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Health and Safety Hazardous Waste Guide

March 22, 2023 | By: Bryan Underdown

You must identify and classify your waste before you send it for recycling or disposal. This makes sure you or anyone handling your waste deals with it properly.

You must make sure hazardous waste produced or handled by your business in England causes no harm or damage.

You have responsibilities known as your ‘duty of care’. You must also meet extra requirements depending on whether you’re a waste:

Check if your Waste is Hazardous

Waste is generally considered hazardous if it (or the material or substances it contains) are harmful to humans or the environment. Examples of hazardous waste include:

  • Asbestos.
  • Chemicals, such as brake fluid or print toner.
  • Batteries.
  • Solvents.
  • Pesticides.
  • Oils (except edible ones), such as car oil.
  • Equipment containing ozone depleting substances, like fridges.
  • Hazardous waste containers.

Steps to follow for Producers and Holders of Hazardous Waste

You must follow these steps in England if your business:

  • Produces hazardous waste.
  • Holds or stores hazardous waste.
  • Has hazardous waste removed from its premises.
  1. Classify your waste to check if it is hazardous.
  2. Separate and store hazardous waste safely.
  3. Use authorised businesses to collect, recycle or dispose of your hazardous waste – check that waste carriers are registered and waste sites have environmental permits.
  4. Fill in the parts of the consignment note that apply to you – keep one copy and give 2 copies to the carrier collecting your waste.
  5. Keep records (known as a ‘register’) for 3 years at the premises that produced or stored the waste.

Records you Must Keep for Hazardous Waste

You must keep your copies of:

  • Consignment notes.
  • Consignee returns – you’ll get these from businesses that receive your waste (consignees).
  • Any related documents, for example ‘carrier schedules’ (list of carriers when there is more than one), records of rejected loads.

If these documents are not accurate or complete, you must keep a record of any missing information.

Hazardous Waste Carriers

You must follow these steps if your business collects and transports hazardous waste in England (for example you’re a waste carrier, or you move your own waste).

  1. Register as a waste carrier.
  2. Check parts A and B of the consignment note and the waste before you accept it – make sure the waste is classified correctly.
  3. Separate waste correctly when you load it for transportation.
  4. Fill in the part of the consignment note that applies to you.
  5. Leave one copy of the consignment note with the waste producer or holder and keep 2 copies – these must stay with the waste until it reaches its destination.
  6. Take the waste to the destination on the consignment note – this must be an authorised waste site.
  7. Keep records (known as a ‘register’) for one year.
  8. You must keep records at your head office.

Records you Must Keep for Hazardous Waste

You must keep copies of:

  • Consignment notes.
  • Any related documents, for example ‘carrier schedules’ (list of carriers when there is more than one), records of rejected loads.

If these documents are not accurate or complete, you must keep a record of any missing information.

Consignees for Hazard Waste

You must follow these steps if you receive, treat or dispose of hazardous waste at premises in England.

  1. Get an environmental permit or register an exemption for your premises.
  2. Check the consignment note and waste before you accept it – make sure it is classified correctly.
  3. Reject the waste if the consignment note is missing, incorrect or it is incomplete.
  4. Ensure part E of the consignment note is filled in for any hazardous waste you accept or reject.
  5. Keep one copy and give one copy to the carrier.
  6. Ensure you send consignee returns to the Environment Agency and the waste producer or holder, to report any hazardous waste you accept or reject.
  7. Keep records (known as a ‘register’).

You must keep records at the site where the hazardous waste was stored, treated or disposed.

Records you Must Keep for Hazardous Waste

You must keep:

  • Consignment notes.
  • Any related documents, for example ‘carrier schedules’ (list of carriers when there is more than one), records of rejected loads.
  • A site inventory that records where waste was stored, treated or disposed of at your waste site – keep this in a secure, marked area that is accessible in emergencies.

There are special rules for dealing with hazardous waste or disposing of waste with a high level of persistent organic pollutants (POPs), this is known as POPs waste.

Filling in Waste Transfer or Consignment Notes

You must describe your waste in the paperwork you give your waste contractor. This must include:

  • The waste classification code, also referred to as LoW (List of Waste) or EWC (European Waste Catalogue) code - classification codes for common types of waste are in the relevant parts of this guidance.
  • Whether it is hazardous or POPs waste.
  • The type of premises or business where the waste was produced.
  • The name of the substance or substances.
  • The process that produced the waste.
  • A chemical and physical analysis of the waste and its components.
  • Any special problems, requirements or knowledge related to the waste.

How to Find out if your Waste is Hazardous or POPs Waste

  • In most cases you can check the waste code or codes associated with your waste to see if they are hazardous and POPs waste. You must make sure your waste contractor can dispose of this waste properly.
  • Some waste items have more than one classification, depending on the possible mix of substances in them.
  • In these cases, you must work out exactly what is in your waste, and how much of it is hazardous or POPs.
  • Check the manufacturers product safety data sheet for the information or carry out an assessment.

It is illegal to mix hazardous or POPs waste with either non-hazardous or another hazardous waste.

If you need advice on health and safety surrounding hazardous waste call 033 33 215 005 or email websiteenquiries@wirehouse-es.com

About the Author
Bryan Underdown
Bryan Underdown
Bryan Underdown, Author at Wirehouse Employer Services

Bryan has worked in the Environmental Services sector for 25 years – initially with risk management companies offering consultancy services on health and safety, food safety, pest prevention and fire safety services to property and facilities management companies. During a period of self-employment as a Health and Safety Technician he worked with small businesses and gained a tremendous amount of ‘hands on’ experience with a wide range of manufacturing companies and contractors. He has worked as an advisor to a major care group - gaining considerable health and safety, fire safety, water safety and food safety experience in the nursing, residential and independent living sectors - and as an advisor to a civils contractor working on the highways.

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