An official from the Ministry of Ecology and Environment answered questions from reporters regarding the “General Criteria for Identifying Hazardous Waste” and the “Technical Specifications for Hazardous Waste Identification.”

Release Date:

2019-11-23

Recently, the “General Criteria for the Identification of Hazardous Waste” (GB 5085.7‑2019) (hereinafter referred to as the “General Criteria”) and the “Technical Specification for the Identification of Hazardous Waste” (HJ 298‑2019) (hereinafter referred to as the “Technical Specification”) have been promulgated and put into effect. An official from the Ministry of Ecology and Environment addressed reporters’ questions regarding the background and guiding principles behind the revisions of the General Criteria and the Technical Specification.
　　Q: What are the main background and guiding principles behind the revision of this edition of the General Provisions and the Technical Specifications?
　　Answer: The “General Rules” and the “Technical Specifications” are two key standards within the hazardous waste identification system. The “General Rules” set forth the procedures and criteria for identifying hazardous waste, serving as the foundation of the hazardous waste identification standard system; the “Technical Specifications” specify the technical requirements for sample collection, testing, and evaluation in the hazardous waste identification process, constituting the fundamental guidelines for standardizing identification work. These two standards were formulated and first promulgated in 2007, playing an important role in regulating hazardous waste identification and environmental management.
　　In recent years, as the standardized management of hazardous waste has been further strengthened, local authorities have systematically carried out hazardous‑waste identification activities. However, shortcomings in the General Rules and Technical Specifications—such as unclear identification targets, imprecise sampling methods, inadequately rational judgment criteria, and lengthy identification cycles coupled with high costs—have gradually become apparent, rendering these documents increasingly ill‑suited to meet the requirements of hazardous‑waste environmental management. Consequently, there is an urgent need to revise and refine the standards for hazardous‑waste identification to align with China’s evolving needs in hazardous‑waste management and identification.
　　The guiding principles behind this revision of the standard are as follows: first, to refine the procedures for identifying hazardous waste, ensuring accurate classification and effective management of environmental risks; second, to optimize technical requirements for sampling, testing, and related processes, thereby shortening the identification timeline and reducing associated costs; and third, to promote the resource‑based utilization of hazardous waste, conserving resources that would otherwise be allocated to incineration or landfill disposal, and fostering greater diversity in the methods used for its treatment and disposal.
　　Q: What are the main contents of this revision of the General Provisions?
　　Answer: The main contents of this revision of the General Provisions encompass three aspects:
　　First, the identification procedure has been refined: Clause 4.3 has been amended to read as follows: “Solid wastes that are not listed in the National Catalogue of Hazardous Wastes but cannot be ruled out as possessing corrosivity, toxicity, flammability, or reactivity shall be identified in accordance with GB 5085.1, GB 5085.2, GB 5085.3, GB 5085.4, GB 5085.5, and GB 5085.6, as well as HJ 298. ……”
　　Second, the criteria for determining whether mixed hazardous waste qualifies as hazardous waste have been revised, stipulating that the outcome of the mixing—namely, “the propagation of hazardous characteristics to other materials”—shall serve as the prerequisite for classifying the resulting solid waste as hazardous.
　　Third, the criteria for determining the status of solid waste generated during the utilization of hazardous waste with toxic hazardous characteristics have been revised: “Solid waste produced in the process of utilizing hazardous waste that possesses toxic hazardous characteristics shall not be classified as hazardous waste if, upon identification, it no longer exhibits such characteristics.”
　　Q: This edition of the General Provisions has refined the identification procedures. What impact does this have on the identification process?
　　A: This revision of the General Rules has refined and optimized the identification procedures, making the hazardous waste identification system more practical and operable. For example, for solid wastes that are not listed in the National Catalogue of Hazardous Wastes and thus require identification, follow-up characteristic testing is conducted only when it cannot be ruled out that they possess hazardous characteristics. If, based on their raw and auxiliary materials and production processes, it can be determined that they do not exhibit hazardous characteristics, then no further hazardous‑characteristic testing or supplementary tests are required; instead, a determination can be made directly that the solid waste does not have hazardous properties, thereby avoiding unnecessary over‑testing in the hazardous waste identification process.
