6. Waste pre-acceptance, acceptance and tracking
Appropriate measures for waste pre-acceptance, acceptance and tracking.
The following measures apply to all processes and operations.
1. Wastes accepted at sites must be capable of biological treatment and be fully recovered and suitable for their intended end use.
2. A waste is only suitable for biological treatment if your treatment process is designed to:
- treat the types of wastes included on your environmental permit
- manage variability in feedstock and optimise process conditions
- make sure there is sufficient capacity to treat waste within the retention time of the process
3. You must implement waste pre-acceptance and acceptance procedures for all new waste streams so that you know enough about a waste (including its composition, characteristics and predicted age) before it arrives at your facility. You need to do this to assess and confirm the waste is technically and legally suitable for your facility.
4. You must document you waste pre-acceptance and acceptance procedures in your management system.
5. You must assess waste on initial acceptance and periodically to ensure constancy.
6. You must obtain representative test data and undertake upstream auditing of the production process to fully characterise the waste and identify the substances it contains.
7. You must not include wastes in the process solely for dilution.
8. You must have a system in place to track waste from receipt, handling on site and transfer off site.
9. You cannot accept waste containing animal by-products unless your facility has been validated following the regulations and approved by the Animal and Plant Health Agency (APHA). You must monitor your process in line with animal by-products regulations where required to do so.
1. You must use WM3 technical guidance on waste classification to be able to assign the correct waste classification code.
2. When you receive a customer enquiry and before the waste arrives at the facility, you must obtain the following in writing or in an electronic form:
- details of the waste producer including their organisation name, address and contact details
- the source and nature of the waste, at the point of production (the process that gives rise to the waste)
- a description of the waste including its physical form
- the full characteristics of the waste including the variability of each waste (for example, liquid effluents must be individually assessed and tested, understanding of the waste’s composition and characterisation must be based on representative samples)
- a description of any hazardous properties including potential risks to process safety, occupational safety and the environment
- the odour potential
- the type of packaging and risks of contamination
- an estimate of the quantity you expect to receive in each load and in a year
- the potential for self-heating, self-reactivity or reactivity to moisture or air
- the age of the waste
3. During pre-acceptance you must consider how you will manage and control the nutrient balance of the waste feedstock, the moisture and any toxic compounds which may inhibit biological activity.
4. You must verify the pre-acceptance information by contacting or visiting the producer. Dealing with staff directly involved in waste production can help to fully characterise a waste.
5. You must keep pre-acceptance records for at least 3 years (in a computerised waste tracking system) following receipt of the waste. If an enquiry does not lead to receipt of the waste, you do not need to keep records.
6. You must reassess the information you had at pre-acceptance yearly. You must also reassess information required at pre-acceptance if the:
- waste changes
- process giving rise to the waste changes
- waste received does not to conform to the pre-acceptance information
Before you accept waste you must consider its potential odour and emissions impact (description and intensity), for example:
- mercaptans, ammonia or other volatile organic compounds (VOCs)
- low molecular weight amines, for example, decaying fish or meat
- other high-nitrogen and odorous materials or chemicals, for example from highly decomposed food waste or poultry manure
You can only accept odorous wastes using special handling and storage arrangements such as in adequately covered or air contained and abated areas.
7. You must keep separate the roles and responsibilities of sales staff and technical staff. If sales staff are involved in waste enquiries then technical staff must carry out a final assessment before approval.
8. You must use this final technical check to make sure that you:
- only accept wastes that are suitable and permitted for the site
- avoid over accumulating waste
- have enough storage and treatment capacity
When you agree that you will accept waste from a customer, you must decide and record what parameters you will check at the acceptance stage. The checks could be visual (for example colour, phase, fuming), physical (for example pumpability, temperature, form) and chemical (for example pH, metals content) parameters.
9. You must also record the criteria for non-conformance or rejection.
10. You must make sure that your facility can comply with other regulatory requirements, for example the Animal By-Products Regulations.
