Waste Transfer & Documentation

Practice staff should be trained in the correct completion of waste documentation as any incorrect information could leave the practice legally liable.

Waste Transfer and Documentation

As the producer of the waste, the legal responsibility for ensuring that the documentation is complete and accurate sits with the dental practice.

Practice staff should be trained in the correct completion of waste documentation as any incorrect information could leave the practice legally liable.

The documentation provided to a dental practice by the contractor is commonly referred to as consignment notes or waste transfer notes.

It is important to know that these are two different documents, both of which will potentially be required at some point during dental practice waste disposal.

Consignment Notes

Consignment notes are provided more regularly to dental practices as this is used for hazardous waste.

Consignment notes should have three copies for:

  • The waste producer
  • The waste carrier
  • The waste consignee

The consignment notes are used to track movements and ensure that the accompanying information is adequate enough to ensure safe disposal hazardous waste.

There must be a new consignment note for each individual collection of hazardous waste.

Completion of Consignment Notes

HTM 07-01 provides an example of a consignment note which is shown and explained below:


Part A

It is standard practice for waste providers to have pre-populated consignment notes whereby the dental practice details and destination of waste are already completed.

Part A details include:

  • Practice details
  • Premises code
  • Destination of waste
PART A Registration Details  

1. Consignment Note Code: 123ABC/001AB

2. The waste described below is to be removed from (name, address, postcode, telephone, e-mail and fax):

Example Dental Practice, A Street, A Town, A County, S62 6NU

Tel 01709 525256, email_address

3. Premises Code: 123ABC

4. The waste will be taken to (address and postcode):

Example Waste Company, A Street, A Town, A County, S62 6NU

5. The waste producer was (if different from 1.) (name, address, postcode, telephone, e-mail and fax)


Part B and C

The waste contractor normally completes these sections by filling in what waste is being removed (the number of orange bags for example) and signing in behalf of the carrier.

Part B details include:

  • Waste being removed from the practice for disposal: Quantities need to be checked (verify the number of orange bags collected for example)
PART B Description of Waste          

1. The process giving rise to the waste(s) was: Dental Healthcare. 2. SIC for the process giving rise to the waste: 85.

3. WASTE DETAILS (where more than one waste type is collected all of the information given below must be completed for each EWC identified).

Description of Waste   EWC Code QTY (Kg) The chemical/biological components of the waste, their concentrations   Physical Form Hazard Code Container type, number & size 

Clinical waste: mixed sharps and pharmaceutical waste for incineration only

180103

180109

10 Kg

Sharps, syringe barrels, medicine vials and ampoules (not cytotoxic and cytostatic)

Mixed

H3, H4, H5, H9, H14

2 × 14 litre yellow lidded sharps receptacle

Clinical waste: infectious, suitable for alternative treatment

180103

20 Kg

Dressings, PPE and swabs, not contaminated with chemicals or medicines

Mixed

H9

4 x orange bags

Dental amalgam: infectious, clinical waste, for recovery

180110

0.5 Kg

Teeth with amalgam fillings (mercury)

Solid

H6, H9, H14

1 x amalgam pot 500 ml

Dental amalgam and mercury: non-infectious, for recovery

180110

0.5 Kg

Dental amalgam and mercury – spent and out-of-date capsules, excess mixed amalgam, and contents of amalgam separators

Mixed

H6, H14

1 x amalgam pot 1 litre

X-ray fixer solution

090101

10 Kg

Acetic acid 1–5%

Silver 1–2%

Liquid

H4

1 x 15 litre drum

X-ray developer solution

090101

10 Kg

Hydroquinone 5–10%

Diethylene Glycol 1–5%

Sodium Carbonate 1–5%

Liquid

H4, H7, H11

1 x 15 litre drum

ADR information for each EWC identified above:          

EWC Code

 

Description for carriage

Special handling requirements

180103

 

UN 3291 Clinical waste, unspecified, n.o.s 6.2 II

No persons in handling chain to have direct contact. Waste to be disposed of at authorised site

Etc.

 

Etc.

Etc.

