Definition and further description of Annex III to WFD

Annex III to the WFD defines HP 4 ‘Irritant’ as: ‘waste which on application can cause skin irritation or damage to the eye’ HP 4 is linked to HP 8 ‘Corrosive’, since both HPs refer to the potential for harm or damage to tissue at different levels of severity. Regarding HP 8, consult Section 3.8 for further details. Note that: — Hazardous waste containing irritant substances can display irritant properties (depending on concentration); — Hazardous waste containing corrosive substances can display either corrosive or irritant properties depending on concentration. Mechanical irritation produced by some substances is not included within the definition of HP 4. The WFD further explains that: When a waste contains one or more substances in concentrations above the cut-off value, that are classified by one of the following hazard class and category codes and hazard statement codes and one or more of the following concentration limits is exceeded or equalled, the waste shall be classified as hazardous by HP 4. The cut-off value for consideration in an assessment for Skin corr. 1A (H314), Skin irrit. 2 (H315), Eye dam. 1 (H318) and Eye irrit. 2 (H319) is 1 %. If the sum of the concentrations of all substances classified as Skin corr. 1A (H314) exceeds or equals 1 %, the waste shall be classified as hazardous according to HP 4. If the sum of the concentrations of all substances classified as H318 exceeds or equals 10 %, the waste shall be classified as hazardous according to HP 4. If the sum of the concentrations of all substances classified H315 and H319 exceeds or equals 20 %, the waste shall be classified as hazardous according to HP 4. Note that wastes containing substances classified as H314 (Skin corr.1A, 1B or 1C) in amounts greater than or equal to 5 % will be classified as hazardous by HP 8. HP 4 will not apply if the waste is classified as HP 8. Hazard Class and Category Code(s) Hazard statement Code(s) Description Concentration limit (total of substances) Skin Corr. 1A H314 Causes severe skin burns and eye damage ≥ 1 % and < 5 % Eye Dam. 1 H318 Causes serious eye damage ≥ 10 % Skin irrit. 2 and Eye irrit. 2 H315 and H319 Causes skin irritation and Causes serious eye irritation ≥ 20 % (8) An example for the assessment of wastes containing CaO and Ca(OH)2 according to HP 4 can be found in Annex 1.4.4. For a waste containing a substance that is H314 Skin Corr.1A, 1B or 1C at a concentration ≥ 5 % see also HP 8 Corrosive (Annex 3.8) as this waste should be classified as hazardous by HP 8 and not by HP 4. The abovementioned concentration limits are applied to the known components of a waste. It may be difficult to identify all specific substances present in certain wastes. Where the waste is not ‘Irritant’ as a result of the known substances and some substances are still unknown, the pH value of the waste should be used for assessment (see Figure 10). A waste with a pH ≤ 2 or ≥ 11,5 should generally be considered HP 8 Corrosive unless both: — an acid or alkali reserve test suggests that the classification as ‘Corrosive’ is not warranted, and — further in vitro testing, or existing human experience and animal data from single or repeated exposure has confirmed that classification as neither ‘Irritant’/‘Corrosive’ applies. The acid/ alkali reserve test measures the buffering capacity of the waste (9).

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07