Whose waste carrier licence do I need?

bradley1984

Registered
Hi all,

Looking for some advice as I progress on my 14001 auditor journey.

Im reviewing some documentation regarding waste disposal at one of the companys sites. The issue I have is waste carrier licences and waste transfer notes are held, but not always for the company actually collecting the waste.

For example, supplier A is contracted to collect waste (printer toners in a box). There is a WCL on file for that company. But they actually send a national courier company to collect it. Should my company be looking to record the courier as they were the ones who took receipt of the waste? And then should we further be looking to document the main supplier or not?

Waste transfer notes are held as evidence, which detail the 'Transfer Made By': courier and the receiver of the waste: supplier.

Before I go bonkers trying to understand what I thought would be pretty simple, can anyone offer any help as to what documented evidence should be kept for compliance / due diligence.

Thanks

Brad
 

geoffairey

Involved In Discussions
Your contract is with the Supplier, so you will need a copy of their Waste Carrier’s license and a copy of your contract with them or their terms and conditions (these may be on the back of the invoice). Make sure the WCL is at the correct level. You also should be aware that having a Copy of their WCL is not enough, it’s your company’s responsibility to ensure that the waste is disposed of responsibly.

if the Supplier sub contracts the work out, they should ensure that the courier has a waste carrier’s license, but there’s nothing to stop you asking the supplier to provide a copy of the courier’s license to ensure it’s in place.
 
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bradley1984

Registered
Your contract is with the Supplier, so you will need a copy of their Waste Carrier’s license and a copy of your contract with them or their terms and conditions (these may be on the back of the invoice). Make sure the WCL is at the correct level. You also should be aware that having a Copy of their WCL is not enough, it’s your company’s responsibility to ensure that the waste is disposed of responsibly.

if the Supplier sub contracts the work out, they should ensure that the courier has a waste carrier’s license, but there’s nothing to stop you asking the supplier to provide a copy of the courier’s license to ensure it’s in place.

Much appreciated for the feedback, have a great day.
 

geoffairey

Involved In Discussions
This is not true. From the Gov.uk website.

You must register if your business does any of the following:

transports waste (a carrier)
buys, sells or disposes of waste (a dealer)
arranges for someone else to buy, sell or dispose of waste (a broker)

Register or renew as a waste carrier, broker or dealer

so if you are a normal business and are engaging a 3rd party to dispose of your waste, you do NOT need a waste carrier’s license.
 

Randy

Super Moderator
You need to cut through everything else and get down to brass tacks, 99 times out of 100, regardless of waste, but especially for EPA listed RCRA waste you maintain legal responsibility for it even after it's buried in the ground (Cradle to Grave). For traceability a best practice would be the licenses or permits of everyone in the waste linkage chain but for practical use the EPA Hazardous Waste Manifest receipt that you hopefully are getting and storing contains necessary & relevant information.

Seeing as you're in the UK your #1 best bet would be to contact your regulator as to what you really need instead of people here many of whom are guessing at best
 

geoffairey

Involved In Discussions
@Randy I find that last sentence to be exceptionally rude as someone who’s researched this quite heavily to ensure compliance and provided a link to the Government’s guidance on the law.
 

Randy

Super Moderator
@Randy I find that last sentence to be exceptionally rude as someone who’s researched this quite heavily to ensure compliance and provided a link to the Government’s guidance on the law.
Rude to recommend seeking the true source of an answer as you recommended in your link? Fine I'm happy with that
 
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