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Waste Transfer Notes - are you filling them in correctly?

OHRA racking in use
Controlled waste transfer notes have been around since the early 1990's but since then a number of changes have been made. Make sure you're aware of the latest requirements.
The duty of care waste transfer note was introduced in 1990’s as a way of tracing the journey taken by waste and now 23.5 million Waste Transfer Notes are produced in the UK each year.

The note records what the waste is, who produced it, who received it and when and where the transfer of waste takes place. Over the years the legislation has changed to make these notes more accurate. The requirement to add the reference code from the List of Wastes, for all waste collected, was introduced some years ago and more recently the need to include a Statutory Industry Classification code (SIC) and a declaration that the obligation to apply the waste hierarchy has been fulfilled. It is important for your business that a waste note or hazardous waste consignment note is produced for every waste transfer and that they are filled in correctly. There have been several instances where waste transfer notes have not contained the required information or have been filled in incorrectly. Don’t fall foul of the Environment Agency because you have forgotten to include a code number or to tick a box.

All wastes are now listed in the European Waste Catalogue (EWC) on the List of Waste (LoW). A code number exists for each waste and the LoW also states if the waste is hazardous, hazardous in certain circumstances or non hazardous. If the waste is hazardous a Duty of Care Waste Transfer Note pad is not sufficient and a Hazardous Waste Consignment note is required. Some wastes have the potential to be either hazardous or not, depending on whether they contain dangerous substances, if the dangerous substances are removed a Duty of Care Waste Transfer Note is suitable for the non hazardous material, but a Hazardous Waste Consignment Note must accompany the hazardous material. The code is to tell anyone that receives the waste exactly what the waste is, allowing for safe handing of the waste. For example an end-of-life vehicle has a code of 16 01 14, It is printed in blue in the EWC with an asterisk and the letter M. The asterisk indicates that it could be hazardous or contain hazardous components and the letter M indicates that there is a mirror entry for its non-hazardous counterpart. In our example an end-of-life vehicles, containing neither liquids nor other hazardous components has a code of 16 01 06, and is non hazardous, but brake fluid with a code of 16 01 13 is absolutely hazardous and is covered by hazardous waste regulations.

More recent additions to waste transfer notes include the Statutory Industry Classification code, which must be added if the owner of the waste is a business. The 2007, not the 2003 SIC code must be used for waste transfer notes. It can be found in company details held by companies house or by visiting the Office for National Statistics website. A declaration from the waste producer to confirm that they have fulfilled their duty to apply the waste hierarchy is also required under Regulation 12 of the Waste (England and Wales) Regulations 2011. Simply stated the waste hierarchy shows the best choice for waste in descending order of environmental preference. Prevention, which is the best outcome for the environment and your business, is top of the list, followed by re use such as repairing, refurbishing or using as spare parts, recycling, other recovery such as incineration with energy recovery and finally disposal with out energy recovery or landfill.

The government is looking at ways to free businesses from having to fill in Waste Transfer Notes by allowing them to use other forms of evidence instead, such as invoices. It is difficult to know when or even if this new legislation will come in to force. Until it does ensure that your waste transfer notes are completed correctly. For more information on waste transfer notes visit wastenotes.co.uk

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