As a waste producer understanding what is required to ensure you are compliant can be time consuming, costly and confusing. Through listening to our customer we developed a new waste compliance service based on the issues our customers tell us they struggle with requiring assistance to ensure they remain compliant. The proactive approach we take means we are able to identify any future or potential changes to legislation. Clarification of change and sourcing ways to limit the impact to our customers is all part of the role responsibilities of our compliance champions (in house experts).
Our compliance service includes:
- EA premises registration
- Pre-acceptance audits
- Consignment Note Compliance, filing, copying and tracking
- Duty of Care Compliance filing, copying and tracking
- Clinical Waste Policy
- Clinical Posters
- Waste Segregation & Colour Coding & Advice
- De-mystifying EWC & Hazardous Waste Coding
When you use our compliance service you can be confident your waste streams are compliant, managed, registered and up-to date leaving you free to manage your business.
EA Premises Registration
You must register with the Environment Agency if you are generating more than 500kg of hazardous waste per annum. This means you are complying with the Environmental Protection Act 1990. Your EA registration number will then appear on all hazardous waste consignments, which is required under the hazardous waste regulations.
EA Premises Registration Questions
- Can my waste be collected if I do not have an EA Premises code?
If you are producing more than 500kgs of hazardous per annum the waste company will not be able to collect your waste unless you are registered. It is important that you keep in mind this 500kgs per annum includes; not only your clinical waste, but also any chemicals, pesticides, electrical equipment, lead acid batteries, fluorescent tubes and other waste types.
- How do I know when I have reached the 500kgs threshold
We are asked this question almost daily and the answer is complex hence why we have set up the compliance service it means having the weights of all your hazardous waste streams and or knowing how to obtain this information.
Pre-acceptance waste audit
The Environment Agency has imposed a legal requirement in the Environmental Permits for Disposal sites to ensure that producers of clinical waste carry out audits of their waste before it can be accepted.
To ensure your waste is suitable for any chosen method of disposal, all your waste streams must be audited, documented and communicated to the final disposal site. Failure to do this may leave you in breach of your duty of care responsibilities, which can lead to prosecution and unlimited fines.
As a result, the disposal contractors accepting your waste from us for disposal require us to demonstrate that we have obtained this audit information from our customers before it can be legally accepted and disposed of.
Waste Pre-acceptance questions
- Who has the responsibility for undertaking pre-acceptance audits?
The waste producer is responsible for providing a compliant waste pre-acceptance audit to the waste contractor, however, the audit can be undertaken by the waste producer, the waste contractor or a waste management consultant.
- Can any member of staff complete an audit?
The person undertaking the audit must be ‘suitably trained and competent’. In practice this means that the person must have a good working knowledge of HTM 07-01 (segregation, colour coding, etc.) and the pre-acceptance guidance in EPR 5.07 (the Environment Agency guidance for clinical waste facility operators) as a minimum.
In England and Wales, it’s a legal requirement (under the Hazardous Waste Regulations 2005 (as amended)) for every movement of hazardous waste to be accompanied by a hazardous waste consignment note. The Environment Agency (in England) and Natural Resources Wales (in Wales) are legally entitled to charge a fee for each movement of hazardous waste. The fees are used by them to pay for regulating hazardous waste management.
Consignment note questions
- How long do i have to keep my HWCNs for?
Waste producers must keep the producer copy of each consignment note for three years from the date of the collection.
- What happens if i lose some or all of my HWCNs?
Principal Hygiene have invested in technology to track all HWCNs we provide for our customers, we send all consignment notes by email, copies are attached to the customer account where weights per consignment are measure, monitored and reported. If a customer loses a single document or several we can produce copies within minutes ensuring, you remain in control.
Duty of care compliance
Principal Hygiene have invested in technology to track all Waste Transfer/Duty of Care Documentation. All documents are sent to customer via email following every waste collection, copies are attached to the customer account. If a customer loses a single document or several we can produce copies within minutes ensuring, you remain in control.
- How do I make sure I comply with the duty of care?
1. You must identify and describe your waste correctly – ensure the waste transfer note or consignment note correctly describes the waste and uses the relevant EWC codes.
2. You must keep your waste safely – use appropriate containerisation and storage, and correct packaging and labelling.
3. You must transfer your waste to suitably qualified persons:
Via a registered waste carrier
To a suitably licensed/permitted disposal site
4. You must make reasonable checks to verify the above – Duty of Care audits
5. You must keep records (consignment/transfer note records, producer returns, service agreements/contracts)
We track all legislation for you monitoring, filing providing copies and updating you with any recent or upcoming changes to legislation. With our Waste compliance Services you get peace of mind and the confidence knowing we care in control and have you covered.
Call the experts
As a waste producer do you know if you are compliant? Do you know how effective or if your waste disposal service represents value for money? Not sure? then talk to Principal Hygiene we can help you with advice and support ensuring you have the right services in place that delivers value for money, is compliant and meets your waste disposal needs.
Get a Clinical quote today or call us to discuss further, if you are unsure about the type of container you should be using or you have a mixed waste stream call us, we are on hand to provide advice and support.