Are your Hazardous Waste Consignment Notes being completed correctly?

EMS-hazardous waste

Last week’s blog looked at Waste Transfer Notes, when they are needed and what they need to include.  You can read it here.  Those notes cover the transfer of non-hazardous waste so this blog is going to focus on hazardous waste.  For the transfer of this type of waste, it must be accompanied by a hazardous waste consignment note.  So, how do you make sure that they are completed correctly?

Why do we have to fill them out?

For very similar reasons to why waste transfer notes need to be completed.  This is part of your ‘Duty of Care’ and you need to be sure that your waste is handled safely and correctly all the way to its final destination.

What information needs to appear?

The information for a hazardous waste consignment note is similar to what you need in a waste transfer note.  In fact, you will need all of the waste transfer note information.  For a refresher, check out last week’s blog as we will be talking here about what additional information is needed for hazardous waste consignment notes.  Where waste transfer notes can be in any format you like as long as it meets the legal requirements for information, hazardous waste consignment notes should be completed as close to the Environment Agency format as possible.  This format splits the information down into five sections, parts A-E.

Part A covers the origin and destination of the waste.  You must have a consignment note code unique to this transfer.  If you’ve registered as a hazardous waste producer, it will start with your premises code, if you are exempt, it will start EXE.  You also need to include your premises code, if you have one in this section.  In addition to where the waste was produced, you will need to include the destination of the waste.

Part B is all about the waste.  For hazardous waste consignment notes, you currently need to use the 2003 list.  In addition to the normal information about your waste, you also need to describe the chemical or biological components of the waste, it’s physical form e.g. gas, sludge etc and its hazard code.  You will also need to include information required for the transport of dangerous goods that includes UN identification number, proper shipping name, UN class, packaging goods and any special handling requirements.

Part C and D include information about the carrier and the holder of the waste respectively.  As well as the normal information, make sure you include the time of the transfer.

Before waste leaves your site, you need to check that all the information is correct, make any amendments as necessary and sign the document.  There is a section E, but don’t fill this out yet.

Do I have to fill one out every time hazardous waste leaves my site?

Yes, you do need to have a hazardous waste consignment note for every transfer of hazardous waste from your site.  There is no option for a season ticket for this type of waste.

Is there anything else I need to do?

You need to make sure that you keep your hazardous waste consignment notes on file for at least three years, a little bit longer than waste transfer notes.  You also need to make sure you get the information back from your waste contractor about where the waste has been disposed of.  This can come in one of two formats.  A copy of the note, with section E completed.  This will tell you where the waste has gone to, when and whether it was accepted.  Make sure you have all this information.  Otherwise, you may get a summary document for all your hazardous waste transfers.  Just make sure you have all the information and you get it at least quarterly.  If you don’t have this information, contact your hazardous waste contractor and they should be able to provide you with everything that you need.

Hazardous waste consignment notes are legal documents that must be completed fully and correctly for all transfers of hazardous waste.  It is important that anyone signing these notes on your company’s behalf know what they are checking and signing.  There are going to be some changes to the hazardous waste consignment note format from 1st April 2016 but we’ll make sure to cover it in a future blog.

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