Advice: Top 3 tips for duty of care compliance
Regardless of your organisational size, or the nature of what you do: if you produce waste, the Duty of Care applies to you.Here are Lee Petts' top 3 tips for ensuring that you stay on the right side of the law.
1. Don't let others describe your waste for youThis is a classic mistake we see all the time.
The law says you, as waste producer, are responsible for this. And it's obvious why - because you know what you put in your skips, or what's in your hazardous waste, far better than anyone else.It's a bit different if you employ somebody like us, where we get so close to what you do that we almost become an extension of your team and know your wastes as well as you do, but if all you do is contract with companies that remove your waste when you ask them to, do not let them describe and classify your waste for you.
2. Registered Carrier check, check and check againBefore allowing any company to remove your waste, you must obtain a copy of their Registered Waste Carrier certification. But don't just accept it at face value and stick it in a filing cabinet somewhere - you need to validate it.
It's pretty easy to do. In England and Wales, simply visit the online public register here http://epr.environment-agency.gov.uk/ePRInternet/SearchRegisters.aspx, enter the search criteria you're interested in and let it do the rest.Your results will be returned on screen. Click on the record you're interested in, and it will then take you to the details you need. We simply print this screen, with time and date stamp, as a record of the checks we've made and then repeat this annually (the details are also logged in our CRM system, which generates an automated reminder after 11 months so we don't forget to check again).
3. Make sure they can take itOK, think you're done checking? Think again.
Once you've validated the credentials of the organisation that's going to collect your waste, next you need to make doubly certain that the intended destination for your waste is appropriately authorised to receive it.Now, here again, it can easily go wrong. Often, when asking for evidence that a facility is properly permitted to receive the target waste, waste producers are presented with the front page of the operator's environmental permit which states the name and location of the facility and the permit number.
Is that enough?Well, no. You see, all that does is confirm the facility is permitted. What you need to do is get a copy of the List of Wastes they are allowed to accept and deal with and check that yours appears (remember Top Tip #1 above). If it does, you're good to go. If it doesn't, then you can't send your waste to them.