations present. If the holder cannot decide which substances might be
present, they should assume the worst-case scenario for each component and assess the waste
accordingly.
In the majority of cases the company producing or storing a “mirror” entry waste should have
enough information about the chemical substances in their waste to know if it is hazardous or not
(e.g. from safety data sheets, or knowing how the waste was produced).
If they do not know what substances are in their waste and they cannot find this out, they will need
to test the waste for hazardous properties (see Step 6b) .
3.1.5 Step 5a: Does the waste contain “dangerous substances”?
Where the composition of a “mirror entry” waste is known, it can be assessed to determine if the waste
contains “dangerous substances” or not. Chapter 2 highlights that the EWC 2002 defines
“dangerous substance” using the European Council Directive on Dangerous Substances1, which is
implemented by CHIP3 in the UK.
There are three ways to find out if the substances in a “mirror” entry are dangerous:
1. use the Approved Supply List (ASL)2. This shows hazard information and classification for many
common chemicals3. If the waste contains substances on the ASL, this classification must be
used. The ASL is updated regularly, the most recent version should be used.
2. use the methodology given in the Approved Guide to the Classification and Labelling of
Substances and Preparations for Supply4 with data for the substance obtained from peer
reviewed sources.
3. use information from the Safety Data Sheets or other data sources to find out whether the waste
contains dangerous substances .
The classification of the substance(s) shows :
• the categories of danger exhibited by the substance; and
• the risk phrase(s), which describe the hazards the substance possesses.
If none of the substances in the waste are classified as “dangerous substances”, the waste will not
be hazardous and the non-hazardous EWC code can be used.

1
67/548/EEC and amendments
2
Approved Supply List (most recent edition) – Information approved for the classification and labelling of substances
and preparations dangerous for supply. At the time of publication the current edition was the 8th, HSE Books, ISBN 0 7176 6138 5
3
Chemical is the common term for substances (a chemical element or one of its compounds, including any impurities) and
preparations (a mixture of substances).
4
Approved Guide to the Classification and Labelling of Dangerous Substances and Dangerous Preparations (the Approved
Classification and Labelling Guide) Fifth edition, HSE Books, ISBN 0 7176 2369 6

Environment Agency Hazardous Waste: Interpretation of the definition of the classification of hazardous waste (2nd edition v2.1) 11
 Using the ASL
The ASL prescribes hazard classifications for many common chemicals, and where a chemical is
listed in the ASL the classification given therein takes precedence over a classification found elsewhere.
(Note: The most recent edition of the ASL should always be used)
The ASL is split into five parts with classification information contained in Part I, which is an
alphabetical listing of all the substances covered. An example of the classification of a chemical given
in Part I to the ASL is set out in Box 3.1 .
To aid identification, each ASL entry provides alternative chemical names and the Chemical Abstract
Service (CAS) number. The CAS number is the most accurate identification of a substance that may
have many non-standard names.
In some cases the ASL shows risk phrases joined together by comma (,) or an oblique stroke (/), to
indicate how information should be presented on a label. For the purpose of assessing hazardous
waste the comma and oblique stroke are interchangeable. A hyphen (-) is used to represent an ‘and’ in
the case of Ecotoxic risk phrases, e.g. R50-R53 represents R50 and R53 .
Box 3.1: Example of an entry from the ASL

Cadmium sulphide The classification required for

CAS 001306-23-6 the assessment of hazardous
Index 048-010-00-4 wastes
Class’n Carc Cat 2: R45 Muta Cat 3: R68 Repr Cat 3:
R62, 63 T:R48/23/25 Xn: R22 R53
Information that must be
Label T
included on the supply label
R22, 40, 48/23/25
S(1/2), 22, 36/37, 45
215-147-8 Some substances have specific
Conc Note 1 threshold concentration limits;
Conc >= 10% T: R22, 40, 48/23/25 they are not used when
Conc >= 1% and < 10% Xn: R22, 40, 48/23/25 assessing hazardous wastes
Conc >= 0.1% and < 1% Xn: R48/23/25

The classification of cadmium sulphide is therefore Carc Cat 2: R45 Muta Cat 3: R68 Repr Cat 3
R62, 63 T:48/23/25 Xn: R22 R53
• Carc Cat 2 (Carcinogenic Category 2), Muta Cat 3 (Mutagenic Catery 3), Repr Cat 3 (Toxic for
Reproduction Category 3 ), T (Toxic) and Xn (Harmful) indicating the Categories of Danger or hazards; and

• R45, R68, R62,63, R48/23/25, R22 and R53 being the risk phrases.
A full description of all risk phrases is set out inPart V of the ASL with a summary in Table 3.1.

