Most farmers, agribusinesses, and AD plants will produce some sort of waste that will require processing or disposal at a waste management facility or landfill site throughout the year, such as round bale plastic, fertilizer bags, containers, and packaging.
All businesses have a duty of care to ensure that their waste is handled by registered waste carriers and disposed of at licensed waste management facilities.
The creation and retention of a waste transfer note for wastes transferred from the business is a critical part of the business’s waste management responsibilities.
Our free online waste transfer note generator is available here >
In this blog post, we will discuss what they are, the key legislative requirements, and how to write a waste transfer note.
What is a Waste Transfer Note?
A duty of care waste transfer note is a legal document that confirms the transfer of non-hazardous waste between 3 different parties.
- The current holder/producer of the waste (Transferor).
- The waste carrier (Transferee).
- The disposal/destination point (Transfer).
The waste transfer note will create a full audit trail between the transferor, transferee, and the transfer point.
It is a legal requirement for all persons to retain proof of all waste transfer notes for at least 2 years. If requested, you may need to provide WTNs to regulatory government bodies or to certification/auditors.
Waste transfer notes cannot be written for the transfer of hazardous waste types which usually concern anything that is chemical, biological, clinical, or electronic (WEEE) in waste type. These types of wastes require a Hazardous Waste Consignment Note.
Do I need a Waste Transfer Note?
Yes, a duty of care waste Transfer Note is a legal requirement for any business that transfers non-hazardous waste from their premises.
A WTN proves your duty of care as a business owner that you’re legally disposing of your waste and monitoring the environmental impact of your business.
Who Issues the Waste Transfer Note?
If you employ a waste management company, they usually will take care of the WTN on your behalf i.e., A skip company will generally provide you with a WTN on collection of a skip at your business premises.
However, whichever company is collecting or receiving your waste, it is still your responsibility to ensure that a WTN was issued and that you receive a copy of the waste transfer note.
Who can Carry the Waste (Transferee)?
Only registered waste carriers can legally carry and transfer waste. It is your duty of care to ensure that all persons collecting or carrying your waste are holders of a valid waste carrier’s license.
How to Write a Waste Transfer Note –
There isn’t one format for producing a Waste Transfer Note, many companies have their own branded WTN format, but the government’s official ‘Duty of Care: Waste Transfer Note‘ is commonly used to guarantee compliance.
As long as the document displays all the relevant details to ensure a clear audit trail, you will be compliant.
What Should the Waste Transfer Note Contain?
A waste transfer note can either be in a physical or digital form. Most waste management companies will use triplicate booklets as an easy way of managing WTN copies i.e., one held for the waste producer, one held for the waste carrier, and one held for the transfer point.
However, more companies are moving towards digital WTNs to reduce their environmental impact by reducing their paper usage.
There is no standard format of a waste transfer note but as long as the required information is included and it is clear to understand the steps of the waste transfer then you will be compliant.
A Waste Transfer Note must include:
- A description of the waste being transferred
- The quantity of the waste
- How the waste is contained or packaged
- The name of the current holder/producer of the waste (Transferor)
- The EWC (European Waste Catalogue) code for your waste
- The SIC (Standard Industry Code) of your business
- The place and date of the waste transfer
- The name of the person/organization carrying the waste (Transferee)
- Details of the waste transfer destination point including name, address, and environmental permit/license number.
A section is required that states that the waste hierarchy has been applied. The waste hierarchy is to ensure that wastes are being transferred to the most suitable waste management facility i.e., waste plastic that could be recycled should not be transferred to a landfill site for burial.
Who Needs to Sign the Waste Transfer Note?
A WTN must be signed by the parties involved-
- The waste producer / current holder of the waste
- The waste carrier (transferee)
- The Disposal Site (Transfer)
Oftentimes, the transferee/waste carrier will be the waste management company responsible for its disposal (transfer point) and thus only 2 signatures are required.
If you employ a company for haulage only of your waste to a waste management facility, then you must ensure that you receive a copy of the WTN with the transfer points’ signature. This is to ensure that the waste is received and validated by the final destination waste management facility.
All these records must be dated, signed, and retained on file.
How Long Do I Need to Keep Waste Transfer Notes?
All parties must legally retain waste transfer notes for at least 2 years. This is to ensure that there is a clear audit trail from the producer of the waste, the waste carrier, and the final destination transfer site.
A Working Example of a Waste Transfer Note –
We like to give working examples of all documentation so that you can get a feel for what a real-life working document looks like.
This duty of care waste transfer note has been filled out with all the required information for a dummy waste transfer of animal manure between ourselves at AR Enviro and Joe Bloggs Energy.
This is a WTN template that we personally use ourselves. But please note that this WTN references the waste management regulations in Northern Ireland.
What are the Different Waste Transfer Note Regulations?
England & Wales is regulated by The Environmental Protection Act 1990 and the Waste (England and Wales) Regulations 2011.
Applying the waste hierarchy is required as per Regulation 12 of the Waste (England and Wales) Regulations 2011.
Scotland is regulated by The Environmental Protection Act 1990 (Duty of Care) Regulations 1991, as amended by the Waste (Scotland) Regulations 2012.
In Scotland, the Waste Hierarchy regulations are set out in the Waste (Scotland) Regulations 2012.
Northern Ireland is regulated by The Waste and Contaminated Land (Northern Ireland) Order 1997 and the Duty of Care (NI) Regulations 2002.
Applying the waste hierarchy is required as per Regulation 17 of the Waste Hierarchy Regulations (Northern Ireland) 2011.
What is a Waste Transfer Season Ticket and When Can it be Used?
A waste transfer season ticket can be used instead of individual waste transfer notes for repetitive transfers of the same waste types from the same waste producer, by the same waste carrier to the same waste management facility.
A waste transfer season ticket covers all waste transfers between the parties for a 12-month period in one document instead of multiple individual waste transfer notes. A log must be kept of all waste transfers between the parties ie., weighbridge dockets.
A waste transfer season ticket must contain all the same information as required for an individual waste transfer note but can be used for multiple transfers.
Waste season tickets are only valid for a 12-month period and must be renewed by all parties after this period.
Our Working Example of a Waste Season Ticket –
This duty of care waste transfer season ticket has been filled out with all the required information for a dummy waste transfer of animal manure between ourselves at AR Enviro and Joe Bloggs Energy.
This is a Waste Transfer Season Ticket template that we personally use ourselves. But please note that this Waste Season Ticket references the waste management regulations in Northern Ireland.
What are the Waste Hierarchy Regulations and Requirements?
Responsible waste management is more than just about getting rid of waste, it is also about finding ways to reuse and recycle materials, and even recover energy from them.
The aim of waste hierarchy regulations is to reduce the amount of waste that goes to landfill, which is the least preferred option for waste disposal. Therefore, it is important to consider all other options before resorting to landfill.
The Waste Hierarchy prioritizes waste management options in the following order:
- Prevention: taking measures to prevent waste generation at the source
- Preparation for reuse: preparing waste for reuse by others
- Recycling: recycling waste into new products
- Other recovery: using waste to produce energy or fuel
- Disposal: disposing of waste to landfill or incineration
Waste producers should first look at ways to prevent waste from being generated in the first place. If waste cannot be prevented, it should be considered for reuse, recycling, or recovery before disposal. By following this hierarchy, businesses can reduce the amount of waste that ends up in landfills and make better use of valuable resources.
Our free online waste transfer note generator is available here >