An End to Hazardous Waste Registration Requirements for Businesses
As of 1 April 2016, businesses who produce hazardous waste in England will no longer be required to register with the Environment Agency (EA) as hazardous waste producers, regardless of the amount of hazardous waste produced on their premises.
Following the UK Government’s “Better Regulation: Red Tape Challenge” – which aims to reduce operational costs and administration for businesses, in an effort to encourage growth – the need for businesses in England to register their premises that produce more than 500kg of hazardous waste per year, is to be rescinded (non-English premises must continue to register with their respective regulatory bodies). Although qualifying premises must continue to have a valid registration up until 1 April 2016.
These changes to hazardous waste regulation also affect the way that hazardous waste consignment notes are to be completed. Currently the first six characters of the unique consignment note code relate to a premises registration number. However, as of 1 April 2016 (England) businesses must ensure that the first six characters of the consignment note code are replaced with the first six letters or numbers of the business name, with the second set of characters continuing to be comprised of five letters and numbers of your choosing. Furthermore, it will no longer be acceptable to use “exempt” in the consignment note code. Businesses are legally still required to use the current format up until 1 March 2016 but must ensure that those completed after follow the new format.
It must be noted that these changes are only applicable to premises in England. Those wastes originating in Wales, Scotland, and Northern Ireland will continue to use the current consignment note coding format.
Another change to be implemented as a product of review is the use of Standard Industry Classification (SIC) codes on hazardous waste consignment notes. Currently, the EA accept SIC 2003, SIC 2007, and NACE (the industry standard classification system used in the European Union) on consignment notes. However, the change in Hazardous Waste Regulations from 1 April 2016, specifies that only SIC 2007 and NACE can be used.
You will need to ensure that your contractors are aware of these changes and that they are following the new system by 1 April 2016. As the landowner (and anyone operating on their behalf) has duty of care for wastes removed from their premises, it remains your legal responsibility to ensure that these changes are adhered to and recorded correctly throughout documentation.
If you require further guidance on the changes or would like to learn more about the range of environmental services provided by the S2 Partnership, please contact our specialist team – we’re happy to help.