The ASL contains two series of notes .

• The alphabetic series (Note A, B, etc.) which appears after the substance name. These notes are only
relevant to hazardous waste where they alter the classification of the chemical. The assessment of
hazardous wastes is based upon the classification .
• The numeric series (Note 1, 2, etc.) which appears above the concentration limit information. As the
concentration limits are not used when assessing hazardous waste, these notes have no relevance to
the assessment.
Approved Classification and Labelling Guide and Safety Data Sheets
The ASL only covers a small proportion of the substances on the European Inventory of Existing
Commercial Chemical Substances (EINECS). If a substance is not listed in the ASL then further research
is required determine the substance classification. There are two options :
• Determine the classification using the criteria set out in the Approved Classification and Labelling
Guide; or
• Use classification information from Safety Data Sheets

12 Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1)
 The Approved Classification and Labelling Guide provides information on:
• the type and sources of data that can be used, which include results of testing, information
required by international rules on the transport of dangerous goods, reference works or scientific
and technical literature and practical experience;
• the criteria for each category of danger; and
• how to assign risk phrases.
The criteria for the categories of danger specify the data or test method necessary to assign each
category. The criteria for health effects are usually based on human or animal toxicological data with
physico-chemical effects generally based on test results. The criteria also assign the appropriate risk
phrase.
To classify a substance that is not on the ASL, the available data must be collected and compared
against the criteria specified for each category of danger. If the data indicate a particular category of
danger, the appropriate risk phrase should be assigned. It should be remembered that substances
could have more than one category of danger and a number of risk phrases. Therefore the criteria for
each category of danger should be considered in turn.
Appendix B provides an indication of the potential hazardous properties (i.e. category of danger) that
different wastes may possess, to help the waste assessor identify which criteria to consider. The
criteria relevant to the assessment of hazardous waste are set out in the individual hazard assessments
in Appendix C.
CHIP3 requires chemical suppliers to provide Safety Data Sheets to the recipient of a chemical. The
Safety Data Sheets must contain sufficient information to allow the user to decide how to protect
people and the environment, and this includes providing the classifications of the substances within a
chemical.
If the Safety Data Sheets for a chemical indicate a hazardous property, then a waste containing that
chemical has the potential to be hazardous. Waste holders need to consider if:
• the concentrations of “dangerous substances ” in the waste, after use of the product, remain
sufficient to be hazardous; or
• any reactions take place during the use of the product which may remove the hazard or create
new/different hazards from those of the product.
Labels on chemical containers should also show the risk phrases associated with a product and the
substances found within a product, along with indications of the danger, i.e. symbols, which should
not be mistaken as the category of danger or hazards (See Section 3.1.9). The information on labels
is not as comprehensive as that provided on Safety Data Sheets.
Appendix D identifies some of the sources of data available and discusses data quality issues.
3.1.6 Step 5b: Is there any reason to indicate the waste may be hazardous (e.g. test results)?
Waste holders have a duty to determine if a “mirror entry ” waste is hazardous. Where:
• there are any reasons to indicate the waste may be hazardous, such as test results, knowledge of
the production process or the raw materials used; and/or
• the composition of a waste is not known, cannot be determined or is insufficient to allow
classification using the ASL or other sources.
The waste needs to be tested to determine if it possesses any hazardous properties.
The HWD identifies the test methods in Annex V of Directive 67/548/EEC as the methods to be used
to test for hazardous properties. Where a hazardous property test in Annex V is a non-mammalian
test, that test should be performed on the waste. Where the test is mammalian-based, the Agencies
views are that such tests should not be performed.

Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1) 13
 The Agencies consider that there are two options:
• perform a surrogate non-mammalian biological effect test; or
• if no means of non-mammalian testing is available, do not test, but ascertain from the
producer or other previous waste holders information on the waste before you assume
the waste is hazardous.
There are some tests that can assess a waste as hazardous without recourse to testing the waste on
animals. These include simple inexpensive tests, such as flashpoint or pH determination that can be
used to indicate that a waste is flammable or irritant/corrosive. Some tests do not define specific
hazards but indicate that a waste is hazardous. Standard tests that are acceptable to the Agencies are
given in the individual hazard assessments in Appendix C. Where a non-standard test is used the
findings should be agreed with the Agencies.
It is not expected that a waste holder will assume an unknown waste is hazardous (or not) without
rudimentary testing of the components of the waste, or ascertaining the nature of the waste from
informed sources.
To assist with the classification of complex “mirror entry ” wastes, Appendix B contains a section for
each chapter of the EWC 2002 that highlights the range of components that may be present in the
wastes covered by that EWC chapter.
3.1.7 Step 6: Does the waste possess any of the hazardous properties H1 to H14?
In order for a waste identified by a “mirror entry” to be hazardous it must “display” a hazardous
property. The Hazardous Properties are listed in Table 2.1.
There are two methods of determining if a “mirror entry ” waste is hazardous or not. These are:
• calculating whether the hazardous property is appropriate by referring to a threshold limit for a
particular risk phrase; or
• testing to prove whether a particular hazardous property is present or not.
Calculating
For many wastes the most appropriate method is to identify the hazardous constituents/chemicals in
the waste and then to use their concentrations in the waste to identify whether they confer hazardous
properties on the waste.
• If a waste contains a dangerous substance(s) at a concentration at or above a threshold
concentration for any of the hazardous properties H1 to H14, the waste will be hazardous
and is categorised as the hazardous “mirror entry ”.
• If a waste contains a dangerous substance(s) at a concentration below the threshold for all of the
hazardous properties, the waste will not be hazardous and is categorised as the non-hazardous
“mirror entry”.
Testing
For some hazards testing of physical properties might be the most appropriate method. For example,
to identify whether a liquid waste is flammable or not, for which the threshold is 55oC, a flashpoint
determination is probably the simplest method. This is because the flashpoint depends upon the
concentration of the flammable chemicals in the waste. Other examples of hazards where a test could
be the simplest option are H1 “Explosive” and H2 “Oxidising”.
As discussed in Step 5b, sometimes testing may be the only option to determine whether a waste is
hazardous because of the complex nature of a waste; this is discussed in more detail in Appendix C.

14 Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1)
 Threshold concentrations
Article 2 of the EWC 2002 sets out thresholds for hazardous properties H3 to H8, H10 and H11, which
are derived from Directive 88/379/EEC.
Threshold concentrations for the hazardous properties not covered by Article 2 (H1, H2, H3-A (second
g
to fifth indents), H9, H12, H13 and H14 (with the exception of H9: Infectious )), have been
developed based on the classification and risk phrases from the CHIP3 which implement Directive
88/379/EEC. The thresholds for some of these hazards can be calculated, while others require testing
of physical properties. The assessment of H9 has been developed based on the presence of infectious
substance and this is set out in Appendix C9.
An assessment methodology for each hazardous property is set out Appendix C, and includes:
• definition of the hazardous property;
• relevant risk phrases;
• thresholds;
• a flow diagram setting out the assessment process for that hazardous property; and
• information on test methods.
Table 3.1 summarises the concentration thresholds for each risk phrase or group of risk phrases, how
they relate to hazardous properties and when testing of physical properties should be used to
determine the hazard.

In summary, for Steps 4 to 6:

Identify the composition of the waste (using Appendix B if necessary).

Identify the risk phrases that apply to each component in the waste. The ASL or alternative sources,
such as Safety Data Sheets, should be used to give all the risk phrases for the waste.

Use Table 3.1, which shows substance risk phrases with the associated hazardous property, to identify
the relevant hazards and threshold concentrations that apply to each component.

Record the hazards and threshold concentrations for each component.

If any of the threshold concentrations recorded are exceeded, the whole consignment will be
hazardous. It should be noted that for some hazards concentrations of components in the waste must
be added together to calculate the total concentration of the substances with that hazard. See
Appendix C for specific instances where this procedure applies.

g
CHIP3 does not cover infectious

Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1) 15
 Theoretical Example of Hazardous Waste Assessment Methodology

Waste A , produced in England, from a manufacturing process contains 10% of chemical X

and 18% of chemical Y with the remainder being water.

