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ISDI thresholds: The complete guide to compliance for your inert waste

Written by: Joseph OLIVIER

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Published on

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Time to read 9 min

Introduction

The construction and public works sector is the largest producer of waste in France, generating over 227 million tons annually. At the heart of this colossal waste stream, inert waste (soil, rubble, concrete, etc.) represents the lion's share. Its management is a major environmental and economic challenge. To guarantee safe and environmentally sound disposal, regulations have established specific channels, including Inert Waste Storage Facilities (ISDI).

But be aware that not all soil and rubble are accepted without conditions. Access to an ISDI (Industrial Waste Disposal Facility) is strictly controlled by admission criteria, known as "ISDI thresholds." These limits, defined by law, act as safeguards, preventing pollutants from contaminating our soil and groundwater. For any waste producer, from the project owner to the earthmoving company, understanding these thresholds is not optional, it is mandatory.

This article aims to demystify ISDI thresholds through the ISDI package . We will delve into the heart of the regulations, analyze the limit value tables, and give you the keys to successfully navigate the waste acceptance process.

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The regulatory framework for ISDI thresholds: a revolution for the environment

To grasp the importance of the thresholds, it is necessary to understand the regulatory context that governs them. The major turning point occurred on January 1, 2015. Before this date, the management of ISDI (Industrial Waste Storage Facilities) was less formalized, which led to abuses, such as illegal dumping or the filling of natural areas with non-compliant materials.

With the entry into force of Decree No. 2014-1501 of December 12, 2014 , ISDI facilities were integrated into the regulations for Classified Installations for Environmental Protection (ICPE). This change transformed everything: it strengthened controls, standardized practices, and placed environmental protection at the heart of the process.

The fundamental text that defines the thresholds is the decree of December 12, 2014, concerning the conditions for the acceptance of inert waste. This document sets the rules. Its objective is twofold:

  • Protecting the environment: "Inert" waste is waste that, by definition, "does not undergo any significant physical, chemical, or biological transformation." Thresholds ensure that only waste meeting this definition is stored, thus preventing soil and groundwater pollution.
  • Ensuring traceability: By imposing analyses and acceptance procedures, regulations ensure complete monitoring of waste, from its production site to its final storage location.

The objective of this reform was to improve the consistency of the administrative policing of storage facilities and to more easily eliminate illegal ISDI, as specified on the website of the prefecture of Morbihan .

Leaching and total content: the two pillars of the analysis

To be accepted at an ISDI (Industrial Waste Facility), waste must pass a series of rigorous tests. Regulations, via Annex 2 of the decree of December 12, 2014, rely on two types of complementary analyses to assess its polluting potential.

1. Analysis on Eluate (Leaching Test)


This is the most emblematic test. It aims to simulate the behavior of waste in contact with rainwater over the long term. The goal is to determine which pollutants (metals, sulfates, etc.) are likely to be "leached" and migrate into groundwater.

The reference method is the NF EN 12457-2 standard. Specifically, a sample of the waste is placed in contact with a defined quantity of water (a liquid/solid ratio of 10 liters per kilogram of dry matter) for 24 hours. The resulting water, called "leachate," is then analyzed to measure the concentration of the various pollutants released. The results, expressed in mg of pollutant per kg of dry waste, are then compared to regulatory thresholds.

2. Analysis on Gross (Total Content)


This second analysis does not focus on what the waste might release, but on what it intrinsically contains. It measures the total concentration of certain organic pollutants directly in the "raw" waste sample.

Why this double check? Because some pollutants, even if they are not immediately soluble in water, can pose a risk in the long term or in case of direct contact. This is particularly true of hydrocarbons (HCTs), PCBs, and PAHs. This analysis of the total content therefore provides a complete picture of the nature of the waste.

Leaching thresholds in detail

Here's the heart of the matter: the values ​​that must not be exceeded. The table below, summarized from regulatory data provided by organizations such as UNIFER , presents the thresholds for the eluate obtained after the leaching test.


Setting

Symbol

ISDI threshold (mg/kg of dry matter)

Arsenic

As

0.5

Barium

Ba

20

Cadmium

CD

0.04

Total Chrome

Cr

0.5

Copper

Cu

2

Mercury

Hg

0.01

Molybdenum

Mo

0.5

Nickel

Neither

0.4

Lead

Pb

0.5

Antimony

Sb

0.06

Selenium

Se

0.1

Zinc

Zn

4

Chlorides

-

800 (¹)

Fluorides

-

10

Sulfates

-

1,000 (²)

Phenol Index

-

1

Total Organic Carbon on eluate

COT

500 (³)

Soluble Fraction

FS

4,000 (¹)

(1) Exceptions exist if the waste complies with either the chloride and sulfate values, or the soluble fraction values.
(²) A higher value may be admitted under strict conditions (percolation test).
(³) If the threshold is not met, a controlled pH test (7.5-8.0) can be carried out.

These figures may seem abstract. The graph below allows us to visualize the differences in scale between the thresholds for certain heavy metals, illustrating the severity of the limits for elements such as mercury or cadmium.

Thresholds for the total content of organic pollutants

In addition to the analysis of the eluate, regulations require that the concentration of several families of organic pollutants be checked directly in the waste. These substances are closely monitored due to their toxicity and persistence in the environment.


Setting

Acronym

ISDI threshold (mg/kg of dry matter)

Total Organic Carbon

COT

30,000 (⁴)

Total Hydrocarbons (C10-C40)

HCT

500

BTEX (Benzene, Toluene, Ethylbenzene, Xylenes)

BTEX

6

Polychlorinated biphenyls (7 congeners)

PCB

1

Polycyclic Aromatic Hydrocarbons (16 PAHs)

HAP

50

(⁴) For soils, a higher value may be allowed if the TOC threshold on eluate (500 mg/kg) is respected.

