This report uses independent empirical research to evidence that incinerator bottom ash is insidiously hazardous and underregulated. Risk is heightened by the fact that testing methods for its use as a building material are outdated. A list of fifteen concerns for public health and safety is provided in relation to the use of waste incinerator bottom ash in cement-based products and as road/pathway aggregate. Calls for the support of its use within a circular economy are premature, and, as per the precautionary principle, all ongoing usage should cease. Examination of independently analysed bottom ash provides a diagnostic on the operational steady state of waste incinerators, incidentally raising concerns about operational compliance with emissions legislation and the capacity of incinerators to produce benign bottom ash when fed with municipal solid waste.
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