11. You must advise your customers that they must avoid contaminating waste because it can cause handling difficulties and inhibit the biological treatment process. You must tell them what wastes are likely to contaminate your process.
12. You must not transfer waste unnecessarily between waste facilities.
13. You must obtain a representative sample or analysis, or analyse a representative sample of a waste, if:
- the chemical composition or variability of the waste is unclear from the information supplied by the customer
- there are doubts about whether the sample analysed is representative of the waste
- you will treat the waste at your facility (this will allow you to carry out tests to determine if the planned treatment will be safe and effective)
Where you rely on a customer sample you must record that you have done this and the reason why the customer sample is acceptable.
If the customer has a number of containers holding the same waste, you can apply the industry standard applying the square root of (N)+1 rule to sampling those containers.
For example: N = 28 containers +1 = √28 = 5.29 You would need to take 5 samples.
If the waste is variable, you must take a sample from each container.
You may not need a sample analysis at the pre-acceptance stage where the waste is:
- packaged food waste from food manufacturers or food retailers – however, you must have confirmation of its origin and enough information to understand how it will affect your biological treatment process
- biodegradable agricultural waste direct from the agricultural premises – however, you must have confirmation of its origin and enough information to understand how it will affect your biological treatment process
- green waste
- food waste and co-mingled green and food waste from local authority collections only
- a pure product chemical or where the chemical composition and hazardous properties are available in a REACH compliant safety data sheet, for example manufactured glycerol product
14. You must make sure that feedstock testing and testing frequency reflects the nature of the material, how it arises and any potential variation within it. For example, taking account of seasonal variations.
After fully characterising a waste, you must technically assess the waste’s suitability for treatment and storage to make sure you can meet your permit conditions and any other regulatory requirements. You must make sure that the waste complies with the site’s treatment capabilities and capacities.
Waste types for standard rules permits
The wastes listed on the biowaste treatment standard rules permits have already been characterised and risk assessed. The Environment Agency considers that they are generically suitable for the biological treatment process allowed by the permit. You must make sure that all the waste types you received match and comply with those wastes listed and described in the standard rules permits.
The biological treatment process must be capable of fully treating the waste feedstock received. For example, within the time-temperature conditions of your process, the biodegradation of any packaging and full recovery of the waste should take place.
1. You must fully assess and manage:
- any effects or inhibition on the biological treatment process and quality of the final waste or product – critical where you accept novel waste streams or multiple waste streams as it may prevent or delay associated landspreading deployments
- the effects of any potential carry-over of residual chemical components into the outputs and on using the final outputs
For novel or water based liquid waste, you may perform laboratory scale tests to predict the treatment’s performance, for example on breaking emulsion or biodegradability.
Personnel and waste acceptance
The following measures apply to all processes and operations.
Non-hazardous wastes
2. For non-hazardous wastes, someone with enough training to determine if the waste is suitable and permitted at the site can do the technical appraisal.
3. At sites where the waste needs only a visual check, for example green waste, the person receiving the waste must have received training to recognise and deal with non-conformant loads
Mirror entries and hazardous waste
4. If you accept hazardous, mirror-entry hazardous, or bespoke wastes, you must follow the requirements of Technical Guidance WM3 Waste Classification and the Chemical waste: appropriate measures for permitted facilities, in addition to this guidance.
If you are permitted to accept mirror entries or hazardous wastes, the person carrying out the technical appraisal of a waste’s suitability for receipt (at pre-acceptance) must be competent.
If you receive multiple hazardous wastes then the person carrying out the technical appraisal must have the minimum of an HNC in chemistry (or equivalent qualification). You must keep training records of qualifications or relevant experience of staff for all waste acceptance processes.
5. You must comply with our guidance on Chemical waste: appropriate measures for permitted facilities when receiving, handling, storing and treating hazardous waste.
The following measures apply to all processes and operations.
