Right off, can I just say how much I HATE waste and the regs??!! Here goes.. We occasionally remove waste from client sites, or have it removed by another company. The waste is oil. The oil belongs to the client, it is being replaced by us. I record how much, when, where (address) who removed it, where it goes.(and I check that place is registered.) Keep the records for 3 years and make sure everything is traceable. Now another client has said that we should be recording THEIR site registration number for the records. I have NEVER been told this before. We are registered for handling waste (which we produce) and transporting it if required. Our specialist contractors who handle oil ALL the time, have never asked for this, our other waste handlers have NEVER asked this. Now we are being marked down in audits and inspections because the client believes they are right. Anyone know who is correct here?

I have no idea..! Not entirely sure they know to be honest. I had a meeting today about unrelated other things and this was mentioned in passing, then the debate began. If it's to show who took their waste, I give them a copy of the waste transfer note if it is taken by another handler, and a copy of ours if we take it. So I don't see why they need me to record THEIR site reg details. I think to be honest their getting themselves all tangled up in this.

The site will only have to be registered as a hazardous waste producer if they generate or hold over 500kg per year.