EU Council Regulation regarding HP 14 „Ecotoxic“

Council Regulation regarding HP 14 „Ecotoxic“ results in new hazardous waste streams.

The Council Regulation (EU) 2017/997 amends the previous definition for the hazardous property HP 14 “Ecotoxic”. One of these new criteria defines waste which contains a substance

classified as ozone depleting assigned the hazard statement code H420 in accordance with Regulation (EC) No 1272/2008 of the European Parliament and of the Council and the concentration of such a substance equals or exceeds the concentration limit of 0,1 % as hazardous. This regulation applies from 5 July 2018.

According to a new Code of Practice released on 26th June 2018 by the Austrian Ministry for Sustainability and Tourism it is from now on necessary in a first step to determine if a waste stream contains ozone depleting substances such as CFCs, HCFCs, HFCs in such a degree, that the hazard property of HP 14 is fulfilled. If this is the case, this waste stream has to be regarded as hazardous.

The Insulation foam of refrigerators which was produced by using CFCs, HCFCs, HFCs as a blowing agent, usually contains 8,5% of these blowing agents before treatment. Having in mind that the limit value for the residual content of CFCs, HCFCs, HFCs after treatment is set with 0,2% in the actual valid CENELEC standard, leads to the assumption that in many cases the remaining PUR fraction after step 2 treatment has to be considered as being a hazardous waste stream.

Essential for the classification is therefore if a sufficient degassing of the insulation foam in step 2 of the usual treatment of refrigerators has taken place or not. This degassing process is costly due to the technical ambitious and time-consuming process needed. During this process the pores of the foam have to be grinded to a very fine dimension combined by heating up the foam in order to achieve a residual content of CFCs, HCFCs, HFCs less than 0,1%. This can apparently not be achieved by every treatment plant, because otherwise the threshold of the CENELEC standard would have been set at this lower value.

On the other hand, only in that cases where there is clear evidence that the PUR-waste fraction meets the requirement that the residual content of CFCs, HCFCs, HFCs is less or equals 0,1%, it can be regarded as non-hazardous. In all other cases this kind of waste has to be treated as hazardous waste from the 5th of July 2018 onward.

But not only insulation foam from refrigerators is going to be affected by this new criterion, also insulation foam used in the field of construction like XPS was produced by using CFCs, HCFCs, HFCs as a blowing agent before 2009. This means that also this kind of insulation panels have to be treated like refrigerators in order to provide a sufficient degassing or they have to be incinerated in treatment plants for hazardous waste.

Property HP 14, Ecotoxic

Christian Keri Ph.D.
Scheugasse 14/14
1100 Vienna
Austria


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