This website describes action research by Andrew Wood, a researcher and environmental campaigner, into the regulation of ash from waste incinerators (Incinerator Bottom Ash) by the Environment Agency (for England and Wales) for H14 ecotoxic hazard. Please note that H14 is a hazardous property which is not specific to only IBA but one of 15 hazardous properties against which all wastes need to assessed in deciding whether they are hazardous waste.
In autumn 2007, the Environment Agency held a public consultation 'Hazardous Waste - H14 Ecotoxicity Assessment'. A report about the consultation is published on this website. Other research, between 2008 and 2011, involved: information
requests to the Environment Agency (PDF); requests for disclosure to the Environmental Services Association (ESA) – an organisation representing waste companies and incinerator operators; requests for disclosure to Veolia - a waste company operating incinerators in the United Kingdom and elsewhere; and parliamentary questions to the Secretary of State for the Environment (PDF). The refusal by the Environment Agency to disclosed information as required by the
The research showed that the Environment Agency and the ESA had been in discussions about the classification of Incinerator Bottom Ash in relation to H14 ecotoxicity. A report was commissioned by the ESA for the Environment Agency using sampling from from six waste incinerators in the UK belonging to Veolia. The ESA advocated a testing methodology using 'direct testing' for H14 ecotoxicity hazard over conventional chemical testing for this hazardous property. The Environment Agency rejected the ESA's assertion that IBA should be classified as non-hazardous for H14 ecotoxicity (it remained a 'mirror entry' - as used in the EU's list of wastes); and it maintained conventional chemical testing - a risk-based approach - was suitable for H14 classification.
Subsequently, the ESA adopted a representative sampling protocol for IBA (PDF) which describes how samples should be gathered at the incinerator site for testing of hazardous properties. Note: the sampling protocol is separate to the testing procedure /classification of a IBA sample for H14 ecotoxicity.
In December 2010, The Guardian published an article by George Monbiot about this research, including reference to estimated cost benefits of IBA being classified as non-hazardous (PDF).
Acknowledgement
The author would like to acknowledge the support of the following organisations for providing seed funding for the project: Artists Project Earth and The Manuka Club. The support of the following individuals and organisations is also appreciated: The Environmental Law Foundation (UK), Laura John, Uk Without Incineration Network, Oxford Friends of the Earth, Ray Foulk, George Monbiot, and the Member of Parliament for Oxford East - Andrew Smith.
Links to other useful information
Environment Agency's Hazardous Waste: Interpretation of the definition and classification of hazardous waste (2nd Edition v 2.3 - 2nd edition revised and republished April 2011). (PDF)Wikipedia entry for Action Research
UK Without Incineration Network