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Environmental query - Who is the producer?
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roshqse  
#1 Posted : 12 June 2013 13:07:24(UTC)
Rank: Forum user
roshqse
Quick question... If we employ a sub contractor on one of our projects, and during THEIR works they have left over materials, off cuts etc... Are THEY the producer, or are we ,as it is our project, site, contract etc. Also, if they are the producer, I assume they would then be required to be registered with the EPA? As a point, the waste would be removed from site in a skip provided by us. (I hate environmental regs, can't get my head round them at all....)
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SafetyGirl  
#2 Posted : 12 June 2013 13:18:59(UTC)
Rank: Forum user
SafetyGirl
We write it into our HSE Plans that waste produced directly from project activities undertaken by our project team is disposed of by us - any waste produced by sub-contractors must be disposed of by them and not via our site (I think we then essentially become a waste transfer station - TBH I'm not sure about this though....)
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jarsmith83  
#3 Posted : 12 June 2013 13:22:04(UTC)
Rank: Super forum user
jarsmith83
I have been asking the very same question. I have been in contact with the EA local authorities and then decided I needed to study the environmental aspect of my role more closely. To answer your question, the waste producer is the person who creates waste at source.
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roshqse  
#4 Posted : 12 June 2013 16:50:32(UTC)
Rank: Forum user
roshqse
My thoughts too. Reason I ask is we are pre approving a contractor and they claim they don't have o be registered with EPA as they are a 'small business' and don't produce waste! Think I'm just going to tell them if they don't register as an upper tier (as we are) they're not getting any work from us.
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chris42  
#5 Posted : 12 June 2013 17:00:07(UTC)
Rank: Super forum user
chris42
Is this hazardous waste ? Didn't think you had to register for non hazardous waste, only hazardous (if over 500 kg/ yr) Other than that registered as what, carrier, dealer ?? Is it construction waste ?
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boblewis  
#6 Posted : 12 June 2013 20:43:53(UTC)
Rank: Super forum user
boblewis
Hazardous waste is part of the premises waste rather than the actual producer ie such as a contractor. As long as you make the waste arrangements clear in the contract then that is what matters. If you do not mention it then the subbie is likely to presume the Principal contractor will provide. In actual fact the PC provision reduces the proliferation of skips on site and perpetual bickering over whose waste is going in which skip. Contra charges are possible if you can find a formula. Bob
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roshqse  
#7 Posted : 13 June 2013 15:19:59(UTC)
Rank: Forum user
roshqse
They are electrical engineers so I assume their waste would be construction waste? I thought you had to register for this??? We are registered for both hazardous waste and as an upper tier carrier. So am I correct in think that as long as they do not remove their waste themselves they do not need to be a registered carrier? Confused..????
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MEden380  
#8 Posted : 13 June 2013 15:42:49(UTC)
Rank: Super forum user
MEden380
roshqse If they don't carry waste they don't need to be a registered carrier. However, I can not imagine they don't carry waste at some time in their vehicles so they should be registered as carriers. If they have a skip on site and the site is registered, this would be the number put on any consignment note for the skip provider. If they take any rubbish away to their yard then put in skip they would use their own number if registered. If a site is not registered and it a relative small number of skips of non hazardous waste there is a number you can find on Environmental Agency web site - don't ask me where, but if you follow the commercial waste ladder you will eventually come to it. On the other hand I might be completely incorrect in my interpretation, as previous threads have said our UK Legislation is a complete minefield
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roshqse  
#9 Posted : 13 June 2013 16:31:16(UTC)
Rank: Forum user
roshqse
'Minefield' is an understatement! the various opinions expressed here show how difficult it is to understand. And we are the professionals??
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CliveLowery  
#10 Posted : 14 June 2013 15:20:04(UTC)
Rank: Forum user
CliveLowery
Roshqse, I had a similar situation a while ago, I spoke to the EA direct in Sheffield - very helpful and friendly, give them a ring, they are after all the enforcers. Regards Clive
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Reed21854  
#11 Posted : 14 June 2013 16:19:35(UTC)
Rank: Forum user
Reed21854
Hi there, The company I work for are electrical contractors. We do hold a Waste Carriers Licence as sometimes on small jobs we will carry waste from site back to our HQ for recycling / disposal. I would say that if the company you are dealing with are small they are probably not aware of their legal obligations and they may tell you that they always dispose of waste on site via the Principal Contractor's skips and waste arrangements. If they really do this every single time they have no need to register with the EA as far as I am aware. Good luck!
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