Pulp Faction Recycling

Waste Transfer Notes & Duty of Care

All our waste transfer notes contain European Waste Classification Codes ensuring European Waste Regulation compliance. 

You will receive 2 copies of your waste transfer note. You will need you to sign both copies, keep one for your records (see below) and return one to us for ours; this will satisfy both our obligations under Duty of Care.

This does not constitute a written contract it is however a legal requirement for both parties to keep a copy of this document for two years.

We are registered as a waste carrier with the Environment Agency under the control of pollution (amendment) act 1989.

Duty of Care as Defined by Environmental Protection Act 1990.
http://www.legislation.hmso.gov.uk

Environment Agency
http://www.environment-agency.gov.uk

Advice from Environment Agency follows

For the purposes of Duty of Care, waste is any substance or object that has been discarded. Even if the waste is not dangerous and even if it is in small quantities, the Duty of Care applies to your business since all businesses produce waste.

  1. Understand that your company has a Duty of Care to ensure the proper and safe disposal of waste even after it has been passed on to another party such as a waste contractor, scrap merchant, recycler, local council or skip hire company. This Duty of Care has no time limit and extends to the final resting place of the waste concerned. 
  2. Make all waste secure and keep it in suitable containers at all times.
  3. Ensure that storage facilities are secure against vandalism or other outside interference.
  4. Keep all wastes under cover when awaiting collection.
  5. Ensure that all those removing wastes from your company's premises prove that they are registered waste carriers or have a relevant waste management license . This aspect of your firm's Duty of Care applies to all those who handle your business wastes including those companies or individuals that act as waste brokers or that carry out recycling involving reprocessing. In the specific example of suppliers taking back empty containers or other materials for reuse in the same form without any reprocessing, they may not need a waste management license or be registered as a waste carrier if the material involved falls outside the description of waste given above.
  6. Check to establish if any containers or other materials taken back by a supplier are, in fact, being reprocessed or disposed of. If they are, check that the supplier is a registered waste carrier or broker as above and, if applicable, holds a waste management licence.
  7. Ensure that all those treating, storing or disposing of your company's wastes (wherever that may be) have a waste management licence.
  8. Quantify and describe EACH DIFFERENT TYPE of waste disposed of. This information must be recorded in writing on transfer notes that are signed by both parties involved in the transfer or disposal of each waste. All transfer notes should contain enough information for the wastes to be handled safety and within the law. However, it is permissible to agree a description with the waste carrier on an annual basis as long as that description remains accurate for the year in question.
  9. Ensure that all wastes that arise irregularly (e.g. redundant materials, wastes arising from cleaning up spills) are declared on waste transfer notes or included in annual waste descriptions agreed with waste carriers. Note that some of these wastes may have to be handled as Special Wastes.
  10. Never rely on waste carriers or waste management contractors to describe your waste for you. Write descriptions of the waste on documentation yourself and write them accurately. Non specific terms such as 'general waste' or 'inert waste' are not acceptable.
  11. Keep copies of all transfer notes for two years (three in the case of Special Waste ).
  12. Wherever your company's wastes are being taken to and whichever organisations are handling them, it will help you to prove that you have discharged your Duty of Care if you carry out periodic audits to ensure that your wastes are being handled correctly from the moment they leave your premises to the final point of disposal.
  13. Ensure that all employees and contractors working on your premises are given specific instructions relating to how EACH AND EVERY waste that might arise is to be handled and disposed of.
  14. Check frequently that employees and contractors are following the instructions given to them with respect to handling and disposal of wastes.