Step 1: Waste A is a Directive Waste

Step 2: The domestic legislation does not contain specific provisions that relate to this waste.

Step 3: Waste A is listed with a “mirror entry ” on the EWC 2002.

Step 4: The composition of the waste is known.

Step 5a: The waste does contain dangerous substances because:

Chemical X is listed on the ASL and is classified as F; R11, Xn: R20/22; and
Chemical Y, which is not listed on the ASL, has the classification of Xi: R36, Xn: R21 and N: R50,
53, on its Safety Data Sheets.
Water is not listed on the ASL and is not considered to be dangerous

Step 6 : Based on the classifications of the chemical with Waste A could display the hazardous properties
H3 (Highly Flammable/Flammable), H4 (Irritant), H5 (Harmful) and H14 (Ecotoxic):

A test is performed on the waste and the flashpoint is 75oC. H3-A “Highly Flammable” and H3-B
“Flammable ” can be discounted .

The threshold for Xi: R36 identified from Table 3.1 is 20%. This is not exceeded as the
concentration of chemical Y is 18% and the waste will not be classified as H4 “Irritant”.

Classifications Xn: R20/22 and Xn: R21 are appropriate to hazardous property, H5 “Harmful ”. The
risk phrases for harmful are additive and the total concentration of substances with harmful risk
phrases is 28%. The threshold concentration for harmful chemicals is 25% as given in Table 3.1 .
This threshold is exceeded. The waste should be classified as H5 “Harmful ”.

Risk phrase N: R50, 53 is appropriate to hazardous property H14 “Ecotoxic ”. The threshold
concentration for N: R50, 53 chemicals is 0.25%. This threshold is exceeded and the waste
should be classified as H14 “Ecotoxic ”.

Therefore Waste A is hazardous by H5 “Harmful ” and H14 “Ecotoxic ” and the hazardous “mirror entry ”
should be used.

16 Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1)
 Table 3.1: Classifications, Risk Phrases, Hazards and Hazardous Waste Threshold Limits
Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition 2.1)

Classification Hazardous
Category Risk Substance Risk Hazards Waste Threshold Comments
of Danger Phrase Limits

R1 is given the symbol E in the Approved

Supply List but not in the Approved
E R1 Explosive when dry H13 by H1 n/a Classification and Labelling Guide. A waste
containing substances with risk phrase R1 is
a candidate for hazard H13 (by H1) because
it may become dry during disposal.
Risk of explosion by shock, friction, fire
E R2 Test for explosive
or other sources of ignition
H1 by ignition or shock Tests are given in Appendix C1.
Extreme risk of explosion by shock,
R3 friction, fire or other sources of ignition
Forms very sensitive explosive metallic A waste containing substances with these
R4
compounds risk phrases is a candidate for hazard H13
N/a H13 by H1 n/a
R5 Heating may cause an explosion (by H1).
R6 Explosive with or without contact with air

R7 May cause fire

Contact with combustible material may Test and/or Tests are given in Appendix C2; however,
O R8 H2
cause fire calculation test does not apply to organic peroxides.
Explosive when mixed with
R9
combustible material
Flashpoint:
N/a R10 Flammable H3B Tests are given in Appendix C3.
>21oC to 55oC
H3A(i) H3A(i) fpt ≤21oC H3A(i) applies to liquids.
F R11 Highly flammable (H3B) H3A(iii) test H3A(iii) applies to solids.
H3A(iii)
H3A(i) H3A(i) fpt ≤21oC H3A(iv) applies to gases.
F+ R12 Extremely flammable (H3B) H3A(iv) test Tests are given in Appendix C3.
17
18
Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1)

Classification Hazardous
Category Risk Substance Risk Hazards Waste Threshold Comments
of Danger Phrase Limits