1. You must implement waste acceptance procedures to check the characteristics of the waste received matches the information you obtained during waste pre-acceptance. This is to confirm the waste is as expected and you can accept it, or that you must reject it.
Your procedures must follow a risk based approach, considering:
- the source and nature of the waste
- the variability of a waste (for example, liquid effluents) – you must carry out individual assessment and testing
- any hazardous properties the waste may have
- potential risks, process safety, occupational safety and the environment (for example from odour and other emissions)
- knowledge about the previous waste holder(s) and the age of the waste
- the waste’s potential for self-heating, self-reactivity or reactivity to moisture or air
2. You must identify the effects of any seasonal variance on the waste’s composition.
3. You must only receive bespoke waste onto site that you have pre booked and that matches the pre-acceptance information.
If you need to take samples on site, they must be representative of the waste and taken by a technically competent person. This means they must be appropriately trained or hold the relevant qualifications.
4. You must visually check wastes and verify them against pre-acceptance information and transfer documentation before you accept them on site. The extent of the initial visual check is determined by the waste type and how it is packaged.
5. You must check and validate all transfer documentation and resolve discrepancies before you accept the waste. If you believe the incoming waste classification and description is incorrect or incomplete, you must address this with the original waste producer during waste acceptance.
6. You must record any non-conformances.
If you have assessed the waste as acceptable for storage or treatment at your facility, you must document this.
7. You must have clear criteria that you use to identify non-conforming wastes and wastes to be rejected.
8. You must also have written procedures for recording, reporting and tracking non-conforming and rejected wastes. These must include:
- using quarantine storage
- notifying the relevant customer or waste producer
- recording a summary of your justification for accepting non-conforming waste in your electronic (or equivalent) system
9. You must take measures to prevent the recurrence of non-conforming and rejected wastes.
10. You must weigh and record each load of waste on arrival to confirm the quantities against the accompanying paperwork, unless there are other reliable systems (for example, based upon density and volume). You must record the weight in a system that enables tracking.
The person carrying out waste acceptance checks must be trained to effectively identify and manage any non-conformances in the loads received.
After the initial visual inspection and confirmatory checks, you must offload the waste into a dedicated reception or storage area to wait for detailed checks or sampling. Wastes that do not require further checking can go into the appropriate storage area.
11. You must not offload wastes if you do not have enough space and capacity to treat the waste at that time.
12. Tankered wastes must not be discharged to the head of a waste water treatment works when storm tanks are in operation as this may result in the waste discharging directly into the watercourse.
If you need to offload feedstock deliveries to inspect them, or carry out acceptance sampling before treatment, you must segregate the reception areas (typically into bays).
13. You must verify the waste is compliant as soon as possible.
14. If you use a bay every day you must clean it at least weekly. You must clean it more often (depending on the waste) if weekly cleans do not deal with the risk of vermin or fugitive emissions.
15. The waste reception area must be inside an enclosed building for the following:
- if receiving, storing or pre-treating (for example, de-packaging food waste) as the waste may lead to fugitive emissions
- for food waste
- for all waste containing animal by-products
A building is a covered structure, enclosed on all vertical sides, that is designed to provide sheltered cover and contain emissions of noise, particulate matter, odour and litter.
16. You must design enclosed buildings with an air extraction that is capable of negative pressure within the waste reception area and have air-lock controls. You must make sure the ventilation extraction and air treatment is suitably designed and engineered.
17. You must collect and treat all emissions in an appropriately engineered abatement system or air suction system close to the source. For in vessel systems, you can use exhaust air to aerate composting piles before treatment and discharge.
18. If you accept food and putrescible wastes, you must fit existing reception buildings with fast-acting roller shutter doors to allow delivery and other vehicles to enter and leave. You may need additional measures to minimise fugitive emissions, for example installing an airlock entry system.
19. You must design and maintain buildings used for feedstock reception and storage in a way that minimises fugitive emissions.
