Morning all,

When I'm not working in Health and Safety, I volunteer as a Scout Leader. We had a leaders meeting recently and discussed fundraising by collecting cans and getting paid to bring them in for recycling. Someone pitched in that the companies being collected from would need to produce waste consignment notes and other associated paperwork. This does sound especially bureaucratic from something that needn't be - it's not like it's hazardous waste.

In my case, the company I work for does get through a fair few cans due to the on-site staff canteen and we have the capability to separate (as you'd expect). I would be transporting the cans back to the scout hut by my own vehicle and the cans would then be collected/delivered by other means.

Do I, the company or the scout group really have to jump through these hoops just to collect and move aluminium cans?

Thanks for your thoughts.

Steve.

Waste is the last definition inferring disposal by incineration, land-fill etc.

The legsilation is there to control waste and ensure it is correctly dealt with - the consignment notes ask you to attest that you have been unable to reduce, re-use or recycle the material.

You are talking about being at level 3 in the heirarchy of controls recycling so by definition not moving waste.

What does your intended reception plant (or the Environment Agency) say?

one man's rubbish is another man's treasure http://forum.iosh.co.uk/posts/t127574-Waste-wood or rather one company's co-production is anothers raw material.

The last update I saw to the directive EU 2018/851 opened with "Waste management in the Union should be improved and transformed into sustainable material management..."

Only when you have exhausted the control options do we get in to actual waste management which is where the paperwork, permits and licensing kick-in.

So whilst it is the Waste Framework under which the legislation is written it is only the residuals at the end of deliberations that are truly "waste" otherwise we would be filling in paper work at every step of our activity.

Yes, it is waste! the definition of waste is “…any substance or object that the holder discards or intends or is required to discard…”

Secondly a consignment note is for hazardous waste, a “Transfer note” is for non-hazardous waste. A transfer note is easy to produce (and does not require a part E)- you will need an EWC code for the cans.

You can get a lower tier waste carriers’ licence ( free) which will allow you to carry your own waste. So, if the company give you the waste it is yours!

On the transfer note you create state the final destination as the place you intend to take it ( who will have a licence- easy to look up on the public register). Get your hands on a transfer note and copy the format no need for a licence to do that, make sure you have the EWC code (looking at the list I would use 15 01 04 for waste metal packaging).

It does not matter if you intend to sell your waste or if it to be recycled or turned into energy or heat it is still waste up to the point it is a raw material for something else.

Edited by user 13 December 2018 17:07:07(UTC)  | Reason: added (free)

You may need a licence as a dealer, but you may be able to get and exemption for what you do as you are only holding it. Your duty goes beyond your premises to its final destination, but that is not a problem. All you need to do is ensure that whoever takes the waste has a carrier’s licence and the place it goes to has an appropriate licence as an operator or they may even have an exemption. Both these licences can be looked up on the public register for free. You will be responsible for the content of the transfer note but the carrier company will produce the note for you. Same EWC code as above. NB to check the carrier you need their permit number which should be written on the transfer note and start likely CBDU……, for the management site it is the address and specifically the post code you want to search on.

I thought waste aluminium was £1,000 a tonne that’s a lot of food cartons !

Hope this helps