One of the most complex tasks Airsafe is asked to do is waste classification. It’s a structured process, set out in the EPA’s Waste Classification Guidelines, and it can involve digging into the history of the site and the material itself, plus laboratory testing for a range of contaminants, with chemistry at an external NATA-accredited laboratory and asbestos identification in our own NATA-accredited laboratory. The aim is to place the waste into one of six classes, because the class decides what you can legally do with it, and where it has to go.
Who is allowed to classify waste in NSW?
In NSW, the waste generator is legally responsible for classifying waste. No licence is needed to classify waste, but the classification has to stand up to the NSW EPA Waste Classification Guidelines. Airsafe classifies soil and waste on the generator’s behalf, so the material can be reused or disposed of legally.
How is asbestos-contaminated soil classified and disposed of?
If any asbestos is found in the material, bonded or friable, it has to be classified as Special Waste (Asbestos Waste) and can’t be VENM or ENM. Airsafe identifies asbestos in soil in our own NATA-accredited laboratory (No. 2959), while the rest of the chemistry goes to an external NATA-accredited laboratory. Asbestos waste must go to a facility licensed to accept asbestos waste. See Airsafe’s Asbestos in Soil page.
The six waste classes
- Special waste, includes asbestos, clinical and related waste, and tyres, each with its own disposal requirements.
- Liquid waste, waste that is, or behaves as, a liquid.
- Hazardous waste, includes explosives, gases, flammable solids, and material contaminated with lead, coal tar and other hazardous substances.
- Restricted solid waste, more contaminated than general solid waste, but below hazardous waste.
- General solid waste (putrescible), waste that breaks down, smells or attracts vermin, such as food waste and manure.
- General solid waste (non-putrescible), stable solid waste that doesn’t readily decay.
Getting the class right matters in both directions: misclassify low and you risk illegal disposal and penalties; misclassify high and you pay landfill prices for material you could have reused.
Can my soil be reused as VENM or ENM?
VENM and ENM both let soil be reused off site rather than sent to landfill. Airsafe assesses whether your soil qualifies as VENM or ENM. ENM and VENM both exclude material that contains asbestos, acid sulfate or potential acid sulfate soils, or sulfidic ores.
Two classifications exist specifically so good soil isn’t wasted:
- Virgin Excavated Natural Material (VENM) is a special type of general solid waste (non-putrescible): natural material such as clay, gravel, sand, soil or rock fines, excavated or quarried from land that isn’t contaminated with manufactured chemicals or process residues from industrial, commercial, mining or agricultural activity, and that doesn’t contain sulfidic ores or soils or any other waste. The advantage of having soil classified as VENM is that you can sell it to be reused at another site, what used to be called “clean fill”. The EPA provides a VENM certificate that can be completed by the waste generator, or by a consultant acting for the generator. It isn’t compulsory, but it provides a useful record of how the material was assessed.
- Excavated Natural Material (ENM) covers natural soil and rock that has been disturbed or carries low-level contamination but still meets the chemical and physical criteria in the Excavated Natural Material Order. Once assessed, tested and certified against the Order, ENM can also be reused off site. ENM and VENM both exclude material that contains asbestos, acid sulfate or potential acid sulfate soils, or sulfidic ores.
If any asbestos is found in the material, bonded or friable, it has to be classified as Special Waste (Asbestos Waste) and can’t be VENM or ENM. We identify asbestos in our own NATA-accredited laboratory (No. 2959), while the rest of the chemistry goes to an external NATA-accredited laboratory. See our Asbestos in Soil page.
How we classify your waste
- We review the site’s history and the material, and design a sampling program for it.
- We recover samples and have the chemistry analysed at an external NATA-accredited laboratory, and identify any asbestos in our own NATA lab. Where PFAS is a possibility, we assess for it in line with the PFAS requirements in the Waste Classification Guidelines.
- We produce a waste classification report, or a VENM or ENM assessment, that complies with EPA and council requirements, so you can move the material with confidence.
For the wider site picture, see our Contaminated Land Assessments page.
We classify. A licensed contractor disposes.
Airsafe is an independent consultant. We classify the material and tell you where it can legally go, we don’t haul it, treat it or run the landfill. The disposal or reuse is carried out by others, to the classification we’ve provided. Because we don’t profit from where the waste ends up, our classification is just the honest answer, which is what keeps you compliant.
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Frequently asked questions
Who is legally responsible for classifying waste?
In NSW, it is the responsibility of those who generate waste to classify that waste. No licence is needed to classify waste. A consultant may act on behalf of the waste generator, and Airsafe classifies soil and waste on the generator’s behalf.
Is asbestos in soil always special waste?
Yes. If any asbestos is found in the material, bonded or friable, it has to be classified as Special Waste (Asbestos Waste) and can’t be VENM or ENM. Asbestos waste must go to a facility licensed to accept asbestos waste.
What’s the difference between VENM and ENM?
Both let you reuse soil off site rather than send it to landfill. VENM is natural material (clay, gravel, sand, soil or rock fines) from land that isn’t contaminated by manufactured chemicals or process residues and contains no sulfidic ores or soils or other waste; the simplest case. ENM covers natural soil and rock that’s been disturbed or carries low-level contamination but still meets the criteria in the Excavated Natural Material Order once it’s been tested and certified. Material with asbestos, acid sulfate soils or sulfidic ores can’t be either. We work out which, if any, your material qualifies as.
Why does the waste class matter so much?
Because it decides what’s legal and what it costs. Classify too low and you risk illegal disposal and serious penalties; classify too high and you pay landfill rates for material you could have reused as fill. An accurate classification protects you on both fronts, and often saves money by keeping reusable soil out of landfill.
Who does the laboratory testing?
Airsafe identifies asbestos in its own NATA-accredited laboratory (No. 2959), and any asbestos present means the material must be classified as Special Waste (Asbestos Waste). Where PFAS is a possibility, we assess for it in line with the requirements in the Waste Classification Guidelines. The wider chemistry is analysed at an external NATA-accredited laboratory.
Do you dispose of the waste?
No. Airsafe classifies the material and tells you where it can legally go. The transport, treatment and disposal or reuse are handled by others, to our classification. Because we don’t profit from where it ends up, the classification stays independent and honest.
Who can issue a VENM certificate?
There’s no licence for it. Under the EPA’s guidance, a VENM certificate can be completed by the waste generator, or by a consultant acting on the generator’s behalf, to certify that the material meets the VENM definition in the Protection of the Environment Operations Act. It isn’t legally required, but receiving sites generally want one before they’ll accept the soil, and supplying false or misleading information about waste is an offence. Most people have a consultant do the assessment, because it has to stand up to the site’s history as well as any test results.
How many samples are needed?
It depends on the classification and the amount of material. For ENM, the Excavated Natural Material Order sets minimums: a stockpile under 500 tonnes needs at least three samples, larger stockpiles need more, and above 4,000 tonnes the sampling program repeats. Material still in the ground is sampled on a grid based on the area, with extra samples at depth. For VENM, chemical testing isn’t always required; where it is, sampling density follows the EPA’s sampling design guidelines. We design the sampling program to suit the site’s history, the material and the quantity.
Talk to us about classifying your soil or waste
Whether you’re trying to reuse clean fill or work out what a contaminated stockpile actually is, Airsafe will classify it properly so you can move it legally and cost-effectively.
To organise a waste or VENM classification, call us on 1300 888 338.
Last reviewed: October 2026
