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Waste classification
A waste, and in particular a mixture, may have hazard characteristics that bring it within the scope of several hazard classes or groups of materials, or have a composition that is not exactly known.
To classify waste, you need to know its physical and chemical characteristics, use the SDSs for the products making up the waste, or seek the advice of a chemist and apply the procedures defined in the ADR.
Classification of substances designated by name or having a single hazard characteristic
If the waste is composed of a substance specifically named in the ADR, it will be classified under this heading:
Example: Waste composed of gasoline: UN 1203 WASTE GASOLINE, 3, II, (D/E) ENVIRONMENTALLY HAZARDOUS
If the waste is composed of substances with only one hazard characteristic or of substances which are not specifically named, the most accurate collective entry for the waste in the hazard class in question should be used:
Example: Waste composed of gasoline and diesel: UN 3295 WASTE HYDROCARBONS LIQUID NSA (Gasoline, diesel), 3, II, (D/E) DANGEROUS FOR THE ENVIRONMENT
Classification of waste presenting several hazards (mixtures)
Step 1: Preponderance of hazard classes :
If a waste with several hazard characteristics falls into one of the following classes or groups of materials, it will automatically be classified under that class or group of materials with the predominant hazard, in the following order:
- Class 7 - Radioactive materials
- Class 1 - Explosives
- Class 2 - Gas
- Desensitized explosives (classification code D) of Class 3 (e.g. UN 1204 Nitroglycerine in alcoholic solution, UN 2059 Nitrocellulose in flammable solution)
- Self-reactive substances (classification code SR) and desensitized explosives (classification code D) of Class 4.1 (e.g. UN 1344 Trinitrophenol (picric acid) moistened with at least 30% (by mass) of water ...)
- Class 4.2pyrophoric substances (ignite in contact with air)
- Class 5.2 Organic peroxides
- Class 6.1 substances meeting the inhalation toxicity criteria of packing group I
- Class 6.2 - Infectious substances
Step 2: Preponderance by named materials:
If the following named substance is present, the waste must be classified under the UN number of this substance:
- Class 3 (UN 1921 and 3064),
- Class 6.1 (UN1051, 1185, 1259, 1613, 1614, 1994, 2480, 2481, 3294) and
- Class 8 (UN 1052, 1744, 1790, 2576),
- Class 9 under UN numbers 2315, 3151, 3152, 3432,
Step 3 (most common case):
If the waste does not belong to any of the above categories, the hazard predominance table in 2.1.3.10 ("double entry") is used to determine the main hazard class and subsidiary hazard(s), and the waste will be classified under a collective heading of this main class.
Example: Mixture of ethanol (Class 3, II) and hydrochloric acid (Class 8, III)
According to the hazards predominance table in 2.1.3.10, classification under class 3 (flammable) packaging group II is predominant. The mixture will therefore be classified in class 3 with subsidiary risk 8 - Corrosive :
Collective heading : UN 2924 WASTE FLAMMABLE LIQUID, CORROSIVE, N.O.S. (ETHANOL, CHLORHYDRIC ACID), 3 (8), II, (D/E)
Waste whose composition is not exactly known (2.1.3.5.5) :
In the case of waste whose composition is not exactly known, classification may be based on the consignor's knowledge of the hazards of the waste.
When in doubt, choose the highest degree of hazard.
In this case, with the exception of UN 3077 and UN 3082 (environmentally hazardous substance), packing group III cannot be assigned: packing group II must be assigned to the waste, if it can be demonstrated that it does not fall into packing group I.
The words " DECHETS CONFORME AU 2.1.3.5.5" (WASTE IN ACCORDANCE WITH 2.1.3.5.5) will appear on the transport document (the BSD if used as an ADR transport document).
Example: Effluent which the sender knows presents a flammability risk, but whose composition is not exactly known:
A 1993 FLAMMABLE LIQUID NSA, 3, II, (D/E) WASTE CONFORMING TO 2.1.3.5.5
REMINDER: Remember that, even if you rely on the skills or resources of a third party (waste service provider in particular), as the sender you remain responsible for the classification of your waste.
Choice of packaging and preparation of parcels
Choice of packaging
The choice of packaging is made by identifying the packing instructions listed in Table A of the ADR, for each UN number.
