Waste Management & Recycling Solutions

The Waste Transfer Note

What is the Waste Transfer Note? And how does it affect your businesses waste collection?

Any business that generates, handles or get rid of ‘controlled waste’ has a legal obligation to hold a Waste Transfer Note under Duty of Care laws.  If you have waste, but are not responsible for its disposal, for instance an estate where there are shared bins managed by a management company, then the Duty of Care and transfer notes lies with the management company. Although, you are still responsible for making sure the waste is being properly handled.

‘Controlled waste’ is effectively all waste that comes from a business. Including waste that is collected for recycling in addition too waste that is disposed of to landfill or incineration.

What is Needed

The Waste (England and Wales) Regulations 2011 and the Environmental Protection (Duty of Care) Regulations 1991 they apply to the Duty of Care requirements brought in by the Environmental Protection Act 1990. They require that:

•       Waste is stored correctly

•       Must be collected by registered waste carriers

•       All collections need a Waste Transfer Note, that details the type of waste being collected

•       Waste Transfer Note’s must be kept for a minimum of 2 years

•       Waste must be taken to an approved waste handling facility

The Department for Environmental, Food and Rural Affairs (DEFRA) have issued a Code of Practice that describes the full specifications of Duty of Care as well as a brief publication.

The Northern Ireland Environment Agency (NIEA) have issued a revised Guidance document for consultation (Dec 2011).

Under the Environmental Protection Act (EPA) Section 33, it is an offence to dispose of waste – such as burning construction waste or tipping waste to land – unless it is at a site with a waste management license.

The Waste Transfer Note

The Waste Transfer Note is a lawful document that must be signed by both the waste producer and the waste collector.  From the 28th of September 2011, a waste transfer note must conform the latest requirements issued by the Waste (England and Wales) Regulations 2011.

It must include the following:

•       A written description of the waste being transferred.

•       The correct EWC code for the waste.

•       An indication of how the waste is contained. Eg. is it loose, in a sack, skip or bin?

•       A SIC 2007 code (required from 28th Sept 2011).

•       A tick box to state that the waste hierarchy has been used (required from 28th Sept 2011).

•       Determine the amount of waste being collected, for example the number of sacks or other containers, the volume of waste or its weight.

•       List your name and identify that you are the producer of the waste.

•       List the name of the person you are passing the waste to and their status, for example a registered waste carrier, including their registration number.

•       Give the address where you passed the waste to the other person as well as the date and time that you gave him the waste.

•       Be signed by both parties and be kept for at least two years.

For repeated transfers, where the description of the waste and all the circumstances remain the same one note can be issued and can last up to 12 months, can be used to cover all transfers.

Polidor Recycling provides all it’s customer with a valid Waste Transfer Note for all waste collection.  Generally, whichever waste collection company you use they should provide the transfer note, however even though they might fill it out, you still  you have to sign it AND ARE THEN LIABLE IF THE INFORMATION ON IT IS WRONG.  So it is extremely important that you confirm the details fully.

A biggest drawback with waste transfer notes is usually the waste description. This should contain both a brief written description and a List of Wastes (LOW) or European Waste Catalogue (EWC) Code (or codes), but where a description is given, the waste must not change from that description. The most typical type of waste is general mixed commercial waste. This is covered by the EWC code 20 03 01, but if a site is undergoing building work, for example, the builders wouldn’t be able to use the site’s normal waste bin for their waste as it requires a different classification.

The Waste (England and Wales) Regulations 2011 have provided the prerequisite for the Waste Framework Directive Waste Hierarchy to be applied. This details:

•       Prevention

•       Planning for recycling

•       Recycling

•       Recovery (Waste to energy etc)

•       Disposal (landfill)

Guidance have been issued by Defra and the EA on this though at this stage, the EA have given no signal as to how they will enforce it.

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