Hazardous Waste Data: The EPD Wildcard
No product manager brags about their hazardous-waste line item, yet the kilograms you generate, recycle, or landfill can nudge an Environmental Product Declaration from “nice try” to “spec-winner.” Skip or fudge the metric and the whole LCA wobbles.
Why hazardous waste shows up at all
EN 15804+A2 treats hazardous waste disposed as a core indicator because downstream toxicity can dwarf a product’s carbon story if heavy metals or solvents leak out over decades (CEN, 2019). In other words, the footprint doesn’t stop at the factory gate; it follows every drum, barrel, and super-sack.
Where manufacturers typically pull the numbers
Plant EHS dashboards, RCRA Info export files, and EU waste registers throw off monthly reports already. Tapping those feeds beats hunting through paper manifests taped to a forklift. In 2024 EPA rolled out batch-export APIs for RCRA site records, slashing data-pull time by 60 percent (EPA, 2024).
Three mistakes that blow up credibility
- Mixing categories. Non-hazardous lime sludge sneakily gets logged under D codes because the landfill accepts both streams. Double-check the waste code before it lands in the LCA spreadsheet.
- Ignoring contractors. Surface-finishing vendors often hold the hazardous waste permit, so your shipment weight disappears from your own totals. The auditor will still ask.
- Counting incineration as disposal. EN 15804 scores hazardous waste to energy recovery differently from landfill. One typo and the indicator jumps off the chart.
The business case: toxic risk equals tender risk
Norway’s Statsbygg and the Dutch Rijkswaterstaat both tightened hazardous-waste thresholds for state projects in 2025 (government bulletins, 2025). Miss the mark and your bid tumbles off the shortlist no matter how stellar the CO₂ line looks.
Shortcut to clean, defensible data
Automated pulls from EHS software paired with a life-cycle consultant who knows the quirks of each waste code clean up the noise fast. The payoff: back-and-forth with the program operator shrinks from weeks to days, freeing your R&D team to focus on the next product tweak rather than digging through binders.
What if the data gap is huge?
Admit it. A recent Eurostat review found 12 percent of construction manufacturers had missing hazardous-waste entries for at least one quarter (Eurostat, 2024). LCA practitioners can model a conservative proxy using regional averages, but transparency notes will flag the assumption and some specifiers will frown. Better to invest an afternoon aligning internal waste codes with the EPD’s PCR once and be done.
Tie-up: the quiet metric that moves markets
Hazardous-waste kilograms rarely make the front page, yet they quietly steer project awards and compliance audits. Treat the data like any other performance KPI, build a reliable pipeline, and your next EPD lands smooth. Otherwise the wildcard might bite back at the worst moment.
Frequently Asked Questions
Do we need to include off-site contractor waste in our hazardous-waste total for an EPD?
Yes. EN 15804 counts all hazardous waste generated in A1–A3, even if a contracted finisher or recycler carries the permit. Gather shipment weights directly from their manifests.
How granular should the waste codes be when reporting?
Match the national hazardous-waste code (e.g. RCRA D010 or EU List of Waste 11 02 05*) in your evidence file, then aggregate to the single indicator “kg of hazardous waste disposed” in the EPD.
Can recycling hazardous waste ever reduce the indicator to zero?
No. EN 15804+A2 still records hazardous waste sent to recovery facilities; the benefit shows up in module D as avoided impacts but the mass remains.
About the Author
With a passion for sustainability and a love for complex data, Toby helps manufacturers efficiently collect data from across their organization and get their EPDs done right. He’s especially interested in how AI can support human expertise, helping R&D and factory teams work faster, smarter, and with less friction.
