Innocent or guilty? Make sure to use correct EWC codes for returns

JUST over two years ago I wrote about the perils of not submitting returns and using the wrong EWC codes, which were amongst the 10 most common problems I encountered on an almost daily basis. Time for a recap as the same problems are getting operators into trouble and most of them can constitute an off ence.

Putting EWC codes on a waste return that are not in your permit Keep the number of codes used to a minimum and check they are in your permit. Make a shortlist and give it to all staff involved in waste transactions. Make sure any other codes used by customers are queried to avoid a breach of your permit. It might be the customer’s responsibility, but if the code is incorrect, and you accept the waste, who do you think will be on the receiving end of grief from the regulator? Submitting waste returns late Keep it simple by submitting them using the excel spreadsheet available, and once submitted, use the previous quarter’s return as a template. Check the regulator’s website for updated guidance and spreadsheets periodically. Make a diary entry and give the responsibility to submit the return to two people so if one forgets the other will hopefully not.

Not submitting a hazardous waste consignee return when taking hazardous waste under an exemption. They are still required and are relatively easy to complete electronically. However, if you forget to include some consignments in error, put them on your next return with an accompanying email to inform the regulator of the administrative oversight. Ignoring the issue could come back to haunt you if your hazardous waste is taken

to another site, which includes the details of your consignment on their return and their records are audited. The same applies to permitted sites. Hazardous waste also needs to be included on your site waste return as well. Forgetting to transfer a permit in time when closing a company down or when a company is in liquidation, thereby losing the permit – making an operational site potentially illegal Not all companies close for bad reasons, but making sure the permit doesn’t get lost in the process is a must. If a company is wound up, the liquidator can disclaim the permit simply by writing to the regulator to state they no longer need it. Engaging with the liquidator to stop this happening is a must if you are taking over a failed site. If the permit is in the name of an individual(s) and one of the named passes away then the regulator must be contacted to discuss transfer of the permit. Not taking advantage of registering exemptions to start operations before a permit is issued There are many exemption and low risk positions, which allow low key activities, or of low pollution potential, to be carried out before a permit is issued, which can then work in conjunction with your permit. If you do make use of exemptions on a permitted site keep a plan on display showing the distinct boundaries between exempt and permitted activities. Make sure separate records are kept of the waste accepted at each.

Not paying permit subsistence fees alone is a reason for a permit to be revoked Google ‘waste fees and charges’ followed by your country. Being in debt to your regulator isn’t going to make dealing with other issues easy.


Marco Muia BSc (Hons) MSc MCIWM is a Director of Oaktree Environmental Limited. He specialises in all aspects of waste planning and regulation consultancy. He also holds the level 4 COTCs for Hazardous Waste Treatment and Transfer. You can contact Marco on: 01606 558833.

If you have any questions about this article, e-mail him via: Follow him on Twitter @wastechat 30 SHWM September, 2018

Not notifying changes to carrier registration such as address, directors or relevant off ences, which potentially is an off ence If you are a limited company check the details submitted at the same time you submit your confi rmation statement to Companies House. Not updating the management system or permit to refl ect what’s happening on site. This usually becomes a problem when a new offi cer comes to site and starts to go through the documents that the previous inspector has all but ignored. Delete procedures are no longer relevant, and the same applies to any supporting documentation such as fi re prevention and odour management plans. Not renewing a planning consent After spending thousands of pounds getting planning, albeit a temporary permission, don’t forget to submit a renewal application (which is easy most of the time) to keep the permission alive. Not completing transfer notes fully Using a season ticket where possible will give drivers less paperwork to complete and avoid simple offences such as having an incomplete transfer note. Having electronic notes, which have most of the details pre-completed, will reduce the rate of errors. We’re all busy but take time to check the above issues as almost all operators I have worked with have had these issues at some time.

Have a good time if you’re going to RWM and don’t forget, if you buy any new shiny kit or software check that none of the issues mentioned above need attention.

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