The general rule is to use approved packaging (meeting various tests: drop, pressure, etc.) for the transport of dangerous goods.
- Approval certificate : The site must ensure (as packager) that it holds a copy of the packaging's approval certificate.
- Service life of rigid plastic packaging: Rigid plastic packaging has a maximum service life of 5 years (New ADR 2025 - Paragraph 4.1.1.21.7: 2.5 years in the case of waste containing chlorinated compounds in particular) following the date of manufacture.
- Use of Intermediate Bulk Containers (IBCs): IBCs are subject to periodic inspection by an approved body every 2.5 years .
Adaptations for certain types of waste
The packaging instructions may derogate from this rule (with conditions) for certain wastes (used aerosols, mixed batteries, UN 2794 acid batteries, 3509 waste packaging, etc.).
For example:
Empty uncleaned waste packaging (UN 3509): Empty uncleaned discarded packagings shipped under UN 3509 may be packed in non-approved packagings complying with packing instructions P003/RR9, IBC08/BB3 or LP02/LL1. Packagings must be rigid and leakproof. Flexible packaging may be used if there is a total absence of liquid (e.g. non-approved pallet box).
Used aerosols: Discarded aerosol dispensers must be packed in accordance with packing instruction P207: unapproved rigid outer packagings with a maximum net mass ≤ 55 Kg (cardboard) or 125 kg (materials other than cardboard)) and special provision P
The latter stipulates that packaging must be adequately ventilated to prevent the formation of hazardous atmospheres and pressure build-up. In addition, the packaging must be fitted with a means of retaining any released liquid likely to escape during transport, such as an absorbent material or bag.
Package marking and labelling
The next step is to :
Marking: UN number (in general, the characters must be at least 12 mm high) and any additional markings or information required (Example of special information: "LITHIUM BATTERIES FOR RECYCLING" for used batteries containing lithium cells or batteries transported under special provision 377 or 636).
Labelling : Main and subsidiary hazard labelling (where applicable) of the package based on column 5 of ADR table A: 10 x 10 cm labels (with exceptions).
Intermediate bulk containers (IBCs) with a capacity of over 450 liters and large packages must bear labels on two opposite sides.
Mark DANGEROUS FOR THE ENVIRONMENT
Packages containing environmentally hazardous substances (see CLP hazard statements H400, H410, H411, H412, H413, H420) must bear the "environmentally hazardous substance" mark , except in the case of single or combination packagings having, per single packaging or combination inner packaging as appropriate :
- A quantity less than or equal to 5 l for liquids; or
- A net mass less than or equal to 5 kg for solids.
ARD 2025: The reconditioning of discarded chemical packaging
Creation of articles 4.1.1.5.3 and 5.4.1.1.3.3
If your site is faced with the disposal of liquid or solid residues contained in inner packagings of different sizes and shapes for which you no longer have the original outer packaging (e.g. disposal of chemical bottles for which you no longer have the original approved carton), you can now repackage them in another outer packaging. The main conditions are :
- The inner packaging must contain goods in classes 3, 4.1, 4.2, 4.3, 5.1, 5.2, 6.1, 8 or 9 only.
- The outer packaging must be a pack (1H2, 1A2, 3A2, 3H1, 3H2, 4A, 4H2), an IBC (11A, 11H1, 11H2) or a large pack (50A, 50H),
- The outer packaging must withstand the tests of packaging group I (the most resistant packaging),
- The chemical compatibility of polyethylene (PE) packaging is demonstrated if the chemical compatibility of PE with all reference liquids has been verified for 1H1 or 3H1 polyethylene packaging,
- Mixed packing ("MP") restrictions are respected,
- Packing is carried out by personnel who have received appropriate and detailed training.
Selection of service providers and carriers
It is essential to use a waste service provider who has been issued with a "récépissé de déclaration" for waste transport and who has appointed a safety advisor for the transport of dangerous goods (CSTMD). In addition to the CSTMD certificate, it may be useful to ask carriers for their CSTMD declaration certificates on the government portal.
Drawing up the transport document
Use of BSD TRACKDECHETS: It is permitted to use the waste tracking slip (BSD).
Dematerialize TrackDéchets as a dangerous goods transport document, if it bears all the information required by the ADR : Proper shipping name, number and description of packages, quantities, any additional information required (e.g. "DANGEROUS FOR THE ENVIRONMENT" for materials meeting this criterion).
