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LER code: Key to the clarification of unregulated asbestos discharges at Zaldibar
  • Why is it so important to know how to read the European Waste List (RSI)? Because at the moment this is a case of asbestos dumped out of the ordinary in the Zaldibar dump in 2012. The 2007 Basque Government’s Integrated Environmental Authorisation (AAI) did not grant it this authorisation, while the Basque Government’s Environmental Department says yes, that this AAI includes the authorisation for the discharge of asbestos. Let us see what exact authorization is granted by AAI 2007 and which does not grant it.
Estitxu Eizagirre @eeizagirre 2020ko otsailaren 28a

The updated European Waste List (RSI) can be found on the European Union website. It was on 18 December 2014 that the last amendments were made to it. All waste management companies should identify each waste in order to accurately identify its nature and specific characteristics. Thus, their treatment possibilities are evaluated. LER is a European identification system and is a code of figures. This system characterises waste from its origin and origin.

Key: RSI designates waste with six figures

In order to know what waste can be collected and which not by a waste management infrastructure (e.g. in the case of Zaldibar, the Verter landfill), the Integrated Environmental Authorisation (AAI) that the Environment Department of the Basque Government has granted this particular infrastructure and to see in it the list of authorised waste. This list of authorised types of waste specifies which of the European Waste List (LER) can be managed in this infrastructure. Here we can see the specific types of waste authorised by the first IBB of the Basque Government in 2007 (from page 42).

In the following figure you can see exactly what it says about asbestos waste:

 

 

 

It is the title of the chapter "Insulation and construction materials with asbestos" (17 06), with four figures. The only type of residue in this chapter is that permitted by the Integrated Environmental Authorisation 2007: "Insulation materials", as is necessary for the designation of waste, which consists of six figures: 17 06 04. Therefore, asbestos does not appear as authorised waste, as six figures are needed to do so.

 

 

 

The European Union's own final document explains how the RSI defines waste under the heading "Waste list" (translated into wording):

"The different types of waste are perfectly defined with six figures and the titles of the chapters with four and two figures. The following procedure shall be used to locate a residue on the list: (...) search for the appropriate six-digit code for that residue."

As shown in the figure above, the Integrated Environmental Authorisation 2007 did not authorize the type of residue called "asbestos materials": 17 06 05 is the number of this concrete residue containing asbestos and is not included in the authorisation.

Environment continues to read the LER code erroneously

This ARGIA news was published by El Salto in Spanish on February 27. On social media, the Environment Department of the Basque Government has responded that the 2007 Integrated Environmental Authorisation approved asbestos-containing waste and cites the four-digit chapter as evidence.

The ARGIA medium, in addition to consulting the European Union document governing the LER code referred to in this article, and checking that the same criterion for the designation of waste is also included in the Official Gazette of Spain (see entry point B), has consulted experts qualified in the matter and all have considered as evidence that according to the LER code, the types of waste are described in this chapter and are not explained in this section.