Directive 2006/21/EC maturity · Extractive waste management compliance
Your extractive waste obligations, measured site by site and turned into a costed action plan.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
Directive 2006/21/EC maturity · Extractive waste management compliance
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Directive 2006/21/EC of 15 March 2006 on the management of waste from extractive industries assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
This mechanism (a level, a higher level, and the action that links the two) is what turns a finding into a trajectory.
Does the waste facility monitoring programme include defined alert thresholds and formalised follow up actions?
- N1
No structured programme. Some ad hoc measurements exist, without a reference threshold or an identified recipient.
- N2
Geotechnical and hydrogeological measurements are taken to a schedule, but alert thresholds are not written down and interpretation depends on whoever is present.
- N3
The monitored parameters, alert thresholds and recipients are documented. Exceedances trigger a tracked action. Handling gaps are occasional.
- N4
Monitoring is systematic, exceedances are analysed at operating review, corrective actions are tracked to closure and results are consolidated at group level.
- N5
Thresholds are reassessed in line with the facility’s evolution, incidents and lessons learned from other sites, with a documented history of revisions and their rationale.
Action to move from L2 to L3
Formalise, for each monitored parameter, a watch threshold and an alert threshold, with the associated recipient and response time, annex them to the waste management plan and check their application at the site’s monthly operating review.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurement
What this framework covers
Directive 2006/21/EC, the so called mining waste directive, requires any operator producing extractive waste to draw up a waste management plan geared towards source reduction, recovery and safe storage. It introduces category A classification for facilities based on the risk of major accident, structural failure or the presence of hazardous substances. It requires an operating permit, waste characterisation, a financial guarantee covering rehabilitation, a major accident prevention policy for category A facilities, and closure and post-closure monitoring arrangements. Decisions 2009/335/EC to 2009/360/EC set out the technical detail.
In practice, the difficulty is not knowing the text but holding the chain together over time. Is the waste management plan genuinely updated every five years and after every substantial modification, or is it still the one from the original permit file? Has the financial guarantee been revised since the stored volume and the rehabilitation cost changed? Who in the organisation holds the waste characterisation and mine water monitoring data, and how often does it reach site management and then the group? The answers often differ from one site to another within the same operator.
One confusion comes up regularly: scope. The directive excludes waste that does not directly result from prospecting, extraction and treatment, as well as waste from offshore extraction and water reinjection. It also interacts with other texts without replacing them: an extractive waste facility falls under 2006/21/EC rather than the landfill directive, but discharges remain governed by the Water Framework Directive, and a category A facility can involve prevention logic similar to Seveso III without being legally bound by it. Mapping these boundaries avoids duplicating arrangements or leaving one without an owner.
A compliance audit concludes with a gap or no gap against a requirement. A maturity assessment answers a different question: what level of control does each practice sit at, and what specific action moves it up a level. A waste management plan that exists but is not linked to operating reviews, geotechnical monitoring carried out without formalised alert thresholds, a closure arrangement that is described but never costed: these are situations that a binary compliant or non compliant verdict does not capture, and that a theme by theme score makes comparable across sites.
The framework is ready to use. You can adapt it to your operating context: the AI adjusts the themes, questions and levels to the nature of the facilities, or builds a variant from your operating permits, waste management plans and monitoring reports. Assessments run across several sites consolidate into a cross site roadmap.
Reference standard: Directive 2006/21/EC of 15 March 2006 on the management of waste from extractive industries
The themes assessed
Extractive waste characterisation
Inventory of flows, geochemical and geotechnical characterisation, acid generation and leaching potential, classification as inert or hazardous waste, updating of analyses.
Waste management plan
Source reduction, reuse and backfilling, storage options chosen and justified, five yearly review, consideration of substantial modifications.
Permit and regulatory scope
Content of the operating permit, category A classification, interaction with water, air and industrial installation regimes, exclusions from the scope of the directive.
Facility design and integrity
Site selection, stability of dams and waste piles, containment, water and overflow management, design file and review by a competent third party.
Major accident prevention
Prevention policy, safety management system, internal emergency plan, information to the public, failure and overtopping scenarios, exercises.
Operational monitoring and control
Geotechnical and hydrogeological monitoring programme, alert thresholds, piezometers and groundwater quality, records, escalation of deviations and follow up actions.
Financial guarantee
Calculation method, scope covered including rehabilitation and post-closure monitoring, form of the guarantee, periodic review, consistency with accounting provisions.
Closure and post-closure monitoring
Closure plan, long term stability criteria, land rehabilitation, duration and content of monitoring, transfer of responsibility to the competent authority.
Competence, organisation and subcontracting
Roles and responsibilities on facilities, qualification of technical staff, oversight of earthworks and monitoring contractors, continuity when staff leave.
Information, transparency and improvement
Communication to authorities and the public, handling of complaints from local residents, lessons learned after incidents, updating of practices and comparison across sites.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Can Directive 2006/21/EC be certified?
No. It is an EU directive transposed into national law, compliance with which is checked by the competent authority and inspectors through the operating permit. The assessment measures the maturity of your practices and prepares you for these checks, it does not deliver any certification.
What is the difference between this assessment and a regulatory compliance audit?
An audit checks requirement by requirement and concludes with a gap or no gap. The assessment places each practice on a maturity scale and identifies the action that moves it up a level. The two are complementary: the assessment prepares and prioritises, the audit validates.
Does the framework cover category A facilities?
Yes. The theme dedicated to major accident prevention covers the prevention policy, the safety management system, the internal emergency plan and information to the public. A dedicated framework for category A facilities allows you to go further on this aspect.
How long does the assessment take?
The short version can be completed in one working session with the site’s HSE manager. The full version, run collaboratively with operations, geotechnical staff and finance, spans one to two weeks, most of the time being spent gathering supporting evidence.
Can several sites be compared with each other?
Yes. Each site is assessed against the same framework, which makes theme by theme scores comparable across business units and over time. Assessments consolidate into a cross site roadmap that groups common actions rather than duplicating them.
Can the framework be adapted to our facilities?
Yes. The themes, questions and levels can be modified. The AI refines the wording to suit the nature of your facilities, or builds a variant from your operating permits and waste management plans.
How does the assessment help calibrate the financial guarantee?
The dedicated theme evaluates the calculation method, the scope covered and the review frequency. The gaps identified feed into the action plan, alongside the cost and timeframe of the corresponding works, giving a documented basis for discussions with the authority and financial auditors.
Where is the data hosted?
In France, with OVH, backed up with Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.