ENV/Waste Management/TBT-ENV-032
Duty of Care and Waste Transfer Notes
Environmental › Waste Management › Duty of Care and Waste Transfer Notes
Toolbox Talk
Duty of Care and Waste Transfer Notes
Under the Environmental Protection Act 1990, every person who produces, carries, or disposes of waste has a legal duty of care to ensure it is handled safely and lawfully. Waste transfer notes are the documentary proof that this duty has been met. Failing to complete them correctly is a criminal offence that can lead to prosecution and unlimited fines. This talk explains the duty of care requirements and how to complete waste transfer notes.
Key Hazards
Criminal prosecution and unlimited fines for failing to meet the duty of care
Fly-tipping traced back to the site because waste carrier checks were not done
Hazardous waste sent to an unlicensed facility due to incorrect classification
Missing documentation making it impossible to prove lawful waste disposal
Control Measures
- Check that every waste carrier collecting from site holds a valid Environment Agency registration.
- Complete a waste transfer note for every load of non-hazardous waste leaving the construction site.
- Complete a consignment note for every collection of hazardous waste and retain copies for three years.
- Describe the waste accurately on the transfer note including the type, quantity, and EWC code.
- Record the destination facility and confirm it holds the correct environmental permit for the waste type.
- Retain all waste transfer notes for a minimum of two years and hazardous consignment notes for three.
- Brief site personnel on the waste segregation system and which skips are designated for each type.
- Refuse to release waste to any carrier who cannot produce a valid waste carrier registration document.
- Review waste records monthly to ensure all collections are documented and no gaps exist.
Remember
- Check that every waste carrier holds a valid Environment Agency registration before releasing waste
- Complete a waste transfer note for every non-hazardous waste load leaving the site
- Complete a hazardous waste consignment note for every hazardous collection and keep it for three years
- Describe the waste accurately including type, quantity, and EWC code on every transfer document
- Retain waste transfer notes for at least two years and consignment notes for at least three
- Refuse to release waste to any carrier who cannot produce valid registration documents
Applicable Legislation: Environmental Protection Act 1990 · Waste Duty of Care Regulations 1991 · Hazardous Waste Regulations 2005 · CDM Regulations 2015
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