Having a problem with out wood skip and would love some insight into your views. Our part C has one company listed as the waste receiver but they have sub contracted this to another company. Should the sub contractor be named on the note? I have asked for this to be changed but as of yet they haven't. They are then taking the waste to a different end destination to which is stated on the note. They stated the recycling centre they are using takes some of the wood from them, so they use this site to save double handling. Are we/them compliant with the wood ending up at a different location to what is on the WTN?

You have a duty to be able to provide an audit trail should the Environment Agency / Local Authority wish to track the waste. (Not sure how long you are required to keep paperwork - think it is 2 years.) Unless you have the best memory in the world, in 23 months time you will not remember that this waste was taken by someone / somewhere that isn't listed on the WTN. Have you checked that the sub contractor holds the correct permits?

I always took the view that I need to see a copy of the transfer note between the contractor and his further subcontractor as this evidences a proper transfer of control of the material. I never accepted such subcontract arrangements with hazardous waste, the exception would be where there was a formal contractual agreement that permitted sight of all succeeding paperwork.

You have confirmed my thoughts. I have only been told about the issues with the wtn in last few days and awaiting a reply from the waste collection company. It's one of our other sites that has the issue and the admin and managers have been round the houses with it and finally passed it to me! If I can not see where our waste is ending up I am not compliant and can not Forfill our audit needs.