This is an additional risk phrase and such a

N/a R14 Reacts violently with water n/a n/a risk phrase alone will not cause a waste to
be hazardous.
Contact with water liberates extremely Test and/or Applies to solids and liquids in the waste.
F R15 H3A(v)
flammable gases calculation Test is given in Appendix C3.
Explosive when mixed with oxidising A waste containing substances with these
N/a R16 substances H13 by H1 n/a risk phrases is a candidate for hazard H13
(by H1).
Applies to solids, liquids and gases.
F R17 Spontaneously flammable in air H3A(ii) Test
Test is given in Appendix C3.
In use may form flammable/explosive A waste containing substances with these
R18 vapour–air mixture H13 by H1 risk phrases is a candidate for hazard H13
N/a n/a
H2 or H3 (by H1, H2 or H3).
R19 May form explosive peroxides
Threshold limit applies to the total
R20 Harmful by inhalation concentration of substances classified as
Harmful. Therefore the concentrations of
Xn H5 ≥ 25% substances with these risk phrases are
R21 Harmful in contact with skin
additive along with the concentrations of
substances with risk phrases R65 and those
R22 Harmful if swallowed with combined/joint risk phrase with R48
and Xn R68.
Threshold limit applies to the total
R23 Toxic by inhalation concentration of substances classified as
Toxic. Therefore the concentrations of
T R24 Toxic in contact with skin H6 (H5) ≥ 3% substances with these risk phrases are
additive along with the concentrations of
substances with combined/joint risk
R25 Toxic if swallowed phrase with R39 or R48.
 Classification Hazardous
Category Risk Substance Risk Hazards Waste Threshold Comments
Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1)

of Danger Phrase Limits

R26 Very toxic by inhalation Threshold limit applies to the total

concentration of substances classified as
Very Toxic. Therefore the concentrations
T+ R27 Very toxic in contact with skin H6 (H5) ≥ 0.1% of substances with these risk phrases are
additive along with the concentrations of
R28 Very toxic if swallowed substances with combined/joint risk phrase
with R39.
Test and/or Test is given in Appendix C12.
N/a R29 Contact with water liberates toxic gas H12
calculation
This is an additional risk phrase and such a
N/a R30 Can become highly flammable in use n/a n/a risk phrase alone will not cause a waste
to be hazardous.
R31 Contact with acids liberates toxic gas H12 Test and/or
N/a calculation Test is given in Appendix C12.
R32 Contact with acids liberates very toxic gas
R33 is used when R48 is not warranted due
N/a R33 Danger of cumulative effects n/a n/a to the degree of danger posed and will not
constitute a hazardous waste in isolation.
The concentrations of substances with R34
C R34 Causes burns H8 (H4) ≥ 5% are additive. However, they are not additive
with corrosive substances assigned R35.
The concentrations of substances with R35
C R35 Causes severe burns H8 (H4) ≥ 1% are additive. However, they are not additive
with corrosive substances assigned R34.
R36 Irritating to the eyes The concentrations of substances with these
Xi R37 Irritating to the respiratory system H4 ≥ 20% risk phrases are additive. However, they are
R38 Irritating to the skin not additive with irritant substances
assigned R41.
19
20
Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1)

Classification Hazardous
Category Risk Substance Risk Hazards Waste Threshold Comments
of Danger Phrase Limits

R39 is only used in conjunction with

combinations of R23, R24, R25 or R26, R27,
R28, which are used to identify the exposure
route. Threshold limit will depend whether
R39 is used in conjunction with a toxic or
T R39 Danger of very serious irreversible effects H6 (H5) ≥ 3%(T) very toxic substance.
T+ ≥ 0.1%(T+) Threshold limit applies to the total
concentration of substances classified as
Toxic or Very Toxic and should be added to
the concentrations of substances with the
same classification.
The concentration of an individual substance
Carc.Cat.3 R40 Limited evidence of a carcinogenic effect H7 ≥ 1% assigned R40 must be above the
threshold limit.
The concentrations of substances with R41
Xi R41 Risk of serious damage to the eyes H4 ≥ 10% are additive. However, their concentrations
cannot be added with irritant substances
assigned R36, R37 or R38.
Xn R42 May cause sensitisation by inhalation Sensitisation has no associated hazard in the
n/a n/a HWD and will not constitute a hazardous
waste in isolation.
Xi R43 May cause sensitisation by skin contact
A waste containing substances with these
N/a R44 Risk of explosion if heated under confinement H13 by H1 n/a risk phrases is a candidate for hazard H13
(by H1).
The concentration of an individual substance
Carc.Cat.1
R45 May cause cancer H7 ≥ 0.1% assigned R45 must be above the threshold
Carc.Cat.2
limit.
The concentration of an individual substance
Muta.Cat.1
R46 May cause heritable genetic damage H11 ≥ 0.1% assigned R46 must be above the threshold
Muta.Cat.2
limit.
 Classification Hazardous
Category Risk Substance Risk Hazards Waste Threshold Comments
Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1)