The following graph puts the thresholds for these organic compounds into perspective. The extremely low limit for PCBs (1 mg/kg), reflecting their high toxicity, is immediately noticeable, compared to that of TOC, which is a more general indicator of organic matter.

The acceptance procedure: from DAP to validation

Knowing the thresholds is one thing, ensuring that your waste complies with them is another. Regulations have established a strict procedure to guarantee traceability and compliance: the Prior Acceptance Request (PAR).

As explained by the ECT group, a major player in the sector , the DAP (Declaration of Pre-Avoided Waste) is a mandatory step in the soil traceability chain. Before any delivery, the waste producer must submit a dossier to the ISDI (Industrial Landfill Site) operator. This dossier contains:

  • The origin of the waste: precise location of the construction site.
  • Identifying the actors: producer, transporter.
  • Waste characterization: this is where the analysis reports (the "ISDI pack") are provided, proving compliance with the thresholds.
  • The estimated quantities.

The ISDI operator reviews the preliminary acceptance report (DAP). If the analyses are compliant and the soil origin shows no signs of pollution (for example, by consulting databases such as BASOL on contaminated sites), they issue a Prior Acceptance Certificate (CAP). This document, often valid for one year for a given site, authorizes the transporter to deliver the waste to the site.

Visual checks are also carried out upon the arrival of trucks at the ISDI site to verify the absence of unauthorized waste (plastics, wood, plaster, etc.). Any non-compliant load is refused, and the incident is recorded.

What if the thresholds are exceeded? Alternatives to ISDI

What happens if the analysis results reveal that one or more ISDI thresholds are exceeded? The waste is not necessarily condemned. It is simply reclassified and must be directed to a treatment stream appropriate to its level of pollution. It is strictly forbidden to dilute or mix waste to artificially meet acceptance criteria.

Here are the main alternatives:

  • ISDI+: Some facilities benefit from a prefectural decree authorizing them to accept waste with slightly higher thresholds for certain parameters (for example, sulfates or fluorides). This is an intermediate disposal pathway for low-level inert pollution.
  • Non-Hazardous Waste Storage Facility (ISDND): If waste is no longer considered inert but remains non-hazardous, it must be sent to a non-hazardous waste storage facility. These facilities are designed with more complex sealing and leachate treatment systems to manage more biologically or chemically active waste. Logically, the acceptance thresholds are higher at these facilities.
  • Hazardous Waste Storage Facility (ISDD): For waste with pollutant concentrations that classify it as "hazardous" (for example, high levels of PAHs, heavy metals, or asbestos), the only solution is an ISDD. These high-security sites are designed to contain highly toxic substances.
  • Treatment and Recovery: Before considering storage, the question of recovery must always be addressed. Techniques such as biological treatment, soil washing, or physicochemical stabilization can sometimes "decontaminate" a material and allow it to be reused or accepted into a less restrictive recycling stream.

Conclusion: ISDI thresholds, a necessary constraint for a sustainable future

Far from being a mere administrative constraint, ISDI thresholds are the cornerstone of responsible construction and demolition waste management. They embody the balance between the need to build and the imperative to protect our natural resources. By setting clear and scientifically sound limits, the regulations ensure that the storage of inert waste will not become an environmental burden for future generations.

For professionals in the sector, mastering these thresholds and the associated procedures has become an essential skill. It is not only a legal obligation, but also a sign of professionalism and a commitment to a more virtuous circular economy, where each material is directed to the most appropriate channel, safely and transparently.

The author of the article: Joseph OLIVIER

Joseph Olivier is an entrepreneur in the environmental sector. Originally from Nantes, he trained in waste management before creating a circular economy consulting firm . In 2022, he co-founded Pouryère with the ambition of addressing citizens' concerns about soil quality in France and access to environmental data.

Frequently Asked Questions (FAQ)

Can waste be admitted to an ISDI (Industrial Waste Disposal Facility) without analysis?

Yes, but only for a very limited list of waste considered inert by nature and unpolluted, as defined in Annex 1 of the decree of December 12, 2014. This includes, for example, uncontaminated concrete or bricks. However, as soon as there is any doubt or when excavated soil is involved, an analysis (basic characterization) is almost always required by landfill operators to protect themselves.

What is the validity period of an ISDI analysis?

Regulations do not impose a strict validity period for the analysis itself, but the resulting Prior Acceptance Certificate (PAC) is generally valid for one year for a given site, provided the nature of the excavated waste remains unchanged. If the waste-generating process is modified, a new characterization is required.

What does "exceedance on the gross TOC but not on the eluate" mean?

This is a scenario covered by regulations. The Total Organic Carbon (TOC) in raw waste can be high (for example, in natural soils rich in humus) without posing a risk of water pollution. Regulations allow exceeding the 30,000 mg/kg threshold in raw waste, provided the 500 mg/kg threshold in the effluent is respected. This demonstrates that the organic matter present is not easily leached and therefore has limited mobility in the environment.

Who is responsible in case of non-compliance with waste regulations?

Responsibility is shared. The waste producer (the project owner) is primarily responsible for its characterization and its routing to the correct disposal channel. The excavation company and the transporter also share responsibility in the traceability chain. Finally, the operator of the landfill is obligated to inspect the waste it accepts. The entire chain must be vigilant.


Does the new traceability regulation (Trackdéchets) change the ISDI thresholds?

No. The Trackdéchets platform, which digitizes Waste Tracking Forms (BSD) and centralizes the registers, does not change the acceptance thresholds. Its objective is to strengthen traceability and control, as explained by the Ministry for Ecological Transition . It simply makes fraud more difficult and ensures that each waste item is tracked from its origin to its final destination, which must comply with its classification... and therefore with the thresholds.

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