Last week the Environment Agency (EA) relaxed the rules around signatures on waste paperwork until 30 June 2020. It fits with social distancing requirements and it is up to you if you use the relaxed requirements.
Under normal circumstances a Waste Transfer or Consignment Note must accompany each collection of waste from site, either via an annual note that covers each collection during the year, or when the contractor arrives on site you normally sign and hand over paper copies in person each time.
The EA’s new COVID-19 Regulatory Position Statement (RPS) states you do not have to sign and hand over paper copies of waste transfer and consignment notes in person at the time of the collection. Instead you must exchange with the waste contractor all the information and data normally provided in the note (i.e. in Parts A – D) either before the collection of the waste or at the time of the collection. So, for example, you and the waste contractor can exchange all the information electronically on email before the collection so that they can pre-fill the note, or if they can complete the note at the time of collection electronically, and send you an instant copy, that is also acceptable. Instead of having a signature in the box from you (at Part D), you need to provide a full name, date of birth and contact number for the contractor to complete this section on your behalf with no signature. You do not need to physically exchange the paper note at the time of collection, but a completed copy must be sent to site no later than 10 calendar days after the waste transfer has taken place so that you have a completed copy for compliance.
The key compliance requirement is that you must exchange all the information for Parts A-D before the collection or at the time of collection – but not later i.e. the contractor can’t just come and collect the waste and complete the paperwork afterwards.
If you have any queries, please get in touch. I suspect waste paperwork exchanged during this time will be checked at ISO 14001 visits!
Stay Safe, Helen (firstname.lastname@example.org)