Guide
Clinical waste consignment notes and the records you must keep
Updated
The paperwork is the part inspectors look at, and the part practices most often get wrong. It is not complicated once you know which bits are yours.
What a consignment note is for
Hazardous waste cannot simply be handed over. A consignment note must be used to move it, and it stays with the waste until it reaches its final destination, so that every stage of the journey is documented and the receiving site can confirm what it got (gov.uk). Non-hazardous waste uses a waste transfer note instead.
Which parts you fill in
| Role | Parts to complete | Who this is in a practice |
|---|---|---|
| Producer | A and B | You, the practice generating the waste |
| Holder, stores waste | A and B | You, where waste is stored before collection |
| Carrier | C | The clinical waste company collecting from you |
| Consignor, hands waste to the carrier | D | Usually you, at the point of collection |
| Consignee, receives waste | E | The treatment or disposal site |
As producer or holder you keep one copy and give two copies to the carrier collecting your waste. You will need two codes: your Standard Industrial Classification (SIC) code from the 2007 list, which describes your business activity, and the waste classification code (also called the List of Waste or LoW code) that describes the waste itself. Your carrier can help you get these right the first time, and once they are set they rarely change.
The register you keep on site
Producers and holders must keep a register for 3 years at the premises that produced or stored the waste. The register is your copies of the consignment notes, the consignee returns you receive back from the sites that took your waste, and related documents such as carrier schedules and records of rejected loads. Where any of those documents are incomplete or inaccurate, gov.uk requires you to keep a record of what is missing (gov.uk).
The three failures that cause problems
- Consignee returns never filed. They come back after the collection, which is exactly why they get lost. Assign one person to file them against the matching note.
- Records kept at head office instead of the producing site. The requirement is that the register is held at the premises that produced or stored the waste. A multi-site group needs a copy at each site.
- Notes signed without being read. The description and codes on the note are your declaration about your waste. If a driver hands you a pre-filled note, check it describes what you are actually handing over.
What to expect from a good carrier
- Consignment notes supplied and pre-populated with your details and codes, for you to check and sign
- Consignee returns sent back to you promptly, in a form you can file
- An annual documentation pack you can hand to an inspector or a regulator without assembling it yourself
- A named contact who will answer a segregation or coding question without it becoming a chargeable consultation
Ask what documentation is included before you compare prices: see how carriers price collections. A cheaper quote that leaves you assembling the paperwork yourself is not cheaper, it is a different product.