If you transport any kind of waste regularly, as part of your business, then you need to register as a lower tier waste carrier; for pest controllers this includes spent rodenticide bait, aerosol cans, empty packaging, redundant stock and florescent tubes. All of these waste products should be disposed of at a suitably licensed waste transfer station or other disposal site.
Pest controllers have a legal duty of care to check that any transfer station or other waste disposal site, which they may use, have the proper licenses in place. These may include;
- An environmental permit
- A waste exemption certificate
- A hazardous waste producer registration
In addition the activity must be under the control of a person holding a current WAMITAB (Waste Management Industry Training and Advisory Board) continuing competence certificate.
Registration as a lower tier carrier is free of charge if you are just transporting your own organisation’s waste. If you do not register you could be fined up to £5,000. Registration lasts indefinitely and your name will appear on the public register of waste carriers. The Environment Agency has now put in place a simplified form to allow companies to register as waste carriers in England and Wales and can be found here: https://www.gov.uk/waste-carrier-or-broker-registration.
You must complete consignee returns every three months (quarter), to the Environment Agency reporting what hazardous waste has been received at your premises.
You must provide a return, reporting your activities for each quarter, within one month at the end of that quarter:
Quarter 1 – 1 January to 31 March – provide by 30 April
Quarter 2 – 1 April to 30 June – provide by 31 July
Quarter 3 – 1 July to 30 September – provide by 31 October
Quarter 4 – 1 October to 31 December – provide by 31 January
It is recommended that you keep records of your returns for six years.
For more information on consignment notes and how to complete the forms go to: http://www.environment-agency.gov.uk/business/topics/waste/32194.aspx
Regulatory Position Statement
A “Regulatory Position Statement” was issued by the Environment Agency in January 2014 (MWRP RPS 135 Version 3) allowing certain relaxation of reporting requirements for specified hazardous wastes. Spent rodenticide bait and other articles fall in to this derogation and it allows for a reduction in the charge imposed by the Environment Agency on the returns. See the position statement for further details.
A consignment note must be completed to accompany hazardous waste when moved from any premises. Consignment notes should be kept for a period of three years.
Step-by-step advice on how to complete each section of the consignment note for standard and multiple collections can be found here: http://www.environment-agency.gov.uk/business/topics/waste/32196.aspx