INDUSTRY NEWS MARCO MUIA BSc (Hons) MSc MCIWM, Managing Director
at Oaktree Environmental Limited. Marco specialises in all aspects of waste planning and regulation consultancy. He also holds the level 4 COTCs for Hazardous Waste Treatment and Transfer.
01606 558833 |
marco@oaktree-environmental.co.uk Twitter @wastechat.
ENVIRONMENTAL Hazardous Waste: FAQs
THE Hazardous Waste (England and Wales) Regulations 2005 have been in force for almost 14 years but I still get asked questions and come across errors on a daily basis, so here are the most common ones answered.
What guidance is available for classifying hazardous waste? Technical Guidance WM3: Waste Classification – Guidance on the classification and assessment of waste. Google it but make sure you download version 1.1 dated May 2018.
When do I have to register as a hazardous waste producer? The requirement to register ceased in England on 1 April, 2016. In Wales it costs £18 to register your premises at
www.gov.uk/hazardous-waste-producer- registration-wales
Where can I get hazardous waste consignment notes?
The standard format can be downloaded from the
gov.uk website. The Welsh version differs in that it has to include the premises registration code and is available on the Natural Resources Wales (NRW) website.
Do I need to comply with the Duty of Care separately?
No. The consignment note replaces the transfer note and the complexity of the consignment note procedure, if followed correctly, ensures compliance with the
Duty of Care. Check the notes you are using are up to date and include the waste hierarchy declaration.
Do all sections of the consignment note need to be completed? Yes. Don’t miss any parts out that apply to you as a consignor, carrier or consignee. Read the guidance. Do not change any of the information entered by another person.
How long should I retain my consignment notes?
Producers/consignors must keep copies for three years and should receive copies from the consignee (destination site) every quarter. Carriers must keep copies for one year but to comply with the Duty of Care they need to be retained for two years. Consignees need to keep the copies until they surrender their permit. Copies can be stored electronically.
What returns need to be made to the regulator?
For sites accepting hazardous waste a quarterly return must be sent to the EA or NRW listing the consignments accepted. The sites are then invoiced for the total cost of the consignments received i.e. £10 per single consignment and £5 for multiple collections (for electronic returns). Hazardous waste must be included on your normal waste returns as well.
Do exempt sites have any specific requirements?
Exempt sites accepting hazardous waste must also use consignment notes and submit hazardous waste returns but do not need to submit non-hazardous waste returns.
Can I mix hazardous wastes? Mixing different categories of hazardous waste or mixing with non-hazardous waste is an offence unless permitted by a permit or exemption.
What do I do if a load is rejected by a hazardous waste site or any other site? Consignees can reject loads for a variety of reasons, not limited to errors on the consignment note, such as site closure, adverse weather, lack of storage capacity etc. Read the detailed guidance on rejecting hazardous waste as it is not widely understood.
If I clear fly tipped hazardous waste do I need to use a consignment note? Yes. Producer registration is not needed. Always contact the regulator as they may be in a position to investigate the deposit and pursue the culprit if evidence is available.
These questions are not fiction. They apply to a number of companies I have advised recently. If you are unsure check the guidance as it is very easy to commit an offence under these regulations.
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