of Danger Phrase Limits

R48 is only used in conjunction with

combinations of R20, R21, R22 or R23, R24,
R25, which are used to identify the exposure
route. Threshold limit will depend whether
Xn R48 Danger of serious damage to health by H5 ≥ 25% (H6) R48 is used in conjunction with a toxic
T prolonged exposure H6 (H5) ≥ 3% and < 25%(H5) or harmful substance.
Threshold limit applies to the total
concentration of substances classified as
Harmful or Toxic and should be added to
the concentrations of substances with the
same classification.
The concentration of an individual substance
Carc.Cat.1 assigned R49 must be above the threshold
R49 May cause cancer by inhalation H7 ≥ 0.1%
Carc.Cat.2 limit.
N R50 Very toxic to aquatic organisms H14 ≥ 25% The interrelationship between these risk
Very toxic to aquatic organisms and may phrases is complex, with different
N R50-53 cause long-term effects in the aquatic H14 ≥ 0.25% combinations of the risk phrases being
environment additive depending on the particular effect
being considered. Therefore if a waste
contains a range of substances with a range
N R51-53 Toxic to aquatic organisms and may cause H14 ≥ 2.5% of these risk phrases, it is recommended that
long-term effects in the aquatic environment the detailed guidance in Appendix C14 is
used to consider the additive effects.

N/a R52-53 Harmful to aquatic organisms and may cause

H14 ≥ 25%
long-term effects in the aquatic environment
N/a R52 Harmful to aquatic organisms H14 ≥ 25%
May cause long-term effects in the aquatic
N/a R53 H14 ≥ 25%
environment
21
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Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2,1)

Classification Hazardous
Category Risk Substance Risk Hazards Waste Threshold Comments
of Danger Phrase Limits

Criteria for preparations containing substances

R54 Toxic to flora with risk phrases relating to the terrestrial
environment, i.e. R54 to R58, are not currently
R55 Toxic to fauna included in the Dangerous Preparation
Directive (DPD). The classification of
R56 Toxic to soil organisms preparations using these risk phrases will be
N H14 Not available included in the DPD when detailed criteria
for use of these risk phrases have been
R57 Toxic to bees
developed for the Dangerous Substances
Directive. Therefore until the detailed criteria
R58 May cause long-term adverse effects have been developed risk phrases R54 to R58
in the environment should not be considered when assessing
hazardous waste.
Substances that are listed in Annex I to Council
Regulation (EC) No 2037/2000 on substances
N R59 Dangerous for the ozone layer H14 ≥ 0.1%
that deplete the ozone layer and its subsequent
amendments are classified as R59.
Repr.Cat.1 R60 May impair fertility The concentration of an individual substance
H10 ≥ 0.5% assigned R60 or R61 must be above the
Repr.Cat.2 R61 May cause harm to the unborn child threshold limit.
R62 Possible risk of impaired fertility The concentration of an individual substance
Repr.Cat.3 H10 ≥ 5% assigned R62 or R63 must be above the
R63 Possible risk of harm to the unborn child threshold limit.
This is an additional risk phrase and such a
N/a R64 May cause harm to breast-fed babies n/a n/a risk phrase alone will not cause a waste to
be hazardous.
Threshold limit applies to the total
concentration of substances classified as
Harmful. Therefore the concentrations of
Xn R65 Harmful: may cause lung damage if swallowed H5 ≥ 25% substances with R65 are additive with the
concentrations of substances with risk phrases
R20, R21, R22 and those with combined/joint
risk phrase with R48 and Xn R68.
 Classification Hazardous
Category Risk Substance Risk Hazards Waste Threshold Comments
Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1)

of Danger Phrase Limits

Repeated exposure may cause skin dryness This is an additional risk phrase and such a
N/a R66 or cracking n/a n/a risk phrase alone will not cause a waste to
be hazardous.
This is an additional risk phrase and such a
N/a R67 Vapour may cause drowsiness and dizziness n/a n/a risk phrase alone will not cause a waste to
be hazardous.
Muta.Cat.3 R68 Possible risk of irreversible effects The concentration of an individual substance
H11 ≥ 1% (H11) assigned Muta.Cat.3; R68 must be above
the threshold limit.
Xn R68 is only used in conjunction with
combinations of R20, R21, R22, which are
used to identify the exposure route.
Xn R68 Possible risk of irreversible effects H5 ≥ 25% (H5) Threshold limit applies to the total
concentration of substances classified as
Harmful. Therefore the concentrations of
substances with Xn R68 are additive with
the concentrations of substances with risk
phrases R20, R21, R22, R65 and those with
combined/joint risk phrase with R48.

