RIVM guidance to decide whether the waste stream can be safely recycled - Risk inventory for SVHCs
SYNOPSIS - Currently there are all kinds of ongoing initiatives to recycle waste streams (circular economy). Waste can contain hazardous substances. Regulations exist to prevent hazardous substances from ending up in the environment. Waste which contains substances of very high concern are subject to specific rules which provide a basis for deciding whether they can be recycled or should be disposed of. These regulations are part of the national waste management plan (LAP3), which went into force end of 2017.
Part of the national waste management plan is a risk inventory with respect to substances of very high concern, in case that these substances not can be separated from the waste. RIVM advices with this guidance and background document on how to perform a risk inventory.
The guidance describes a decision scheme for authorisation holders to decide whether the waste stream can be safely recycled. At first hand the authorisation holder should consider if the substance of very high concern can be removed from the waste stream. If the substance of very high concern cannot be removed a risk inventory is needed for the applications of interest. The outcome of the risk inventory provides insight if the risk related to the presence of substance of very high concern is acceptable or not.
The basis of the risk inventory is a set of aspects which have to be considered according to LAP3. An example of one of these aspects is to what extent a substance of very high concern can be released from the new product. When the outcome of the risk inventory is not decisive, the decision scheme provides a possibility to refine the risk inventory. If risks are determined to be not acceptable, no authorisation can be granted for the new application. An alternative application should than be selected for which risks are considered acceptable.