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On November 25, 2020, Ministry of ecological environment, national development and Reform Commission, Ministry of public security, Ministry of transportation and National Health Commission revised and issued the national hazardous waste list (2021 Edition) (hereinafter referred to as "directory"). In view of the revision of the directory and some common problems in the process of use, the compilation group of the directory prepared the answer materials for reference in the use of the directory.

1. what connection work should local ecological and environmental departments and enterprises do after the implementation of the new directory?

A: the revision and addition of this catalogue has reduced the changes in some hazardous wastes and some waste codes. Local ecological and environmental departments and relevant enterprises need to do well in the connection work between the implementation of the directory and the environmental management system such as hazardous waste management plan, transfer joint sheet, license and so on. For example:

1) In case of any change in the types or codes of hazardous wastes produced by relevant enterprises, the management plan and emission permit of hazardous waste shall be changed in time.

2) In case of any change in the types and codes of hazardous wastes in the collection and comprehensive license of hazardous wastes, the licensed enterprises and local ecological and environmental departments shall make changes in time.

3) In case of any change in the types or codes of hazardous wastes applied for cross provincial transfer, relevant enterprises shall change the transfer plan and submit the transfer application again.

2. what are the main considerations for the revision and deletion of the relevant articles (Articles 3 and 4) of the body of the Chinese medicine treatment waste and waste hazardous chemicals in the catalogue?

A: this revision is not to simply delete the relevant articles on the body of the list of Chinese medicine treatment wastes and waste hazardous chemicals, but to further improve and refine the relevant contents into the list schedule, which is more scientific and rigorous.

As for medical waste, the law on prevention and control of environmental pollution by solid waste stipulates that "medical waste shall be managed according to the national list of hazardous wastes". The list no longer simply stipulates that "medical waste belongs to hazardous waste", but lists the relevant types of medical waste in the attached table of the list, and stipulates that "the classification of medical waste shall be carried out in accordance with the classification catalogue of medical waste".

Regarding the waste hazardous chemicals, the first is to further clarify the scope of the waste hazardous chemicals included in the environmental management of hazardous wastes. Hazardous chemicals in the catalogue of hazardous chemicals are not all environmental hazards. Waste hazardous chemicals cannot be simply equivalent to hazardous wastes, such as "liquid oxygen", "liquid nitrogen" and other hazardous chemicals with only "pressurized gas" physical hazards.

Second, the requirements for the inclusion of waste hazardous chemicals into the environmental management of hazardous wastes are further clarified. After some inflammable and explosive hazardous chemicals are abandoned, their properties of hazardous chemicals have not changed; whether or not hazardous chemicals are abandoned is difficult to define by the regulatory authorities. Therefore, the list of abandoned hazardous chemicals puts forward "declared for waste by owners", that is, the owners of hazardous chemicals should report to the emergency management department and the ecological environment department for abandonment. The main reason for the "3.21" accident of sound water is that the enterprise has not stabilized the waste hazardous chemicals into the environmental management of hazardous waste according to the relevant national standards, nor reported to the emergency management department and the ecological environment department to avoid supervision, which leads to serious events.

3. what are the considerations for the exemption from point-to-point directional utilization? How to operate the implementation?

A: the exemption management system has played an active role in promoting the utilization of hazardous waste after it was first proposed in the 2016 edition of the list. However, there are many kinds of hazardous wastes and various utilization methods, so it is difficult to make regulations one by one. It is necessary to implement more flexible management of exemption from use in combination with the actual situation, and further promote the utilization of hazardous waste. Therefore, the directory puts forward "on the premise of controllable environmental risks, according to the scheme determined by Provincial Ecological and environmental departments, the" point-to-point "directional utilization of hazardous waste is implemented.

After the Ministry of ecological environment issued and implemented the guidance on improving the environmental supervision ability, utilization and disposal capacity and environmental risk prevention capability of hazardous waste in 2019, Shandong, Jiangsu and other places have explored and carried out the relevant work on the management of "point-to-point" directional utilization exemption of hazardous waste, with good results.

Next, in the implementation of point-to-point directional use exemption management, Provincial Ecological and environmental departments can formulate implementation rules and organize relevant work in combination with local practice.

4. are the wastes listed in the list exemption list not hazardous wastes?

A: the list of exemption management of hazardous waste only exempted some management requirements of specific links of hazardous waste, and did not exempt its hazardous waste properties.

5. what is the specific meaning of exemption content in Appendix "list of hazardous waste exemption management"?

Answer: the "exemption content" in the list of exemption management of hazardous waste refers to the content that can not be managed according to the hazardous waste. The specific meaning of the above is as follows:

1) The whole process is not subject to hazardous waste management: the whole process is exempted, and the management links do not need to implement the provisions on the environmental management of hazardous waste.

