Carriage of Goods & Waste Policy
This policy sets out our arrangements to ensure our duty of care in respect of waste carriage and to ensure that at all times waste is transported in a safe and professional manner and that all risks to driver / passenger safety and the general public have been identified and appropriate controls are in place to mitigate these risks.
No driver is permitted to or will be asked to transport any dangerous or hazardous goods while operating a vehicle on behalf of Stripout London Ltd. This is communicated through tool box talks to general staff and drivers. Where dangerous goods are to be transported in relation to any of our operating activities a specialist company will be employed to undertake such work.
Our carriage of dangerous goods and waste policy is designed to meet Section 34(9) of the Environmental Protection Act 1990 (EPA). In relation to the duty of care set out in Section 34(1) of that Act.
Our Commitments
We will prevent unauthorised or harmful deposit, treatment or disposal of waste.
We will not treat, keep or dispose of controlled waste in a way that is likely to cause pollution of the environment or harm to human health.
For Example:
We will NOT operate illegal waste sites without the correct permit or appropriate exemption to accept or manage a particular waste
We will NOT misclassify waste as a non-waste or a waste that does not fit the written description
We will NOT fly-tip, the deliberate unlawful dumping of waste - for example, at the roadside or on privately owned land - We will prevent a breach (failure) by any other person to meet the requirement to have an environmental permit, or a breach of a permit condition.
We will NOT transfer waste to a facility that does not have an appropriate permit or exemption to accept or manage that type of waste
We will NOT transfer waste in a condition which means that it cannot be managed or stored safely pending removal - for example, waste being stored outside the confines of buildings or bunds
We will NOT transfer waste in a quantity that causes a facility to exceed the limits allowed by its permit or exemption - for example, increasing or expanding piles of waste
If we suspect that someone does not have an appropriate environmental permit or registered exemption, or that they are breaching a condition of their permit or exemption, we will NOT give them our waste or take waste from them. We will report suspected illegal activity or breaches to permits or exemptions to the EA or NRW.
We will prevent the escape of waste from our control.
To prevent waste from escaping our control, or from our employees’ or waste contractors’ control, we will make sure it is handled and stored safely and securely.
We will do this by: using containers that are:
Clearly and correctly labelled
Suitable for the storage, transport and subsequent management activities by us and the following waste holder
Designed to prevent leakage, contamination or spoiling of waste (spoiled waste is waste that cannot be managed in the way intended)
Limiting access to the waste to only those that are authorised to handle it. This will help prevent accidents, pests, incidents of vandalism and theft. It will also stop unauthorised people adding to the waste and so invalidating the waste description.
Ensuring vehicles are covered and waste is secured appropriately for transport purposes
Before our waste is collected and disposed of or recovered we will assess and classify waste as set out in the waste classification guidance. This identifies whether the waste is hazardous or not, and which controls apply to the movement of the waste to prevent harm to people and the environment.
We will ensure that any person we transfer the waste to has the correct authorisation.
We will check whether a person or business is authorised to take waste before we transfer our waste to them. An authorised person is one of the following:
Someone who has a valid registration as a carrier, broker or dealer of waste.
A waste management operator who has an environmental permit or registered exemption to accept such waste
We will ask the person or business we transfer our waste to or who arranges the transfer for evidence of their authorisation, such as a copy of their permit or proof of their exemption registration.
We will also use the public register to check any evidence they provide. The register contains information on:
Waste carrier, broker and dealer registrations
Environmental permits for waste operations
Waste exemptions
In England, we will check registration on the EA’s public register or call 03708 506 506.
In Wales we will check on the NRW’s public register or call 0300 065 3000.
The person receiving the waste must also check that the previous holder has complied with their duty of care. If we suspect that the previous waste holder has breached their duty of care (for example, misdescribing the waste or not properly storing it), we will not accept the waste and report our suspicions to the EA or NRW.
We will record any checks we make as we can use this as evidence that we have met our duty of care.
If we use a dealer or broker to manage our waste, they will be registered as a dealer or broker with their regulator, even if they do not take physical possession of the waste.
