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Waste Management Policy

This policy outlines our approach to waste management in compliance with the Separation of Waste (England) Regulations 2025. We are committed to reducing waste, improving recycling efforts, and ensuring legal compliance.

Definition of waste

Waste includes any material that is discarded, whether intended for disposal, recovery, or recycling. This includes but is not limited to packaging, paper, construction debris, electrical equipment, and trade effluent.

Waste hierarchy compliance

In accordance with Regulation 12 of the Waste (England and Wales) Regulations 2011, we prioritise waste prevention, followed by preparation for reuse, recycling, recovery, and disposal as a last resort.

Most favoured option to least favoured option:

  1. Reduce – lowering the amount of waste produced
  2. Reuse – using materials repeatedly
  3. Recycle – using materials to make new products
  4. Recovery – recovering energy from waste
  5. Landfill – safe disposal of waste to landfill

Separation of waste requirements

Under the Separation of Waste (England) Regulations 2025, the following materials must be separated at the point of disposal:

  • Paper & Cardboard
  • Glass
  • Metal & Plastic
  • Food Waste (from commercial operations producing over 5kg per week)

These waste streams must not be mixed and should be collected separately to facilitate effective recycling and recovery.

Duty of care for waste

We have a legal obligation to:

  • Handle and store waste safely in designated, labelled containers.
  • Prevent contamination by keeping separated waste streams distinct.
  • Maintain waste transfer notes and separation compliance records for at least three years.
  • Use only licensed waste carriers for transportation and disposal.

Storage and collection of separated waste

  • Waste must be stored in clearly labelled and designated bins to prevent cross-contamination.
  • Containers should be covered to prevent materials from dispersing into the environment.
  • Food waste should be collected separately and disposed of in line with the new organic waste treatment requirements.

Waste skip ordering and reconciliation process

To ensure full traceability of waste movements and compliance with Duty of Care requirements, East On Projects operates a waste skip ordering and reconciliation process.

The Company shall:

  • Maintain a register of all skips and waste collection services ordered for Company operations and projects.
  • Record the following information for each skip or waste collection:
    • Site or project location
    • Date ordered
    • Waste type
    • Skip size/type
    • Waste carrier details
    • Collection and exchange dates
    • Associated Waste Transfer Note (WTN) or Consignment Note reference number
  • Verify that all Waste Transfer Notes and hazardous waste consignment notes are received from the waste carrier for each waste movement.
  • Reconcile skip orders and collections against received documentation to confirm:
    • Waste has been removed by an authorised carrier
    • Waste descriptions are accurate
    • Waste streams have been correctly segregated
    • Disposal or recovery routes are identified where applicable
  • Investigate and resolve any missing documentation, discrepancies, or unidentified waste movements promptly.
  • Retain records of skip orders, Waste Transfer Notes, consignment notes, invoices, and supporting documentation for a minimum of three years or longer where legally required.
  • Periodically review waste data and skip usage to identify opportunities to reduce waste generation, improve segregation performance, increase recycling rates, and minimise environmental impact.

Responsibility for maintaining the waste skip tracking and reconciliation process rests with the Managing Director or delegated responsible persons overseeing project operations and waste management activities.

Waste disposal and recovery

  • Recyclable waste must be sent to an authorised recycling facility.
  • General waste should only be sent to landfill as a last resort and must comply with pre-treatment requirements.
  • Hazardous waste must be segregated, stored, and disposed of in compliance with applicable regulations.

Prohibited landfill waste

The following types of waste must not be sent to landfill:

  • Liquid waste, including trade effluent.
  • Infectious healthcare waste from hospitals, clinics, and veterinary facilities.
  • Hazardous waste, including substances that are flammable, corrosive, reactive, or toxic.
  • Electrical and electronic equipment (WEEE) containing hazardous components.
  • Batteries, including automotive, industrial, and portable batteries.
  • Fluorescent tubes and light bulbs containing mercury.
  • Ozone-depleting substances, such as those found in certain refrigeration units.
  • Unprocessed food waste, where separate collection for organic treatment is required.

Hazardous waste management

Hazardous waste includes materials that pose a risk to human health or the environment. Examples include asbestos, chemicals, electrical components containing hazardous substances, batteries, and fluorescent light tubes. We must:

  • Store hazardous waste securely in clearly labelled containers.
  • Segregate different types of hazardous waste to prevent dangerous reactions.
  • Provide written handling and disposal instructions to employees.
  • Conduct regular inspections of hazardous waste storage areas.
  • Ensure that only authorised carriers transport hazardous waste to designated disposal facilities.
  • Maintain consignment notes for hazardous waste transfers for at least three years.

Waste Electrical and Electronic Equipment (WEEE) management

WEEE includes discarded electrical and electronic equipment such as computers, televisions, kitchen appliances, and power tools. To comply with regulations, we must:

  • Segregate WEEE from other waste streams to ensure proper recycling and disposal.
  • Store WEEE securely in designated containers to prevent environmental contamination.
  • Ensure collection by authorised WEEE recyclers who can process and recover valuable materials.
  • Maintain records of WEEE disposal to demonstrate compliance with waste management regulations.
  • Prevent hazardous WEEE components (e.g., batteries, mercury-containing devices) from mixing with non-hazardous waste.

Treatment of WEEE

Large appliances such as fridges, dishwashers, and washing machines account for over 40% of WEEE, alongside other equipment such as computers, televisions, kettles, and power tools. These items contain a variety of materials, including:

  • Metals (e.g., 6% in an average TV),
  • Glass (e.g., 50% in an average TV),
  • Plastics, ceramics, and precious metals.

Due to the presence of hazardous substances such as arsenic, cadmium, lead, mercury, and flame retardants, WEEE recycling poses health and environmental risks. Proper controls must be in place to manage exposure, especially to heavy metals like mercury and lead. If exposure to these substances is adequately controlled, the risk from other hazardous materials is typically also mitigated.

East On Projects is registered as an upper-tier waste broker with the Environment Agency (Registration number CBDU500358). A copy of the certificate is available upon request.

Controls on specific types of waste

Certain waste types require additional controls to ensure proper handling and compliance:

  • Packaging Waste: Businesses must minimize packaging waste by using reusable, recyclable, or biodegradable materials. All packaging waste must be separated and sent for recycling where possible.
  • Batteries: Used batteries, including industrial, automotive, and portable types, must be collected separately and disposed of through authorised recycling facilities to prevent environmental contamination.
  • WEEE: Electrical and electronic equipment must be disposed of as per WEEE regulations to ensure valuable materials are recovered and hazardous substances are managed safely.

Non-Compliance and penalties

Failure to comply with the Separation of Waste (England) Regulations 2025 may result in:

  • Fines of up to £10,000 per offense.
  • Legal action or revocation of waste disposal permits.
  • Increased waste disposal fees for non-separated waste streams.

Staff training & responsibilities

Our staff must be properly trained to deal with spills of hazardous materials stored on our premises. This includes instructions on what to do if there is a spill, the type of personal protective equipment required, and how to correctly dispose of contaminated clean-up materials.

All employees must:

  • Undergo training on proper waste segregation procedures.
  • Follow on-site waste management protocols.
  • Report any issues related to waste separation compliance.

Policy review

This policy will be reviewed annually or as required by legislative updates to ensure ongoing compliance with waste management laws.