London Wider Waste Strategy - London - Greater London Authority

6.17. Hazardous wastes may be transported directly from their point of production to the
point of disposal in a single journey. In these cases, the consignment notes provide an
accurate indication of hazardous waste arisings.
6.18. Alternatively, hazardous waste may be transported in multi-stage journeys from the
point of production to the point of disposal. This may be for a number of reasons such
as transport logistics, for intermediate bulking or sorting, and also for intermediate
treatment. Since each journey requires an additional consignment note, each additional
movement of the waste will result in double counting by the consignment note system.
6.19. Processing of hazardous waste may also result in data validity uncertainties under the
current consignment note system. Where hazardous wastes are processed on the site of
production, the waste data may not be recorded (refer para 6.19) and lead to underreporting.
Hazardous waste may cease to be defined as ‘hazardous’ after processing,
and will therefore no longer be recorded using the consignment note system. Where
the processing is carried out by a different company (or by the same company but on a
different site to the production site), then this hazardous waste will have already been
recorded through the consignment note system and the processing will not result in
double counting. Some double counting can also occur where the processing does not
result in the waste being re-classified as non-hazardous, but rather changes its physical
or chemical properties prior to disposal.
6.20. Hazardous waste managed at the site of production may include, for example, liquid and
sludge (generally referred to in terms of volume) from the manufacture of chemicals or
metals that is treated or disposed on site. Such treatment can reduce the volume and
change the properties of the waste. The result may be that wastes which would have
been designated as hazardous are no longer hazardous wastes, or that the volume of
waste to be designated as hazardous waste is reduced. Such wastes are excluded from
the data recorded on consignment notes of the arisings of hazardous waste, although
this data is recorded on a separate confidential database (refer para. 6.24). Other ways
in which the consignment note system may fail to capture all hazardous waste arisings
are noted in the following paragraphs.
6.21. The consignment note system may also fail to identify waste that is illegally handled.
For example, a company that transports its own waste to a point of treatment or
disposal where the receiver does not ask for a consignment note will not be included in
the consignment notification system. This may be due to ignorance of the regulations
or a decision to not follow the regulations. Either way, failure to notify means that
hazardous waste arisings are not recorded.
6.22. Fly-tipping is another way in which hazardous waste can fail to be defined at the point
of origin. However, the removal of fly-tipping is a statutory duty of local authorities
and therefore any hazardous waste in the fly-tipped material should be captured by the
notification system, albeit not at the point of production. Therefore from the
perspective of total tonnage of arisings, fly-tipping should not result in hazardous
wastes being excluded from the total arisings figures.
6.23. In summary, the consignment note system was designed to provide data for the
Environment Agency’s SWaT database about the movements and quantities of special
waste, under the Special Waste Regulations, 1996. However the system was not
designed to take account of the complexities arising from multi-stage movements and
the processing of hazardous wastes on the site of production, and any resulting volume
reduction or elimination. Hence the current system does not provide a completely
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