It is necessary to emphasize that except for the hazardous waste transfer process under the scenario of "the whole process is not managed according to hazardous waste", and the transfer process of hazardous waste collection and transfer to the centralized storage point under the exemption of the collection process, the transfer sheet shall not be operated, and the hazardous waste transfer sheet shall be operated for all the hazardous waste transferred under other exemption scenarios.

2) The collection process is not managed according to hazardous waste: the collection exemption conditions specified in the list of exemption list are met. The collection unit may not need to hold the hazardous waste collection license, and the transfer process of collecting and transferring to the centralized storage point can not run the transfer sheet; the storage after centralized collection and other links are still managed according to the hazardous waste.

3) The utilization process is not managed according to hazardous waste: meet the exemption conditions specified in the list of exemption list, and the utilization enterprise may not need to hold a comprehensive license for hazardous waste; it is necessary to run the transfer list, and other links such as storage in the utilization enterprise are still managed according to the hazardous waste.

4) The landfill (or incineration) disposal process is not subject to hazardous waste management: it meets the exemption conditions for landfill (or incineration) disposal specified in the list exemption list. The landfill (or incineration) disposal enterprise may not need to hold a comprehensive license for hazardous waste, and the pollution control system of landfill (or incineration) shall be exempted from the requirements; the transfer sheet shall be operated and the storage in the disposal enterprise shall be carried out Other links such as storage are still managed according to hazardous waste.

5) The collaborative treatment process of cement kiln is not subject to hazardous waste management: it meets the exemption conditions for the collaborative disposal of cement kiln specified in the list of exemption list. The cement enterprise may not need to hold a comprehensive license for hazardous waste, and the requirements of exemption conditions for pollution control in the collaborative treatment process shall be implemented; the transfer sheet shall be operated and other links such as storage in the disposal enterprise shall still be in accordance with the requirements of hazardous waste Manage the things.

6) Transportation not according to hazardous waste: transport process can not be carried out according to dangerous goods, pollution control in transportation process shall be subject to requirements of exemption conditions; transfer sheet shall be operated.

6. the wastes removed by this revision and the "excluding..." in parentheses in the directory Does the waste of mean it is not a hazardous waste?

Answer: according to the legal definition of hazardous waste, the wastes listed in the list belong to hazardous wastes, and those not listed in the list are also classified as hazardous wastes according to the national standards and methods for hazard identification.

The waste removed by this revision and the "excluding..." in parentheses in the directory All wastes are not listed in the list. If the hazardous characteristics of these wastes cannot be eliminated through process analysis, it is necessary to further determine whether they belong to hazardous wastes according to the standards for identification of hazardous wastes (gb5085.1-7) and the technical code for hazardous waste identification (HJ 298).

7. for hazardous waste meeting the exemption of utilization or disposal, if it is submitted to another enterprise for pretreatment before use or disposal, is the pretreatment exempt? In addition, is the derivative principle applicable to waste generated in the exempt disposal process?

Answer: Article 3 of the list stipulates that "hazardous waste listed in the list of exemption management of hazardous waste listed in the appendix to this list may be exempted according to the provisions of exemption content when the exemption links listed and the corresponding exemption conditions are met". The pretreatment link is not in the exemption link listed, so it cannot be exempted.

In addition, the list of exemption management of hazardous waste only exempted some management requirements of specific links of hazardous waste, and not the nature of hazardous waste. Therefore, the hazardous waste properties of the wastes generated in the exempted disposal process should still be determined according to the national list of hazardous wastes, the identification standards for hazardous wastes (gb5085.1-7) technical code for the identification of hazardous wastes (HJ 298).

8. when determining whether the waste belongs to the hazardous waste and its category listed in the list, it is determined according to the industry source or the waste description is preferred?

A: the source of hazardous waste is wide, and there is a phenomenon that the same waste comes from many industries. The industry code in the directory refers to the main industrial source of this waste, not the only source. Therefore, when judging whether the waste belongs to the hazardous waste and its category listed in the list, the principle of waste description should be taken as the main principle and the industry source as the auxiliary. In case of contradiction or inconsistency, waste description shall be taken as the main judgment basis.

9. if the waste residue after harmless treatment of overhaul slag is used as raw material for brick or paving, aluminum ash can be used as raw material of other enterprises to produce calcium aluminate, can it apply to Provincial Ecological and environmental department for point-to-point directional utilization. In this case, does the utilization enterprise not need to hold a comprehensive license for hazardous waste?

Answer: the exemption from "point to point" directional utilization of hazardous waste meets the corresponding exemption conditions stipulated in the list, and ensures that under the condition of controllable risk, when the enterprise makes directional use according to the scheme determined by Provincial Ecological and environmental department, the enterprise may not need to hold a comprehensive license for hazardous waste.

