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18 November 2008


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Duty of care – your waste responsibilities

Records for receiving and transferring waste – waste transfer notes

What is a waste transfer note?

A waste transfer note (WTN) is a document which must accompany any transfer of waste between different holders. The purpose of a WTN is to allow other people who handle your waste to know what they are dealing with so that they can manage it safely and properly.

You must create a WTN for each load of waste that leaves your site. For repetitive transfers, you can use a 'season ticket’, ie one transfer note will cover multiple transfers over a given period of time of up to 12 months. However, you can only use a season ticket if the parties involved in each transfer are the same and the description of the waste transferred remains the same.

What information should a WTN contain?

The WTN must contain enough information about the waste to enable anyone coming into contact with it to handle it safely, and either dispose of it or allow it to be recovered within the law. If you don’t give enough information you may be prosecuted.

In England and Wales, you should describe the quantity and types of each different waste being transferred on the WTN, both in words and by using the appropriate codes in the List of Wastes (England) Regulations 2005 and the List of Wastes (Wales) Regulations 2005.

If you operate in Northern Ireland, you should describe the quantity and types of each different waste being transferred both in words and by using the appropriate codes in the List of Waste Regulations (Northern Ireland) 2005.

In Scotland, you should describe the quantity and types of each different waste being transferred on the WTN, both in words and by reference to the appropriate codes in the European Waste Catalogue (EWC).

The WTN should also include details of how the waste is contained, ie whether it is loose or packaged. If the waste is packaged, then the WTN should include details of the type of container.

Who needs to sign the WTN?

You should never rely on waste carriers or waste management contractors to describe your waste for you on WTNs. As the producer, you are in the best position to describe your waste accurately. It is not acceptable to use non-specific terms, eg 'general waste' or 'inert waste'.

Both you and the waste carrier must sign the WTN before the waste leaves your site.
If you transport waste yourself, you and the operator of the waste management site who you hand your waste over to must sign the WTN. If you use a waste broker, you must ensure that they are registered.

You must keep copies of all WTNs for at least two years. This is your record of the type and quantity of waste you transferred, how it was packaged, when you transferred it, where it went and who you transferred it to. These are all requirements of the duty of care.

Periodic checks (audits) will help you to ensure that your wastes are handled correctly from the moment they leave your premises to the final point of disposal or recovery, and prove that you are complying with your duty of care.

Documentation for hazardous/special waste

The transfer documentation for hazardous/special waste is called a 'consignment note'. If your waste has hazardous properties, you may need to treat it as hazardous/special waste. In this case, you need to complete a consignment note to comply with your duty of care. The consignment note must contain similar information to a WTN. A separate WTN is not required.

Waste that is defined by the European Waste Catalogue (EWC) as hazardous can only go to a waste treatment facility that is licensed to receive hazardous waste.

You must ensure that wastes that you produce irregularly (eg redundant materials, wastes from cleaning up spills) are declared on WTNs. Some of these wastes may have to be handled as hazardous/special waste.

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Author: Emma Davies | enquiries@environment-agency.gov.uk