Part C details include:

  • Contractor’s declaration
  • Drivers name
  • Vehicle details
PART C Carrier's Certificate

(If more than one carrier is used, please attach a schedule for subsequent carriers. If a schedule of carriers is attached tick here) [  ]

I certify that I today collected the consignment and that the details in A2, A4 and B3 are correct & have been advised of any specific handling requirements:

1. Carrier driver name (please PRINT) __________________

2. On behalf of:

(name, address, postcode, telephone, e-mail and fax)

Example Dental Practice, A Street, A Town, A County, S62 6NU

Tel 01709 525256, email_address

3. Carrier’s registration no/exemption reason: 012345/ABCD

4. Vehicle registration no: AB10 WAS

Signature __________________

Time: 17.00 Date: 27/09/2030


Part D

This is the consignors (the Practice’s) declaration that information on the consignment note is accurate and correct

  • Part D MUST be completed by a member of staff from the practice. 
PART D Consignor's/Holders Certificate

I certify that the information in A, B and C above is correct, that the carrier is registered or exempt and was advised of the appropriate precautionary measures. All of the waste is packaged and labelled correctly and the carrier has been advised of any special handling requirements.

1. Consignor/Holder name (please PRINT) __________________

2. On behalf of:

(name, address, postcode, telephone, e-mail and fax)

Example Dental Practice, A Street, A Town, A County, S62 6NU

Tel 01709 525256, email_address

Signature __________________

Time: 17.00 Date: 27/09/2030


Part E

This section is completed by the destination site when they verify what they have received.

PART E Consignee’s Certificate (where more than one waste type is collected, all of the information given below must be completed for each EWC)

Individual EWC code(s) received

Quantity of each EWC code received (kg)

EWC code accepted/rejected Waste Management operation
(R or D code)
       
       

I received this waste at the address given in A4 on:

Vehicle registration no (or mode of transport if not by road):

_________________________________________

Where waste is rejected please provide details:

_________________________________________

I certify that the waste management licence/permit/authorised exemption no(s).

_________________________________________

authorises the management of the waste described in B at the address given at A4

Name: (please PRINT)

 

On behalf of (name, address, postcode, tel, e-mail

& fax):

 

Signature: __________________________________

 

Date: _____________ Time: _____________ 


 

Waste transfer notes

Waste transfer notes are used for the collection of non hazardous waste, for example X-ray lead foils and general waste.

The legal responsibility for describing the waste lies with the dental practice, however this is likely to be pre-populated by the waste contractor

Waste from Domiciliary Visits and Other Practices

Where waste has been created at a domiciliary visit, it is acceptable for this to be brought back to the dental practice without requiring documentation. There is an exemption granted for temporary storage by the producer.

Dentists may move non-hazardous waste between their practices under the same exemption.

If Hazardous waste is moved then the practice must use a consignment note. This makes the receiving practice the receiver or the consignee, and this carries significant legal obligations.

Registering as a Hazardous Waste Provider

In England and Wales, if the total amount of hazardous waste produced in a 12 month period exceeds 500kg then the practice needs to register their premises annually.

If the amount is less than 500kg in a 12 month period registration exemption is granted. Many dental practices will require registration although smaller practices may be exempt. This does not mean exemption from using consignment notes.

Commonly, waste management contractors may register dental practices on their behalf. When practices are registered a ‘premises code’ (Hazardous waste producer registration number) is given which will be used on al consignment notes. Renewal of registration with the Environment Agency is required annually.

Hazardous Waste Records

Dental practices are required to keep hazardous waste records:

  • Consignment notes- Waste producers copy
  • Consignee returns to the producer or holder.

This is known as the register and these documents should be retained for 3 years.

Each waste receiver (consignee) is required to send a quarterly return to the dental practice.

Dental practices need to ensure these returns are received as it is a record of what has happened to the waste. It is a requirement to have this in the register and the register will not be legally compliant without it.

Returns can be provided in 2 ways:

  • A form created from the regulations, listing individual waste movement, their nature and what has happened to them.
  • A copy of consignment notes plus a description or confirmation of the disposal and/or recovery of waste: Essentially it is a consignment note with parts A-E completed.

If waste was taken to a ‘transfer station’, documentation of its removal and transportation to its final destination should be included.

Waste providers should produce returns every quarter as standard as this is a legal requirement.

Requests can be made in writing, however if unsuccessful practices should seriously consider ceasing the use of the contractor until compliance is achieved.

 Waste transfer notes are required to be kept for 2 years.