Waste Tansfer Notes....'fingers crossed!'

[Dean Lofthouse]

"However, if you are working on a commercial site, for instance, AND the commercial manager instructs you to remove a tree then he would be deemed the 'originator' (producer) of the waste and a WTN would be deemed a requirement. Indeed this would definately be the case if you were transferring the waste to a third party site AND the third party should require this of you. However, however, if YOU advise the manager the tree needs to be removed, and therefore you are deemed the 'producer' of the waste AND you are transferring it to your own (again, registered exempt site)"

 

Thanks Paul, your efforts are much appreciated.

 

This however, is the bullshite bit.

 

It once again shouldn't matter who decides the tree should come down, who decides shouldn't be a deciding factor

 

If I chip the tree with my chipper and that chip is used, it isn't waste, only if the chip is sent to landfill should it be deemed "waste". It really isnt a hard concept to grasp

[Yorkshireman]

Ea When is it a waste & what isnt ,,,

EA waste timber.pdf

[AA Teccie (Paul)]

"However, if you are working on a commercial site, for instance, AND the commercial manager instructs you to remove a tree then he would be deemed the 'originator' (producer) of the waste and a WTN would be deemed a requirement. Indeed this would definately be the case if you were transferring the waste to a third party site AND the third party should require this of you. However, however, if YOU advise the manager the tree needs to be removed, and therefore you are deemed the 'producer' of the waste AND you are transferring it to your own (again, registered exempt site)"

 

Thanks Paul, your efforts are much appreciated.

 

This however, is the bullshite bit.

 

It once again shouldn't matter who decides the tree should come down, who decides shouldn't be a deciding factor

 

If I chip the tree with my chipper and that chip is used, it isn't waste, only if the chip is sent to landfill should it be deemed "waste". It really isnt a hard concept to grasp

 

Dean, in principle I entirely agree with you and sorry I don't mean to bullsh*t you (I guess this is directed at the EA tho!)

 

I'm offering a 'best interpretation' of the current position as advised by the EA. I fully understand your view that it's the 'use' and not the product that should determine whether it is waste or not BUT at this current time the product, or rather the 'producer' of the product, it is and it has 3 seperate waste category classifications on their 'Waste Catalogue'...how sad eh?!

 

As I say I don't have time currently to pursue this any further but I sincerely hope to revisit it at some later stage and hopefully with greater resources available to challenge it.

 

In the meantime however the AA advice will be for WC Licences and Para. 21 exemptions and of course this will be a requirement for 'ARB Approved Contractor' status.

 

Cheers..

Paul

 

PS As Yorkshire Man quite rightly advises (thank you) the EA have issued a position statement on this but it quite clearly states the 'Virgin Wood' exemption does not apply where greenery is included in the load...hmmm!

Edited November 10, 2010 by AA Teccie (Paul)

[Yorkshireman]

PS As Yorkshire Man quite rightly advises (thank you) the EA have issued a position statement on this but it quite clearly states the 'Virgin Wood' exemption does not apply where greenery is included in the load...hmmm!

 

Paul the wording isnt quite that restrictive the wording is (it does not include clippings or trimmings that consist primarily of foliage2)

 

 

rgds Iain

[Amelanchier]

Paul the wording isnt quite that restrictive the wording is (it does not include clippings or trimmings that consist primarily of foliage2)

 

 

rgds Iain

 

Problem is it then goes on to say; "... if virgin timber is mixed with waste timber or any other waste, the mixed load is classed as waste." So your load might contain chip/timber that does qualify as the elusive virgin timber but if there is any non virgin timber materal in the load (i.e., a leaf), the whole lot is waste.

 

Which is clearly mental, but hey.

[Amelanchier]

If its of any help/interest to anyone, Paul and I have cobbled a flowchart together with regard to Waste Transfer Notes (see attached). If I get a chance (perhaps if I stop faffing about on here!) I'll get one together for an overview of the whole WCL/WTN issue.

Arb Arisings and EA Requirements Flowchart v2.pdf