10. is the water-based paint residue not hazardous waste according to 900-252-12 "waste generated during painting and painting with paint (excluding water-based paint), organic solvent?

A: "excluding water-based paint" refers to the hazardous waste that is not included in the list of water-based paint slag. Whether it belongs to hazardous waste shall be judged according to the technical code for identification of hazardous wastes (HJ 298) of the standard for identification of hazardous wastes (gb5085.1-7).

11. is the exterior wall coating a class 900-255-12 waste, i.e. "waste pigments produced in the process of coloring with various pigments"?

Answer: 900-255-12 refers to the waste pigments produced in the process of coloring with various pigments. The exterior wall coating is not pigments, so the waste exterior wall paint is not classified as 900-255-12 waste.

In addition, the properties of waste exterior wall coating shall be determined according to the composition of the exterior wall coating, whether it belongs to water-based coating or not, and the waste of 900-299-12 is not water-based coating.

12. is the waste water from cleaning roller and wastewater treatment sludge produced by water-based ink printing belong to the category of 900-299-12 "waste of" invalid, deteriorated, unqualified, eliminated, fake and inferior ink, dye, pigment and paint (excluding water-based paint) "generated in the process of production, sale and use?

A: the waste water from cleaning ink roller and sludge treatment from water-based ink printing are not classified as 900-299-12 wastes in the list.

13. is the circulating water and sludge of circulating water pool used in the wet treatment facility of overhaul slag belong to 772-006-49 waste?

Answer: first, it is necessary to judge whether circulating water belongs to solid waste according to general principles for solid waste identification standard. If it is not solid waste, it is not hazardous waste.

Sludge from circulating water tank used in wet treatment facilities of overhaul slag belongs to 772-006-49 waste.

14.900-047-49 whether laboratory waste generated by the laboratory of the enterprise is included.

A: including.

15.336-100-21 and 336-100-17 both contain "waste tank liquid, slag and waste water treatment sludge produced by anodizing with chromic acid", what are the reasons for this?

A: the hazardous wastes in the list are classified according to the mixture of the source and substance composition, and the classification system is not uniform. In the future, it is proposed to gradually implement and unify the classification by source of production. In the 2016 edition of the list, the waste is classified under hw21 and classified according to the composition of substances; in the new directory, it is classified under hw17, and the source of production is classified. However, considering that there are many sources of such waste, in order to avoid the problem of large number of waste transfer and disposal due to the change of waste code in a short time, special transitional treatment is carried out, and the new list hw21 still retains such waste.

Therefore, after the implementation of the new directory, the waste can be classified into two types in the management process. Facilities with 336-100-21 and 336-100-17 utilization and disposal qualification can handle such wastes.

16. should the dust removal dust from steel-making of stainless steel furnace be included in hw21 or hw23?

A: the dust removal ash of stainless steel-making is mainly zinc, so it should be classified as hw23.

17.900-041-49 "waste packaging, containers, filtration and adsorption media containing or contaminated with toxic and infectious hazardous wastes" belong to hazardous wastes. Are the waste packaging containing or contaminated with corrosive and flammable hazardous wastes belong to the wastes in the national hazardous waste list?

Answer: waste packaging containing or contaminated with corrosive and flammable hazardous wastes is not included in the list. Whether it belongs to hazardous waste shall be recognized according to the technical specification for identification of hazardous wastes (HJ 298) in gb5085.1-7.

18.221-002-35 "waste alkali liquor produced by cooking and pulping in alkaline pulping" refers to black liquor or white liquor of paper making?

A: black and white liquor produced by alkali (caustic soda and sulfate) pulping are waste alkali liquid, and belong to 221-002-35 waste in the list.

19. can it be understood that the waste oil drum is inverted without oil outflow in the list of exemption 900-249-08 "waste iron oil drums, sealed in open state, static without dripping and used for metal smelting after packing and pressing blocks"? In addition, can the iron waste oil paint bucket be executed by reference?

A: the condition of "open state, no dripping leakage in static position" can be satisfied if the waste oil tank is inverted without oil outflow. However, the exemption from the utilization process of "metal smelting" should also meet the condition of "after packing and pressing block".

The iron waste paint barrel is not within the scope of the exemption list in the list.

20. according to the list of exemption list, aluminum ash and secondary aluminum ash recycling process in class 321-024-48 and 321-026-48 wastes are not managed according to hazardous wastes. Can it be understood that aluminum ash and aluminum ash can be exported to other enterprises to extract aluminum?

A: enterprises recovering aluminum from aluminum ash and secondary aluminum ash do not need to hold a comprehensive license for hazardous wastes, but in addition, other environmental management and pollution control of such wastes still need to be implemented。