A reception building should have enough space to minimise the time waste is held before treatment, and to allow you to follow the first-in, first-out principle for waste treatment.
You should operate an alternate bay system or single bay all-in, all-out approach.
All bays used to segregate wastes must have defined and visibly clear storage demarcation boundaries.
Where there is a likelihood you will generate bioaerosols and dust you must treat the air with a dust filter before releasing emissions.
If you accept and store large volumes of ammonia-rich feedstock, for example poultry litter and manures, you must store it in a way that minimises the release of ammonia. You can do this by:
- covering it with a sheet or with an organic layer such as straw or compost to form a ‘biofilter’
- using a 3-sided walled area
You may need additional measures to reduce odour or ammonia if your site is located in sensitive areas.
20. You must design reception areas for easy cleaning and include contained drainage so you can collect wash-water separately for disposal or reuse.
21. If you are permitted to accept animal by-products you must:
- segregate these from other waste
- keep liquors and leachate separate and provide wheel-wash facilities for disinfecting delivery vehicles on exit from the reception building
You may need additional cleaning methods, for example steam cleaning. You must carry this out in an enclosed area.
22. You must characterise wash-down water containing cleaning chemicals, for example disinfectants, and dispose of them appropriately.
23. For outside reception areas, you must have impermeable surfacing and a contained drainage system.
24. You must minimise the time you store putrescible waste in reception before treatment and hold it for no longer than 5 working days. You must treat waste promptly and within 24 hours if there is risk of:
- attracting vermin
- causing fugitive emissions such as odour
You can store green waste and agricultural wastes for longer providing you follow all other appropriate measures to prevent uncontrolled decomposition and emissions.
You may store stable waste material for longer periods as long as it does not degrade and is stored in a way that does not encourage vermin or result in fugitive emissions.
Once offloaded, and as soon as is practicable to do so, you must assess the waste and verify it for acceptance, following your procedures.
25. You must put non-conforming containers and wastes into quarantine and deal with them immediately. You must record all non-conformances.
26. Where pallets are used to hold containers, you must stack them no more than 1.8m high (including the height of the pallet) and secure them with clear or transparent shrink-wrap.
The containers must not extend beyond (over-hang) the sides of the pallet. The shrink-wrap must be clear or transparent so that you can identify waste types, damaged containers, leaks or spillages and incorrectly stacked containers.
27. If you identify a non-conforming waste during a spot check, you must take measures to prevent a recurrence (including contacting the customer).
The following measures only apply to AD plants.
1. Operators of AD plants must characterise the feedstock to understand its effect on the biological treatment process.
This includes understanding, for example:
- particle size distribution and physical contaminants
- total solids and volatile solids
- biogas potential
- total organic carbon (TOC)
- chemical oxygen demand (COD)
- nutrient analysis
- fibre content
- pH and alkalinity
- volatile fatty acids (VFA)
- ammonia and total nitrogen content – carbon to nitrogen (C to N) ratio
- heavy metals and potentially toxic elements (PTEs)
- carbohydrates and lipids
Where the waste is from a known supplier and is consistent you can carry out these checks on initial acceptance and then periodically.
The following measures only apply to aerobic plants.
1. Operators of composting and aerobic treatment plants must characterise the feedstock to understand its effect on the biological treatment process. This includes understanding, for example:
- particle size distribution and physical contaminants
- total moisture
- TOC
- pH and alkalinity
- ammonia and nitrogen content (kjeldahl nitrogen)
- heavy metals and PTEs
The following measures apply to all processes and operations.
These measures cover assessing the suitability of accepting waste that is not listed in the standard rules permits or quality protocols.
The waste producer must follow the guidance document WM3 when characterising and classifying waste. Producers must fully characterise the waste to include all the chemical components so you can adequately assess whether the waste is suitable for biological treatment.
1. You must understand and be able to demonstrate what happens to the substances in the bespoke waste material when it undergoes biological treatment. You must demonstrate that these substances will completely degrade during the treatment process.
