Paul Sanderson’s report:
I recently had a conversation with an official from the Environment Agency about what they consider best practice when it comes to paperwork and photos for PRN and PERN audits.
It is the view of the Agency that by following this best practice, it helps it to focus on catching illegitimate companies that are trying to illegally export and protects the integrity of the PRN/PERN system.
The reason behind the discussion I had with them was that a number of Members had said that they perceived an inconsistency between what the regulations said and what was being requested by Agency officers.
When it comes to photos of material, these are required for the audit process. While the guidance says that these ‘should’ be time and date stamped, this does not say that they ‘must’ be time and date stamped. This lack of clarity has led to some confusion.
Therefore, the Agency has suggested that they consider it recommended best practice for these to be time and date stamped.
Some have asked whether the data attached to the photo file can be used, but it is the view of the Agency that this data is easily manipulated. Instead, they suggest the use of apps to do this.
While these time and date stamps are not a requirement, it is a recommendation that companies do it.
However, if your company has said it will time and date stamp photos in your accreditation application, then you must do as this would be a breach of the application otherwise.
Officers from the Agency have also been briefed that this is the approach that will be taken.
When it comes to Waste Transfer Notes, there has also been some confusion over when these are required.
Waste Transfer Notes are used by the Agency to audit the provenance of the waste and assess if it is eligible packaging waste.
The Agency have said that where the waste arises at the waste producer’s site no Waste Transfer Note would be expected as no movement has taken place, for example waste from a distribution centre. If the same company transfers non-hazardous waste from one of their sites to another by their own waste carrier then again there is no requirement for a Waste Transfer Note. However, if the sites are a permitted or exempt waste facility, they must demonstrate that all waste accepted, regardless of the source, is within their tonnage and waste type conditions, so Waste Transfer Notes are recommended to evidence compliance.
If the waste is exported, then the supplier should, where relevant, provide to the exporter the Waste Transfer Notes from its supplier(s). For Article 18 waste movements the exporter should at audit provide completed Annex VIIs and the supplier’s Waste Transfer Notes. The Agency often requests other documentation, including weighbridge tickets, invoices etc. Please get in touch with me if you have any queries about this and I’d be happy to get clarification for you from the Agency.
