Guide to Hazardous Waste and Hazardous Recyclable Material Classification: chapter 4

Classifying Hazardous Waste and Hazardous Recyclable Material Using Codes Required under the Regulations

Paragraph 8(j) of the Regulations specifies information required in a notice of import, export, or transit with respect to each hazardous waste or hazardous recyclable material. Distinct line item numbers are required for each hazardous waste or hazardous recyclable material entry, as well as any information associated with that entry.

4.1 Specific information required in a notice to classify the hazardous waste or hazardous recyclable material

1. The International Waste Identification Code and Basel “Y” codes make up a seven-part code (thereafter referenced in this Guide to Classification as the IWIC) that provides a way of classifying hazardous waste and hazardous recyclable material for export/import/transit purposes.

   Each part of the IWIC is prefixed with a specific letter, to indicate the type of information it contains. The different parts of the code are separated by two slashes (//). In some portions of the code, more than one number can be entered. When more than one entry from a specific appendix of this Guide is used, a plus sign (+) must separate those entries.

   The completed code will have the following form:

   Q_a_(+_a_)*//D,R**_b_//L,P,S,G***_c_//C_d_(+_d_+_d_+_d_)//H_e_(+_e_+_e_)//A_f_//Y_g_(+_g_+_g_+_g_)

   Note:

   * The portions of the code in brackets ( ) may or may not be required, depending on the waste in question.

   ** Enter only one letter: “D” for disposal or “R” for recycling, as set out in column 1 of Appendix 2 or 3, respectively, of this Guide.

   *** Enter only one letter: “L” for liquid, “P” for sludge, “S” for solid, or “G” for gas.

   The IWIC can be obtained as follows using the tables included in this Guide:

   1. Choose the one (or, at most, two) major reason(s) why the waste or recyclable material is intended for disposal or recycling from the list in Appendix 1. Mark your selection as “Q” plus the code number(s).
   2. Indicate the method selected for disposal or recycling by choosing the one operation from either Appendix 2 or Appendix 3 that most closely describes the fate intended for the material. Mark your selection as “D” or “R” plus the code number (only one method by line item is accepted).
   3. Indicate whether the waste or recyclable material is a liquid (L), sludge (P), solid (S) (powders are considered to be solids) or gas (G). Select the one descriptor from Appendix 4 that most closely describes the generic form of the waste or recyclable material. Mark your selection as “L”, “P”, “S” or “G” plus the code number.
   4. Indicate whether the waste or recyclable material does or does not contain any of the constituents listed in Appendix 5. If it does not, mark "C0". If it contains one, mark the appropriate code number. If it contains more than one, estimate the hazard of each constituent (to a maximum of four entries) and indicate them in descending order of importance, using the appropriate C code numbers. The order of importance is an estimate by the notifier based on the quantity, concentration, and hazard characteristic of the waste or recyclable material constituents which is meant to be qualitative. Testing is not required to establish the order of importance. It is based upon the best judgment of the notifier.
   5. Select from Appendix 6 the one (or, at most, three) major potential hazard(s) presented by the waste or recyclable material. Mark your selection as “H” plus the code number(s) indicated for the corresponding TDGR class in the chart below.

      For Classes 2 to 6 and 8 of the TDGR, the corresponding Class is the first “H” code in the IWIC. The subclasses is the corresponding second and third “H” codes (if applicable). For example: for UN1816 the Class is 8 and the first “H” code will be H8. The subclass is 3, therefore the second “H” code would be H3. If there was a sub-subclass, this would be the corresponding third “H” code (except when there is an applicable leachate code (see item 5 below), then H13 would be reported as the second H code, if there is no subclass, or third if there is a subclass. When dealing with cases where there is a leachate code and a sub-subclass, the sub-subclass would be omitted from the IWIC).

      For Class 9, the “H” code does not correspond directly as they can be H10, H11, H12 or H13.