2. You must provide details of any pre-treatment or additional process control measures needed.
Treating non-standard or bespoke wastes must result in full mineralisation and stabilisation of the waste. Mineralisation is the advanced stage of decomposition where organic matter completely breaks down into available nutrients, water (H2O) and carbon dioxide (CO2).
Treating non-standard or bespoke wastes must also result in recovery of the waste or must benefit the biological treatment process itself.
3. For each bespoke waste type you must fully describe or demonstrate the:
- source and process that gives rise to the waste
- characteristics, including chemical, physical and biological make-up of the waste
- variability potential, considering source production methods
- biodegradability rate or biogas potential
- inhibition effects on the biological process
- residual by-products
- substances within the waste are biodegradable and recoverable under the conditions of the biological treatment process
4. Using the information in these bullet points (point 3), you must have a sampling and testing plan to demonstrate how you will make sure the waste is as described and remains suitable for treatment.
Sampling plans must meet the requirements of BS EN 14899:2005.
The testing plan must adequately reflect the waste and include the:
- objectives of the testing
- details of the testing needed
- test parameters based on chemical and physical characteristics
- the sampling approach including population, number of sampling events, number of samples, sample weight and reliability of the outcome
- sampling methodology
5. You must demonstrate the additional measures you will take if the waste is not within the suggested inhibition values. Guideline references are given in section 13 Bespoke waste assessment.
1. If you accept a waste load and only identify a non-conformance after the waste has been deposited, for example loose green waste with high levels of metal or plastic, you must remove and quarantine the contaminants.
You must address the non-conformance with the waste producer as part of your waste acceptance procedures and record these events. You should tell them the actions you have taken, for example, removed it for disposal.
2. You must remove packaging and non-biodegradable packaging items that are not independently certified as industrially or home compostable (or both). You must do this before and during treatment to minimise the contamination of outputs.
Non-packaging items include:
- non-biodegradable materials integral to the product, for example tea bags
- items used when consuming food or drink, for example straws, single-use tableware
- plastic bags, used for example, in a kitchen caddy, food bin liners, or garden waste sacks
You can accept industrially compostable packaging and non-packaging items that are independently certified as compliant with at least one of the following:
- EN 13432
- EN 14995
- ASTM D6400
You can accept home compostable packaging and non-packaging items that are independently certified as compliant with at least one of the following:
- EN 17427
- AS 5810-2010
- NF T51-800
- TUV Austria’s certification requirements for home compostable packaging under their ‘OK compost HOME’ scheme
3. You must only accept separated loads of plastic packaging and non-biodegradable packaging items (for example, from closed loop sources such as festivals, coffee shops or individual buildings) if both of these apply, the:
- packaging is independently certified as industrially or home compostable (or both)
- load complies with your permit acceptance criteria
1. You must only offload bulk loads (liquid, sludge or solid) after they have been fully verified. You must not accept a non compliant bulk load for interim storage except in an emergency.
Verification testing must include:
- checking consistency with the pre-acceptance information
- compatibility with the receiving vessel contents
- where appropriate, checking treatability by using laboratory scale simulation
Deliveries in a bulk road tanker must be accompanied by a ‘wash-out’ certificate or a declaration that previous loads do not pose a risk of cross contamination. This will not apply to dedicated tankers carrying only one type of waste.
2. You must take representative samples when sampling from:
- tankers of chemical production waste or hazardous waste
- new customers
- emergency deliveries
3. You must sample from each compartment if the tanker is divided into multiple compartments. If you have to take a sample from the back valve, you must avoid spillages.
When storing drummed waste, each drum must have a contents identification label.
Mixing wastes (by bulking, blending or repackaging)
4. You must take operational and design precautions when mixing or blending wastes, depending on their composition and consistency.