Where a dealer or broker is the transferor or transferee of the waste, their details (including their registration number) will be included in the waste transfer information.
We will provide an accurate description of the waste when it is transferred to another person.
When we transfer waste to another person, we will ensure that:
1: A written description of the waste is agreed and signed by us and the next holder. The description is part of the waste information we will provide.
For non-hazardous waste we will do this using:
edoc – a free national electronic duty of care system that creates, shares, signs and stores waste transfer notes and season tickets for us online
A paper waste transfer note– a form to fill in or you can use alternative documentation - for example, an invoice, as long as it contains all the required information
A season ticket - a single waste transfer note that covers a series of non-hazardous waste transfers. The season ticket can last up to one year and be used for regular transfers of the same type of non-hazardous waste with the same carrier. If you have several sites serviced by the same carrier with the same types of waste collected, they can be listed in a schedule to the season ticket. You should keep a record of the collection times and the quantity of waste
A waste information note is not required for non-hazardous waste if the waste holder does not change on the transfer of waste - for example, the waste is moved to other premises belonging to the same business. However, it is best practice that the business understands who has responsibility for that waste and a record is kept of internal transfers for audit purposes.
For hazardous waste we will use a:
Consignment note - this applies to all movements of hazardous waste including collections from businesses by registered waste carriers, movements from one premises to another within the same business and all movements from the waste producer’s premises. The only 2 exceptions where a consignment note is not needed are where domestic hazardous waste (other than asbestos waste) is removed from a domestic household or waste is imported or exported under international waste shipment controls (which uses an equivalent note)
2: The description contains a statement confirming that we have fulfilled your duty to apply the waste hierarchy as required by regulation 12 of the Waste (England and Wales) Regulations 2011 (see Waste Hierarchy Guidance for England and Wales.
3: The description of the waste is accurate and contains all the information we are reasonably in a position to provide to ensure the lawful and safe handling, transport, treatment, recovery or disposal by subsequent holders, including:
Classification of the waste by using the appropriate codes (referred to as the List of Wastes (LoW) or European Waste Catalogue (EWC)) - Appendix A of the Waste Classification Technical Guidance provides a list of the codes as well as advice on how to assess and classify waste its quantity and nature and whether it is loose or in a container; if in a container, the type of container, the time and place of transfer the SIC code of the transferor (current holder of the waste). The name and address of the transferor and transferee (person receiving the waste) and their signatures (the signature can be electronic as long as an enforcement officer can view it)
The capacity in which the transferor and transferee are acting (for example, as a producer, importer or registered waste carrier, broker or dealer) and their relevant authorisation to act in that capacity (for example, their permit number or registration number)
We will also consider whether there are any problems associated with the waste that we need to describe so that subsequent users can handle it properly. Examples include whether the waste:
Needs a special container
Needs particular treatment or handling, for example batteries or waste electrical and electronic equipment (WEEE)
Can or cannot be mixed with other wastes
Could cause a problem during treatment or disposal - for example, dusty, smelly or otherwise offensive waste)
Has been processed (for example, undergone treatment) or had certain materials removed from it (for example, packaging) to meet basic characterisation requirements of wastes destined for landfill
Displays a hazardous property (for example, flammable) or presents a chemical hazard
Has other issues (for example, risk of spillage or leakage of liquids)
If we receive waste, we will ensure the waste matches the written description and that your permit allows you to accept such waste.
If we are operating under a waste exemption, we will ensure that by accepting any waste we are not contravening the exemption criteria - for example, waste limits.
Retention of waste documentation
We will keep a copy of the waste description for waste we have transferred or received (either electronically or on paper format) for:
2 years for non-hazardous waste
2 years for season tickets
Three years for hazardous waste consignment notes (different retention periods apply for consignees (receivers) of hazardous waste; see further detail in the hazardous waste guidance)
Six years if we are ever a landfill operator for non-hazardous waste (for landfill tax purposes)
The lifetime of our permit if we are ever a landfill operator for hazardous waste
The lifetime of an environmental permit (when the permit is surrendered, the regulator often requires a history of the types of waste received)