      • H10 is reserved for substances releasing a gas.
      • H11 is reserved almost exclusively to waste or recyclable material containing or composed of asbestos.
      • H12 is substances or wastes, that if released, present or may cause immediate or delayed adverse impacts to the environment by means of bioaccumulation or have toxic effects on biotic systems.
      • H13 is reserved for substances or wastes producing a leachate, which would have a corresponding “L” code from Schedule 6 of the Regulations (see point 5 below).
   6. Indicate the one activity that generated most of the hazardous waste or recyclable material from the list in Appendix 7. Mark your selection as “A” plus the code number.
   7. Select the appropriate “Y” code(s) (four codes at the most) from Appendix 8. If none of the “Y” codes apply, mark "Y0". While this code sometimes duplicates information in the “L”, “P”, ”S”, ”G”, and “C” codes, it is required to meet international reporting obligations. Please note that if the number of the “L”, “P”, ”S”, ”G” code is between 1 and 18, the first “Y” code provided must be the “Y” code of the same number between 1 and 18. For the remaining “Y” codes, if they provide the same information as the “C” codes (see (d) above), they must be provided in the same order as those matching “C” codes.
2. The applicable code set out in Appendix 9 (corresponding to Annex VIII of the Basel Convention)
3. For exports to, imports from, or transits through a country that is subject to the OECD Decision C(2001) 107/Final, the applicablecode set out in Appendix 10 (corresponding to Part II of Appendix 4 of the OECD Decision^Footnote1)
4. The Customs Code (tariff item and statistical suffix) set out in Customs Tariff Departmental Consolidation, published by the Canada Border Services Agency (CBSA)^Footnote2.

   Under the Canadian Harmonized System for these codes, the first six digits of the Customs Code are based on the World Customs Organization’s Harmonized Commodity Description and Coding System. The seventh and eighth digits are for Canadian trade purposes, and the ninth and tenth are the statistical suffix. This code is also a requirement for reporting purposes under the CBSA and Statistics Canada. The HS codes are updated throughout the year by CBSA, therefore please ensure that you consult the latest CBSA Tariff List on the CBSA website prior to submitting your notification to Environment and Climate Change Canada to ensure your notification includes the most updated HS code.

5. The applicable identification number or hazardous constituent code set out in column 1 of Schedule 3, 4, 6, or 7 of the Regulations (e.g. HAZ 1, T1, L1, P001, U001).
6. The UN number, hazard class, and packing or category (as applicable) as set out in Schedule 1 of the TDGR.

   Schedule 1 of the TDGR is periodically updated by Transport Canada and as such some UN numbers are removed and packing groups may have changed. Please ensure you verify the latest Schedule 1 of the TDGR on the Transport Canada website prior to submitting your notification to Environment and Climate Change Canada to ensure your notification includes the most recent UN number as well as associated class(es), and packing group(s).

   Note: In circumstances where waste or recyclable material does not meet the criteria for inclusion in any of the classes 2, 3, 4, 5, 6, 8 and 9 (as per section 2.43) of the TDGR (i.e. there is no applicable UN number based on those hazard criteria), and this waste or recyclable material is considered to be hazardous under the Regulations, one of the following UN numbers applies to the hazardous waste or hazardous recyclable material and must be used^Footnote3:

   • For a liquid, the UN number 3082 (shipping name ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S.),
   • For a solid, the UN number 3077 (shipping name ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S.),
   • Either UN number 3082 or UN number 3077 in the case of sludge (using the corresponding shipping name).

   Therefore, the hazardous waste or hazardous recyclable material is designated as a dangerous good of Class 9 and applicable TDGR requirements are triggered for its transportation.

7. The applicable “D” or “R” code from Appendix 2 or 3 (corresponding to annex 1 or 2 of the Regulations), as well as the name and description of the process to be employed for every applicable operation associated with that entry
8. The name, quantity, and concentration of any persistent organic pollutant (POP) set out in Schedule 10 of the Regulations that is contained in the hazardous waste and hazardous recyclable material, if applicable.

Please ensure that all codes utilized, to describe the hazardous waste or hazardous recyclable material, make sense together because many inconsistencies are still observed during the review process for notifications.

4.2 Other information required

Paragraph 8(j) and (k) of the Regulations also require that additional information be provided for each type of hazardous waste or hazardous recyclable material recorded on the notice.  This information includes:

• The total quantity in kilograms or litres of each hazardous waste or hazardous recyclable material proposed for export, import, or transit. Note that the same unit of measure must be used in the movement document (kilograms or litres). A common error on the movement document, in particular for shipments from the USA, is to use measures from the Imperial system (pounds and gallons) which don’t match the unit of measure used on the notification.
• For exports for final disposal, a note in writing explaining the options considered for reducing or phasing out the export, and the reason the final disposal is taking place outside Canada