Safety Management Plan
A waste survey serves as the starting point for effective waste management and the identification of more environmentally and economically sustainable alternatives to landfilling.
Conducting a waste survey requires comprehensive data collection, definition, and classification of all hazardous and non-hazardous wastes generated at the facility.
Waste Classification
Classifying waste is an essential part of the waste management process.
Based on the type of waste (hazardous or non-hazardous), one can determine appropriate handling procedures, assess the level of risk to which employees are exposed, define necessary precautionary measures, and understand the cost implications of waste and wastewater disposal.
Hazardous waste must be managed in accordance with the requirements of the Hazardous Materials Permit and cannot be stored at a facility for more than six months (although stricter or more lenient regulations may apply in certain cases).
The approach to hazardous (or non-hazardous) waste is dictated by the Hazardous Materials Law (1993), which defines "hazardous waste" as any material containing a hazardous substance that is disposed of, intended for disposal, or must be disposed of under any legal requirement. However, this definition is outdated and problematic.
Currently, an absurd situation exists: "waste" in Israel is defined differently from its definition in the USA or Europe. For instance, a material exported from the USA to Israel may be shipped as waste, despite not being classified as such in its country of origin, and vice versa.
Another instance in which we encounter regulatory conflicts is when searching for alternative solutions for waste streams based on circular economy principles, aiming to find new uses for one company's waste as a resource for another.
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Key Points About Waste Surveys
When it comes to conducting a waste survey, precise and unified classification is of great importance, particularly for waste export, regulatory reporting, monitoring, and the optimal treatment of specific materials.
The European Waste Catalogue (EWC) system has been adopted in Israel in recent years, although it has been established in Europe for over 15 years.
Under this system, waste streams are classified based on the production process and industry of origin, for example, wastewater from the pharmaceutical industry or mineral oils from oil separators.
The catalogue includes:
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408 types of hazardous waste
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434 types of non-hazardous waste
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180 "mirror entries": wastes that can be classified as either hazardous or non-hazardous depending on specific characteristics.
Mirror entries must be assessed on a case-by-case basis. A mirror entry is classified as hazardous unless analysis and testing prove otherwise.
Over time, the classification method has been refined to account for not only the waste category but also the associated risk levels.
The Ministry of Environmental Protection has adopted the European Directive 2006/12/EC, and soon corresponding regulations are expected to be enacted into Israeli law.
Hazard Characteristics
Fourteen main hazard characteristics have been defined, labeled HP1–HP14. These hazard properties resemble those for hazardous materials but are not identical:
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HP1 – Explosive
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HP2 – Oxidizing
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HP3 – Flammable
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HP4 – Irritant (causes skin or eye irritation)
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HP5 – Specific target organ toxicant; toxic if inhaled
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HP6 – Acute toxic
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HP7 – Carcinogenic
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HP8 – Corrosive
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HP9 – Infectious
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HP10 – Reproductive toxicity
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HP11 – Mutagenic
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HP12 – Releases acutely toxic gases
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HP13 – Sensitizing
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HP14 – Ecotoxic
The classification method is based on the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).
Each hazard property is assessed by a series of tests, using clear parameters, to determine whether the waste exhibits specific hazardous characteristics.
If certain hazard properties can be ruled out due to the source or manufacturing process of the waste, there is no need to conduct further analytical testing for those properties.