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Defra removes WTN requirement despite opposition

Defra has removed the requirement for recording information on waste transfer notes (WTNs) despite opposition to the proposal, the Government’s response to consultation on the matter has revealed.

Since the Waste (England and Wales) (Amendment) Regulations 2014 came into effect in April, businesses can provide information on transferred waste on documentation other than the traditional WTNs. This might include invoices, orders and receipts.

Defra had asked for feedback on the proposal at the end of last year as part of the Government’s Red Tape Challenge.

The official response to the consultation is yet to be published but a copy of the document obtained by Phil Conran, director at consultancy 360 Environmental, indicates that 40 out of 66 respondents were not in favour of the proposal.

Concern was expressed that allowing alternative recording options could increase non-compliance, make it more difficult for regulators to check transfers, and discourage the adoption of the newly launched electronic duty of care reporting system ‘edoc’.

Defra acknowledged these concerns but went ahead with the proposal, saying the information requirements would remain the same as on a WTN, that businesses would have to retain that information for two years and make it available to the regulator on request.

Defra expects 80% of businesses to move to edoc, so the proposal for alternative documentation would provide greater flexibility only for a minority wanting to continue with a paper-based system.

Sam Corp, head of regulation at the Environmental Services Association, said that the organisation was not in favour of removing the requirements of WTNs, as it considered them useful tools for waste tracking, crime prevention and data collection.

“However, we do question whether the amendment in the regulations will actually make any difference in real terms,” he added. “WTNs and, in particular, their electronic successor via edoc are in fact a very simple and efficient way of capturing information required to satisfy Duty of Care legislation and it is likely that most waste producers will continue to utilise them.”

“The ‘greater flexibility’ required by the Red Tape Challenge will be provided by the edoc system and the Government should encourage all appropriate businesses to utilise it.”

Claire Poole, education and training manager at the Chartered Institution of Wastes Management, said the new regulations simply clarify requirements on waste transfers.

“There has never been a prescribed format for the information required for a waste transfer,” she said. “WTN was a suggested template but not mandatory. Therefore it could always be recorded in different ways, for example on other documents such as weighbridge tickets.

“In this respect, the new legislation simply makes the requirements clearer and more business friendly and ties in with the launch of edoc as an alternative recording method.”

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