5. Mixing must have a clear and defined benefit to the process (for example, adjusting moisture content or solid fraction). You must only mix wastes together under controlled and safe conditions. You may need air handling, extraction and treatment.
6. You must complete a pre-acceptance and acceptance process that assesses the compatibility of wastes in the mixing process. You must not allow dangerous reactions to take place, for example those caused by:
- polymerisation
- gas evolution
- exothermic reaction
- decomposition
- crystallisation
- precipitation
7. You must understand the compatibility effects before:
- combining waste batches
- discharging from a tanker to bulk storage
- tank to tank transfer
- transfer from a container to a bulk tank
- bulking into drums or intermediate bulk containers
- bulking solid waste into drums or skips
If you do not clearly understand the compatibility effects, you must not blend or mix the waste until you can demonstrate compatibility.
Compatibility tests are risk based considering, for example:
- the hazardous properties of the waste
- the risks posed by the waste in terms of process safety
- occupational safety and environmental impact
- the knowledge of the previous waste holder(s)
8. You must prevent substances mixing if they react strongly with each other (causing heat, fire or gas formation). Mixing must not lead to increased risks to human health or the environment, either during the mixing operation itself or during the subsequent treatment process. Before wastes are combined, you must assess whether this combination can take place safely.
9. You must guarantee the traceability of wastes when mixing wastes.
10. You must only mix or blend waste in a dedicated area.
11. Mixing wastes must lead to the best possible level of waste management. For example, you must not mix:
- a waste which could be recovered with other wastes, meaning that the waste must now be sent for disposal or a lower form of recovery
- liquid wastes with other wastes for the purpose of landfilling
- waste to deliberately dilute it
12. When mixing wastes you must follow the joint Environment Agency and HSE Compatibility Testing Guidance for Bulking Operations in the Waste Treatment Industry.
Acceptance sampling
This does not apply to:
- green wastes
- food wastes and co-mingled food and green wastes from local authority collections
- food slurry that has been pre-treated and pre-pasteurised at separately permitted facilities
- biodegradable wastes from agriculture
- sewage sludge and septic tank sludge
13. You must still visually check the waste and carry out periodic audits of the waste against pre-acceptance and duty of care criteria. You must record the reason why you did not sample the waste in your waste tracking system.
14. You must representatively sample bulk or containerised waste (including from every container). You do not need to do this if the waste you receive has been representatively sampled and fully characterised during the pre-acceptance stage and you have verified the information as correct.
You can make a composite sample if each of the containers holds the same waste and you know the waste is not variable.
15. You must obtain a representative sample by taking a core sample down to the base of the container.
16. You must make sure that you replace lids, bungs and valves immediately after sampling.
17. You must have a sampling and analysis procedure. You must design it based on the risk factors for the waste, including:
- the type of waste (for example hazardous or non hazardous)
- knowledge of the customer (for example waste producer)
- the impact of potential mixing or blending and the possibilities for subsequent treatment
A representative sample is one that considers the full variation and any partitioning of the load so you can account for worst case scenarios.
Qualified staff must supervise on site sampling.
You must have suitable absorbents and spill kit material available to deal with any spills.
18. Where a driver arrives at the site with a sample taken from elsewhere, you must verify the sample as representative, reliable and obtained by a person technically competent to take it.
On site sampling may not be possible for health or safety reasons, for example, where you have previously taken a sample and there are specific risks regarding the waste handling.
Sampling must not increase the risk of incompatible substances coming into contact with one another, for example within a sump serving the sampling point, or because of contaminated sampling equipment.
