While Watching the waste line (NCE 18 November) related to 'hazardous' wastes, there could also be considerable cost implications for 'nonhazardous' wastes arising from basic engineering operations.
The issue centres on when engineering materials become waste and, equally, when they cease to be waste. Routine pavement repairs, for example, will generate waste because any excavated materials are considered 'discarded' - a crucial parameter for defining waste.
The fact that the particular excavated materials might be re-used or recycled elsewhere, at some unknown time or location, would not place them outside the waste regulatory regime. Furthermore, there are time and volume limits on the storage of such innocuous wastes.
Worse still, some could be classified as hazardous if they contain coal tar or, for example, a high hydrocarbon content.
So, whether you are the Highways Agency, a highway authority, Network Rail or even the Environment Agency, in the engineering role, make sure you can classify such wastes and arrange due licence exemptions.
David Barry (F), DLB Environmental dlbarry@btinternet. com