KEY
N/a not applicable
H3A (i) H3A (first indent) “Highly flammable”: - liquid substances and preparations having a flashpoint ≤ 21°C (including extremely flammable liquids).
H3A (ii) H3A (second indent) “Highly flammable”: - substances and preparations which may become hot and finally catch fire in contact with air at
ambient temperature without any application of energy.
H3A (iii) H3A (third indent)“Highly flammable”: - solid substances and preparations which may readily catch fire after brief contact with a source of
ignition and which continue to burn or to be consumed after removal of the source of ignition.
H3A (iv) H3A (fourth indent) “Highly flammable”: - gaseous substances and preparations which are flammable in air at normal pressure.
H3A (v) H3A (fifth indent)“Highly flammable”: - substances and preparations which, in contact with water or damp air, evolve highly flammable gases in
dangerous quantities.
23
 3.1.8 Notes on using Table 3.1
Hazardous waste holders should be aware of the following issues when using Table 3.1.
Concentration effects
The classification assigned to a substance relates to the substance in its pure (100%) form. If a
substance is not pure or is present as a component of a complex mixture the same hazard may not
apply. As an example, ethanol is classified in the ASL as F: R11, which indicates that at 100%
concentration it will have a flashpoint less than 21oC. However, an aqueous (“mirror entry ") waste
containing 4% w/w ethanol, will have a flashpoint greater than 55oC, and so will not be hazardous.
At higher concentrations of ethanol, the flashpoint will reduce to between 21oC and 55oC so the
waste will be hazardous by H3B “Flammable”. At even higher concentrations the flashpoint will be
less than 21oC so the waste will be hazardous by H3A (first indent) “Highly Flammable”. As discussed
above where wastes are concerned a flashpoint determination is probably appropriate to identify
whether the waste is flammable or highly flammable. Table 3.1 shows the effect of such dilution by
listing the subsidiary hazard in brackets e.g. H3A (first indent) (H3B).
Linked hazardous properties
Some hazardous properties are linked because they relate to the same effect:
• H4 “Irritant” and H8 “Corrosive” are linked because they both refer to the potential for harm or
damage to tissue. Preparations containing corrosive substances can exhibit either corrosive or
irritant properties dependent upon concentration of the corrosive substance. However,
substances classified as irritant cannot become corrosive.
Concentrations of irritant and corrosive chemicals and concentrations of chemicals with the
classification C: R34 and C: R35 are not additive when assessing hazardous waste.
• H5 “Harmful” and H6 “Toxic” (including “Very Toxic”) are linked because they both relate to
acute lethal effects. Preparations containing toxic or very toxic substances can exhibit either toxic
or harmful properties dependent upon concentration of the toxic or very toxic substance.
Substances classified as harmful, however, cannot be toxic at any concentration.
Concentrations of very toxic, toxic and harmful chemicals are not additive when assessing hazardous
waste.
Testing and calculation
For certain risk phrases the indicated option is testing and/or calculating: ie testing; or calculating; or
both testing and calculating. In such cases the testing relates to the physical properties of a waste.
The relevant hazards are:
• H1 “Explosive”: the explosive nature of a waste cannot be determined by calculation, therefore
testing is required. See Appendix C1 for details of test methods.
• H2 “Oxidising”: for organic peroxides a calculation method is available, with testing required for
other substances that may potentially exhibit hazard H2. See Appendix C2 for details of both
calculation and test methods.
• H3A (fifth indent) “Highly Flammable” and H12: a calculation or test is always required. If
the composition of the waste is available the gas evolution should be calculated. Alternatively, the
waste can be tested to determine whether 1 kg of the waste will evolve 1 litre of a highly
flammable gas (the test for H3A (fifth indent)) or a toxic/very toxic gas (the test for H12) in one
hour, on addition of water or acid as appropriate. See Appendices C3 and C12 for details of both
calculation and test methods.