19. Apart from packaged waste you must make sure that all waste is free from visual contaminants as far as practicable.
20. You must keep a record of the sampling regime, process, and justification in your waste tracking system.
Depending on the constancy, variability and confidence in the waste stream, you may need to keep samples on site after you have:
- treated a waste and removed its treatment residues from the facility
- transferred a waste from your site
21. You must customise sampling procedures for bulk liquids.
22. You must determine and record the following information:
- the sampling regime for each load, together with your justification for selecting each option
- a suitable location for the sampling points
- the capacity of the sampled vessel (for samples from drums, an additional parameter would be the total number of drums)
- the number of samples and degree of consolidation
- the operating conditions at the time of sampling
23. Wherever possible, you must sample waste in accordance with:
- EN 14899 Characterization of waste – Sampling of waste materials – Framework for the preparation and application of a sampling plan
- CEN/TR 15310 1 Characterization of waste – Waste Collection – Part 1: Guide on the selection and application of criteria for sampling under various conditions
- CEN/TR 15310 2 Characterization of waste – Waste Collection – Part 2: Guide on sampling techniques
- CEN/TR 15310 3 Characterization of waste – Waste Collection – Part 3: Guide on procedures for sub sampling in the field
- CEN/TR 15310 4 Characterization of waste – Waste Collection – Part 4: Guide to the packaging procedures for storage, conservation, transportation and delivery of samples
- CEN/TR 15310 5 Characterization of waste – Sampling of waste – Part 5: Guide on the process of developing a sampling plan
Testing and analysis
24. Where you sample a waste, you must test the waste for acceptance according to the parameters decided at pre-acceptance. You must record the results of the tests in the computerised waste tracking system. You must note and investigate any discrepancies.
Laboratory samples must be analysed by a UKAS approved laboratory.
Quarantining waste
25. Your facility must have a dedicated waste quarantine area.
Where there is a risk of fugitive emissions from quarantined waste you must store it in closed or covered containers or within a building or covered skip.
Your quarantine storage must be separate from all other storage and clearly marked as a quarantine area.
26. You must not keep quarantined waste longer than 5 working days.
27. You must have written procedures in place for dealing with wastes held in quarantine, together with a maximum storage volume. The maximum storage time must take account of the potential for odour generation, pest infestation and storage conditions such as temperature effects. If the waste is infested or odorous you must remove it as soon as possible and in any event within 24 hours.
28. The waste off-loading area, any sampling points, and quarantine areas, must have an impermeable surface with self contained drainage. This is to prevent any spillage entering the storage systems or escaping off site.
29. You must design all surfaces to allow effective cleaning.
The following measures apply to all processes and operations.
1. You must use a waste tracking system which records information about the available capacity of the waste quarantine, reception, general and bulk storage areas of your facility. Your information must include treatment residues and end of waste product materials.
Your tracking system must hold all the information produced during:
- pre-acceptance
- acceptance
- non-conformance or rejection
- storage
- repackaging
- treatment
- removal off site
This information must be in a readily accessible format. Where possible this should be computerised.
2. You must create records and update them to reflect deliveries, on site treatment and despatches. Your tracking system will operate as a waste inventory and stock control system. It must include this information as a minimum:
- the date the waste arrived on site
- the original producer’s details
- all previous holders
- a unique reference number
- the pre-acceptance and acceptance analysis results
- the package type and size
- the intended treatment or disposal route
- the nature and quantity of wastes held on site
- where the waste is physically located on site
- where the waste is in the designated disposal route
- staff (name and position) who have taken any decisions about accepting or rejecting waste streams and who have decided on recovery or disposal options
- details that link each waste container accepted to its consignment or transfer note
- non-conformances and rejections
The tracking system must be able to report:
- the total quantity of waste present on site at any one time and how that compares with the limits authorised by your permit
- the total quantity of end of waste product materials on site at any one time
- a breakdown of the waste quantities you are storing pending on-site treatment or waiting for onward transfer
- a breakdown of the waste quantities by hazardous property
- where a batch or load of waste is located based on the site plan
- the length of time a waste has been on site
3. You must store back up copies of computer records off site. Records must be easily accessed in an emergency.
4. You must hold acceptance records for a minimum of 2 years after you have treated the waste or removed it off site. You may have to keep some records for longer if they are required for other purposes, for example hazardous waste consignment notes.