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#1 Posted : 18 December 2007 09:28:00(UTC)
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Posted By halesowen Baggie
We as a warehouse discard quite a lot of polystyrene packaging, a company adjacent to our says that it will buy this packaging off us.

What do I need to do as regards 'duty of care' as this is our waste, or is it our goods that we are selling on?
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#2 Posted : 18 December 2007 09:49:00(UTC)
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Posted By J Knight
Hi,

This would be waste, as that's what you see it as; by analogy we participate in white goods rebuild and resale schemes; these products are waste until they have been delivered to the engineers and refurbished, even though they are always intended for sale.

You should abide by the Duty of Care to Waste COP when you are shifting your polystyrene; the best approach would be to contact your local EA office,

John
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#3 Posted : 18 December 2007 10:01:00(UTC)
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Posted By Julian Wilkinson
Not sure if it really matters whether you pay or they pay you, but as far as the duty of care goes, it's important that you get some sort of confirmation that satisfies you their recycling processes specific to your waste is legal and ethical.
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#4 Posted : 18 December 2007 10:01:00(UTC)
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Posted By M J Matthews
Hi

Does your participate in the Valpak scheme
if so this waste would need to be recorded for your calculations for yearly submission.


Regards

Mick M

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#5 Posted : 18 December 2007 10:12:00(UTC)
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Posted By Heather Collins
Whether you sell it or not it's still waste. This is often misunderstood when selling or giving away something for recycling. I always think of it this way - if the outlet you are selling/giving it away to didn't exist, would you have to dispose of the material as waste? If the answer is yes then it has to be considered as waste no matter what happens to it.

As to what documentation you need. First you need to be satisfied that the company taking it has either a waste management licence in place or a letter from the local Environment Agency office granting them a specific exemption from the Waste Management Licensing regime. In either case you must ensure it covers them to accept and store your particular waste material. The application regime for exemptions has been considerably simplified in the last 12 months so even if they don't have an exemption it might be worth encouraging them to apply (assuming they don't have a WML)

Secondly you must make sure that transfer notes are completed showing what waste you have given them. If it is the same waste every time you can complete an "annual transfer ticket" to cover multiple collections, although it would still be necessary to record the amounts every time.

We do something similar with waste rubber and it's not nearly as complicated as it sounds. Saves us a great deal of money on landfill charges and also helps to save the planet!
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#6 Posted : 18 December 2007 10:15:00(UTC)
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Posted By Heather Collins
By the way Mick - transit packaging originating from within the UK does NOT need to be counted when calculating your obligation under the Producer Responsibility Regs. So unless this is packaging round imported products you can ignore it for the purposes of the Regs.
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