　　Q: This revision of the General Provisions has amended the post‑mixing determination rules. What should be kept in mind when applying these rules?
　　Answer: The mixed‑waste determination rule stipulated in the original General Provisions played a crucial role in preventing the dilution of hazardous waste. However, years of practical experience have shown that this rule has also led to an increase in both the volume and the disposal costs of the resulting mixed waste. To avoid such outcomes, Article 5.1 of the newly revised General Provisions builds on the original rule’s criteria for assessing mixing by adding a consequential assessment: “resulting in the spread of hazardous characteristics to other materials.”
　　When applying post‑mixing determination rules in identification work, two points must be borne in mind: first, the “mixing” referred to in the General Provisions denotes the act of combining two or more solid wastes or substances originating from different sources or generation points; second, it is necessary to assess, based on the speciation of pollutants in hazardous waste and the migration of substances during the mixing process, whether the mixing results in the spread of hazardous characteristics to other materials, thereby determining whether the post‑mixing determination rules are applicable.
　　Q: This revision of the General Rules has introduced criteria for determining whether hazardous waste has been properly utilized or disposed of. What should be kept in mind when applying these criteria?
　　Answer: In this revision, the “Post‑Treatment Determination Rules” from the original General Provisions have been replaced with “Post‑Utilization and Disposal Determination Rules,” which are now stipulated separately for two scenarios: the utilization process and the post‑disposal phase. During the identification process, when applying the post‑utilization and disposal determination rules to hazardous waste, the following two points should be kept in mind:
　　First, the “utilization” scenarios to which these General Rules apply refer to activities involving the extraction of substances from solid waste for use as raw materials or fuels. For example, this includes extracting valuable metal elements from heavy-metal‑containing solid wastes such as electroplating sludge, and recovering mineral oil from waste mineral oil and oil‑containing sludge. The characteristics of solid waste generated during the utilization process may be determined in accordance with the identification procedures set forth in Chapter 4 of these General Rules. If the solid waste produced during utilization has already been listed in the National Catalogue of Hazardous Wastes, no hazardous characteristic identification is required, and such waste shall continue to be classified as hazardous waste.
　　Second, solid wastes generated after the disposal of hazardous wastes with toxic hazardous characteristics, or after the utilization and disposal of hazardous wastes with infectious hazardous characteristics, may be exempted from hazardous waste management if specific provisions are stipulated in relevant national laws and standards; otherwise, they shall still be classified as hazardous wastes. Solid wastes produced from the disposal of hazardous wastes that possess only one or more of the hazardous characteristics—corrosivity, flammability, or reactivity—may have their waste classification determined through a characterization procedure.
　　Q: What are the key highlights of this revision to the Technical Specifications?
　　Answer: The key revisions to this edition of the Technical Specification cover the following three areas:
　　First, the scope of application has been expanded. Provisions have been added regarding the procedures and technical requirements for identifying the hazardous characteristics of solid waste involved in environmental incidents, thereby enhancing the soundness of the identification process for solid waste associated with illegal transfer, dumping, storage, utilization, and disposal, as well as for solid waste generated during emergency environmental events and their subsequent handling.
　　Second, technical requirements have been optimized. The criteria for identifying objects, the number of subsamples, sample testing, and the interpretation of test results have been further refined and clarified for different scenarios, thereby enhancing the feasibility of identification work. The provisions governing the number of subsamples in the identification process have been revised, and the basis for determining the number of subsamples in cases involving parallel production lines has been supplemented. By improving the accuracy and representativeness of collected samples, the number of subsamples required has been reduced, the identification cycle shortened, and identification costs lowered.
　　Third, the identification procedures have been refined. During sample testing, provisions have been added for identifying solid wastes generated during use or after disposal. In practical identification work, the priority of testing can be determined based on the likelihood that various hazardous characteristics of the solid waste exceed regulatory thresholds, thereby avoiding unnecessary and excessive characterization tests.