24 Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1)
 Highly polluting substances
It is necessary to treat certain substances differently due to their pollution potential and persistence in
the environment, e.g. polychlorinated biphenyls (PCBs) and polychlorinated terphenyls (PCTs).
Therefore specific concentration limits will be set for such substances based on international
agreement. To maintain consistency with international and UK legislation and guidance, the Agencies
consider that the level of 50 mg/kg (0.005%) should be the defining threshold concentration for
wastes containing PCBs and PCTs; above that concentration such waste should be considered as
hazardous waste.
In the future, specific individual thresholds for other highly polluting substances will be set, based on
international agreements, as with PCBs and PCTs.
Additional risk phrases
The Approved Classification and Labelling Guide identifies a number of “additional risk phrases”.
When substances are classified with an “additional risk phrase” such a risk phrase alone will not cause
a waste to be hazardous. As an example, red phosphorus is given risk phrases F: R11 (highly
flammable) and R16 (explosive when mixed with oxidising substances) in the ASL. Red phosphorus is
hazardous by virtue of H3A (third indent) “Highly Flammable”, due to risk phrase R11 but is not
hazardous due to R16. However, if mixed with oxidising substances the resulting mixture might be
classified as H1 “Explosive”, for which a test would be required.
Other risk phrases that are similar to R16 in this respect are R4, R5, R6, R14, R18, R19, R30, R44 and
R64. Some of these risk phrases may give rise to hazard H13 (substances and preparations capable by
any means, after disposal, of yielding another substance which possesses hazards H1 to H12).

3.1.9 Other important notes on the use of CHIP3 to assess hazardous waste
Waste producers familiar with CHIP3 must be aware of the differences when using CHIP3 to assess
hazardous waste.
• The “conventional method” used in CHIP3 to determine the classification of preparations
cannot be used for determining the classification of a hazardous waste. For example, the
concentrations of a “very toxic” substance and a “toxic” substance cannot be added when
assessing hazardous properties whereas they may be for CHIP3 purposes. See “Linked hazardous
properties” in Section 3.1.8.
• Articles such as electronic equipment are not classified as hazardous by CHIP3. However, determining
if such wastes are hazardous means determining whether they, or their components, possess any
hazardous properties. This should be done by considering the classifications of the substances within
the article, or component, and their threshold concentrations with reference to the weight of the
article, or component. The availability of substances is not considered when assessing hazardous waste.
• The ASL considers some preparations such as blends of oils as substances. For the purposes of
classifying hazardous wastes, waste can also be considered as a substance, e.g. for the purposes of
testing, although it remains simpler to classify waste by knowing its chemical constituents.
• The category “Sensitising” (risk phrases R42 and R43) has no associated hazard in the
HWD and will not constitute a hazardous waste.
• Threshold concentrations given in Part I of the ASL do not apply when classifying
hazardous waste.
• Categories of danger and indications of danger should not be confused. An indication of
danger is a symbol used for labelling purposes only and does not specify the category of danger
or hazard, which is the information required to assess hazardous waste. Table 3.2 highlights the
different hazardous properties cover by the indication of danger symbols “Harmful” and “Toxic”.

Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1) 25
 Table 3.2: Comparison of Indication of danger and Categories of danger in relation to Hazardous
Waste

Indication of danger Categories of danger Hazardous Hazardous Waste

Property Threshold Limit
Harmful H5 ≥ 25%
Irritant H4 ≥ 10% or ≥ 20%
depending upon risk
phrase
Sensitising N/a N/a
Carcinogenic, Category 3 H7 ≥ 1%
Harmful Toxic for reproduction, Category 3 H10 ≥ 5%
Mutagenic, Category 3 H11 ≥ 1%
Toxic H6 ≥ 3%
Very Toxic H6 ≥ 0.1%
Carcinogenic, Categories 1 & 2 H7 ≥ 0.1%
Mutagenic, Categories 1 & 2 H10 ≥ 0.1%

Toxic Toxic for Reproduction, Categories 1 & 2 H11 ≥ 0.5%

26 Environment Agency Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd edition v2.1)