The words WASTE or WASTE CONFORMING TO 2.1.3.5.5 will be added to the designation depending on the case and classification procedure (see above):
Examples:
UN 1203 PETROL WASTE, 3, II, (D/E) HAZARDOUS FOR THE ENVIRONMENT
A 1993 FLAMMABLE LIQUID NSA, 3, II, (D/E) WASTE CONFORMING TO 2.1.3.5.5
Estimated quantity: Since ADR 2023, it is possible to indicate an estimated quantity under certain conditions. The words ESTIMATED QUANTITY PURSUANT TO 5.4.1.1.3.2 must appear on the transport document.
Partial exemption 1.1.3.6 : If the partial exemption of 1.1.3.6 is applied, then the following must also be included
provide a summary of total quantities and "calculated values" (coefficients) for each transport category on the transport document. In this case, it may be useful to use a loading summary accompanying the BSDs.
Reminder: The estimated quantity cannot be used under this exemption based on the quantities actually loaded on board the transport unit.
Shipping control
It is recommended to fill in checklists to verify the provisions applicable to shipments, within the framework of the responsibilities of the establishment where the loading takes place, as defined in 2.1 of appendix I of the decree of May 29, 2009 (TMD), as amended:
- Checking the driver's training certificate (ADR driver's certificate)
- Check vehicle signage: orange panels (parcel transport)
- Checking compliance with mixed loading bans (with explosives)
- Checking the wedging and securing of packages
- Check and issue transport document (BSD TRACKDECHET if used as MD transport document)
Training your staff
ADR 1.3 training must be provided to persons in charge of :
- Selection, purchase of packaging, service providers,
- Drawing up the transport document (creation and verification of ADR information on BSDs in TRACKDECHET if used as a transport document)
- Package preparation: choice of containers, marking and labelling
- Loading transport units
- Shipment control.
This training must be periodically refreshed to take account of changes in regulations (TDG decree and ADR every two years), but the ADR does not formally specify a frequency.
Feedback management
A feedback system is needed to identify the types and number of incidents, accidents and events linked to waste management and treatment (implementation of remedial or improvement actions).
Event declaration
In addition, in 2024, the Transport of Dangerous Goods Mission (MTMD - responsible within the Directorate General for Risk Prevention for the regulation of the transport of dangerous goods) set up a service to of "events involving dangerous goods" (via "Cerbère" authentication). (via "Cerbère" authentication).
Reminder The accidents or serious incidents referred to are those occurring during the loading, filling, transport or unloading of dangerous goods if the consequences exceed certain criteria set out in 1.8.5.3 of the ADR:
- Bodily injury: Death, intensive medical treatment, hospital stay of at least 1 day, inability to work for 3 consecutive days or,
- Product losses: Quantities in excess of 50, 333 or 1,000 liters / kg, depending on merchandise transport categories (0 and 1 / 2 / 3 and 4) or
- NB : It should be noted that this criterion also applies if there is an imminent risk of product loss, and in particular if the damage to the means of transport (packaging, tanker, etc.) is too extensive to allow transport to continue in complete safety.
- Property damage: Over €50,000 (excluding cost of transport equipment) or,
- Intervention by authorities or emergency services: evacuation of people or closure of road infrastructure for at least 3 hours.
And CSTMD?
The ADR requires that any company whose activities include the shipment or transportation of dangerous goods by road, or the related operations of packing, loading, filling or unloading, appoint one or more safety advisors.
The decree of May 29, 2009 (TDG decree) specifies the exemptions from the requirement to designate a CSTMD in France. In particular, the following are exempted
- Shipments of dangerous goods in packages, in quantities below the thresholds defined in 1.1.3.6 of the ADR, and packaging, loading or unloading operations of dangerous goods in packages, in quantities below these thresholds per operation,
- Occasional loading or shipment of packages in a transport unit for national transport, if the number of operations per year does not exceed two...
Any site with at least one tanker shipment is required to appoint a CSTMD.
The declaration of your CSTMD must be made on the platform of the Ministry of Ecological Transition. Your CS annual report should only be uploaded to this platform if requested by the authorities (DREAL, DEAL, DRIEE, DRIEA, etc.).