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Social distancing when signing and handing over waste transfer and consignment notes in person: RPS C8

Andrew Lake

15 Dec 2021

Compliance

As more robust COVID restrictions are being re-introduced to every day life, we see the return to social distancing, mask wearing and the impact this has on the waste sector with the exchange of transfer and consignment notes. If you have an electronic system in place the impact of social distancing is already less on you.

If however, you do not then you should be aware of the Regulatory Position Statement (RPS) the Environment Agency (EA) will allow you to operate under RPS C8.

This position statement does not however alter your legal obligations under ‘Duty of Care’ If you follow the conditions set out in RPS C8 the EA will not normally take enforcement action.

This RPS only applies when you use:

• paper copies of waste transfer notes
• paper consignment notes
• an electronic system that requires a digital signature on a handset

and applies when:

• hand over waste to others
• receive waste from others

If you follow the conditions in this RPS, the EA will not normally take enforcement action if you do not carry out the following, in person, when you transfer the waste:

• sign or hand over paper copies of waste transfer notes
• sign or hand over paper copies of consignment notes
• get a digital signature on a handset

There are 6 conditions to this RPS that need to be complied with see RPS: https://www.gov.uk/government/publications/social-distancing-when-signing-and-handing-over-waste-transfer-and-consignment-notes-in-person-rps-c8/social-distancing-when-signing-and-handing-over-waste-transfer-and-consignment-notes-in-person-rps-c8

Our top tip here at Umbrella Environmental is to ensure you comply with this RPS your activity meets the description set out in the RPS, you comply with the conditions set out in the RPS and that your activity does not, and is not likely to, cause environmental pollution or harm human health.

If you are unsure or need further compliance advice please don’t hesitate to contact us here at Umbrella Environmental on 07498 671 713 or Andrew@umbrellaenvironmental.co.uk

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