The HWR (SI 2005/894) were amended on 1 April 2016 by SI 2016/336. This changes affect the entire hazardous waste control system and mean more than just a saving of £18 per annum. It results in a more inconsistent approach across the UK and is perhaps a reminder of the implications of further devolution.
Producers of hazardous waste in England NO longer need to notify their premises to the Environment Agency. This requirement previously applied to sites in England and Wales producing more than 500kgs of hazardous waste in any 12-month period and required the use of a 6-digit alpha-numeric ‘premises’ code, forming the first part of a unique ‘consignment code’ on consignment notes.
Consignment note completion must change to accommodate the removal of the premises code. Businesses producing any amount of hazardous waste now need to use the first 6 letters or numbers of their business name, followed by a once-only used number. NB. Until 30 June, businesses can continue to use the old coding system if it had a valid premises code (or did not need one) on 31 March 2016.
For businesses names with <6 characters, they should assign the letter ‘Q’ to complete the remaining characters. There are separate letters to be added to some other waste types – see gov.uk for guidance.
In addition, the 2007 version of the Standard Industry Classification (SIC) code should now be used on consignment notes (replacing the 2003 version), just like it is for non-hazardous waste transfer notes. The use of ‘NACE’ codes are still allowed.
The regulations apply in England only. Wales will continue to use the premises code system via Natural Resources Wales, while Scotland and Northern Ireland continue to use their pre-notification system.
Waste received from Wales into England should use the premises code (issues via NRW). However, waste moving from England to Wales, Scotland or Northern Ireland should use the new format.
Chris Wilson Consulting is a specialist environmental and management system consultancy working with businesses and on projects to improve compliance performance, identify resource efficiencies and improve business credentials.
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Original Author: Chris Wilson at Chris Wilson Consulting
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