In earlier blogs in this series, we have detailed the general duty of care all parties handling waste need to comply with and what information needs to be included in a waste transfer note. Here we look specifically at what you need to do if you are a haulier and you transport waste.
The rules for transporting waste apply whether or not it is your main business to transport waste or you just do it occasionally. There are two tiers of waste carrier’s licence – lower and upper tier registration. You must make sure you have the correct tier of registration.
All the usual transport regulations continue to apply whether or not you are carrying waste, so you need to make sure you have planned your journey to comply with those as well.
The five most important things you need to do are as follows:
- Register for the relevant Waste Carrier’s Licence (and renew it each time it comes close to expiring)
- Check that the person you are receiving the waste from and the person and site you are delivering the waste to have the relevant permit or exemption if required
- Check that any description of waste transfer note you receive from the producer (or transferor) of the waste contains all the information it needs to and that you have signed the note to confirm this. Challenge the information if it is incorrect.
- Ensure that any waste transfer note you produce for the waste transfer contains all the information it needs to and ensure that the receiver of the waste signs your waste transfer note
- Keep records of the transfer (most importantly the waste transfer notes or consignment note) for 2 years (for non-hazardous waste) or 6 years (for hazardous waste)
In terms of waste transfer notes for hauliers, we would advise having a template waste transfer note which includes your details and registration number pre-printed/entered so it makes it easier for your drivers to fill in. You may also want to consider having spaces for both the address and registration of the person you receive the waste from and the details, address and registration of the person and site you are delivering the waste to on the same form, with lines for all three parties to sign the waste transfer note. That way you have a complete and accurate note if the transfer note you receive from the person you collected the waste from is less detailed.
You should also consider training all your drivers in the waste duty of care and what to look out for as you as a company will be criminally liable for your driver’s actions if they do not comply with the duty of care.
If you have any concerns or queries, or are being investigated by the EA for waste issues, please contact our Regulatory Team who will be happy to help.