RECORDKEEPING > Details

Duty of Care / Hazardous Wastes

Not only do you have a duty to dispose of waste in a correct and legal manner, you should also have documentary evidence of how and whom disposed of the wastes for your institution. The Environment Agency Netregs covers the basic principles of Waste Transfer Notes (WTNs).

What is a Waste Transfer Note (WTN)?

A Waste Transfer Note (WTN) is a document which must be completed and accompany any transfer of waste between different holders.

A WTN must be created for each load of waste that leaves your site. For repetitive transfers, there is provision to use a 'season ticket’ i.e. one transfer note will cover multiple transfers over a given period of time of up to 12 months. The use of a season ticket is, however, only permissible where the parties involved in each transfer are the same and where the description of the waste transferred remains the same.

What information should it contain?

The WTN must contain enough information about the waste to enable anyone coming into contact with it to handle it safely and either dispose of it or allow it to be recovered within the law. Failure to give enough information may result in prosecution.

You should describe on the WTN both in words and by reference to the appropriate codes in the European Waste Catalogue (EWC) and the quantity and types of each different waste being transferred. The requirement was introduced in England, Wales and Scotland by the respective Landfill Regulations.

If you are operating in Northern Ireland, you currently need to describe the quantity and types of each different waste being transferred both in words and by reference to the appropriate category (chapter heading) of the EWC. This is a requirement of the Controlled Waste (Duty of Care) Regulations (Northern Ireland) 2002.


The WTN should also include details of how the waste is contained i.e. loose or packaged and, if packaged, then in what type of containers.

Never rely on waste carriers or waste management contractors to describe your waste for you on WTN’s. You, as the producer, are in the best position to accurately describe your waste. Ensure that description of the waste on documentation is accurate – ideally write the description yourself. Non-specific terms such as 'general waste' or 'inert waste' are not acceptable. The purpose of the description is to allow other people who handle the waste to know what they are dealing with so that they can manage it safely and properly.

Both parties to the transfer must sign the transfer note e.g. you and the waste carrier must sign the WTN before the waste leaves your site. If you transport the waste yourself, you and the operator of the waste management site to whom you hand over your waste must sign the transfer note. If you use a waste broker, you must ensure that they are registered with your Environmental Regulator and that they also sign the WTN in their own right. This is your record of the nature and quantity of waste you transferred, how it was packaged, when you transferred it, where it should go and who you transferred it to – all requirements of the Duty of Care.

You must keep copies of all WTN’s for at least two years.

Whatever the destination of your business wastes and whichever organisations are handling them, it will help you to prove that you have properly discharged your Duty of Care if you undertake periodic audits. This will help you to ensure that your wastes are being handled correctly from the moment they leave your premises to the final point of disposal or recovery.

WTN’s and Hazardous Waste

The transfer documentation for Hazardous Waste is referred to as a ‘consignment note.’ If the material you are handling has hazardous properties, it may need to be dealt with as Hazardous Waste. In this case, completion of a Consignment Note (requiring similar information to a WTN) will fulfil the Duty of Care requirements; a separate waste transfer note is then not required.

Be aware that waste defined by the EWC as hazardous (i.e. those where the description matches an entry with an asterisk) can only go to a waste treatment facility that is licensed to receive hazardous waste.

Ensure that wastes that arise irregularly (e.g. redundant materials, wastes arising from cleaning up spills) are declared on WTNs. Note that some of these wastes may have to be handled as hazardous waste.