Person disposing hazardous waste

What is a consignment note?

A consignment note is the documentation which is left when hazardous waste is removed from your site. It is legal documentation and it details a description of the waste, where the waste has been removed from and where it will be taken. It should be signed by us, Citron Hygiene as the carrier of the waste and also yourselves and then kept on your site.

What is a duty of care waste transfer note?

A waste transfer note is similar to the consignment note, except that this covers non-hazardous waste. It is also only provided once a year on the first service and is then valid for the rest of the year.  No further documentation is required for the rest of the year.

What is a hazardous waste quarterly return?

As the name suggests it’s a summary waste return that documents the weights of waste removed in the previous quarter.  Rather than filling out part E within the consignment note, a quarterly waste return can be used instead, however, it should correlate with the consignment note in terms of timeline and format.

How do I know which documentation I need?

For any hazardous waste, you will receive a consignment note every time this type of waste is collected. For all non-hazardous waste you should have a duty of care waste transfer note on site and this will detail all non-hazardous waste and cover these for the year period stated on the document.

How long do I need to keep this documentation on site?

Consignment notes and quarterly returns need to be filed on site for a minimum of 3 years. Duty of care waste transfer notes need to be kept on site for 2 years. In the event of an audit you will be asked to produce the documentation dating this far back.

How do I determine whether my waste is hazardous?

Determining if waste is hazardous or not is based on whether or not the activity producing the waste is a healthcare activity. All healthcare activity waste should be consigned, whereas non-healthcare does not need to be. Some waste types are never hazardous (sanitary waste, offensive non-infectious waste) and some waste types are always hazardous (cytotoxic/cytostatic medicines or sharps, dental amalgam waste). Other waste types such as clinical bags, sharps contaminated with body fluids or medicines can be either hazardous or non-hazardous and this is when it depends on whether the waste is produced in a healthcare environment or not.

What is a pre-acceptance waste audit?

A pre-acceptance waste audit is a legal requirement brought in by the Environment Agency to ensure waste producers carry out audits on their waste in order for it to be accepted at disposal sites. Without having a copy of the waste audit, contractors should not remove any clinical waste from your site.

How do I know whether the pre-acceptance waste audit applies to me?

The waste pre-acceptance audit includes all healthcare activities. Specifically listed are businesses such as dental practices, vets, hospitals, health centres, pharmacies and care homes. The Environment Agency briefing is available, and this includes a longer list of business types that need to audit their waste.

What are my responsibilities as a waste producer?

As a waste producer your responsibilities do not end once the waste is collected. You have a duty of care to ensure the waste is safely stored on your site and then once the waste has been removed you need to ensure that the waste is taken to permitted disposal sites and moved by licensed carriers right up until final disposal.

How can I check that the company who collects my waste is licensed?

Any waste contractor should be able to provide you with copies of their waste carrier licence and the permits for the where the waste is taken. They should also be able to give you permit/licence numbers for any sub-contractors they use to dispose of the waste and this way you can check the waste is disposed of correctly.

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