Managing waste and getting it off site safely is a challenge at the best of times, but even more so during the current crisis. It’s been pleasing to see how well the waste management industry has reacted in general to the situation and there has now been further help from the regulators to help maintain social distancing as much as possible for frontline workers when transferring waste.
RPS concerning waste transfer and consignment notes
The Environment Agency has released a Regulatory Position Statement (RPS) concerning the requirement to sign paper waste transfer and consignment notes.
Under the duty of care regulations a signature is required at the point of transfer from one party to another. If you are using a paper-based system to comply with your duty of care obligations, then you would be required to sign the form and hand it over to the person collecting your waste.
Conditions
The agency has released an RPS C8 to allow this requirement to be temporarily suspended to protect front line workers and maintain social distancing, providing the following conditions are met:
Condition 1
You must make sure the appropriate person fills in the relevant sections of the waste transfer note or consignment note for each waste transfer. You do not need to sign, or get a signature, in the signature box. Instead of a signature the responsible person should provide personal / contact details.
Condition 2
If you are transferring or receiving waste, you do not need to physically hand over (or receive) the waste transfer or consignment note. But you must give (or receive) all the information and data normally provided in a note. This must be done before the waste transfer or at the time of the transfer – but not later.
Condition 3
For each waste transfer you must send or receive (as appropriate) the completed paper copy (without the signature) of the waste transfer or consignment note. You must do this as soon as possible and not later than 10 calendar days after the waste transfer has taken place. You must keep a record of any waste you transfer or receive during the period of time you use this COVID-19 RPS. These records must include all the information and data required by the waste transfer note and consignment note.
RPS Withdrawal Date
The RPS will be withdrawn on 30 June 2020 unless there is further communication from the Environment Agency to extend this. Once this deadline has passed the physical signature on paper documents will be a requirement again immediately.
This RPS is a welcome amendment in helping to reduce the risk to front line workers during the pandemic and is one in a series of similar adjustments the agency has been making to try to keep the system running as efficiently and safely as possible, whilst ensuring environmental standards are kept. If you require any help in moving waste or queries around waste management compliance during the pandemic please contact us on the details below. We are also holding fortnightly update webinars on managing waste during the pandemic and you can sign up to them here.
The full RPS can be found here.
