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Waste on the Thames

Waste is created during many different activities on the Thames within the Port, due to the different regulatory processes there are subtle variations in what is required to minimise the impact to the environment.

  • Ship derived waste
    • under Marpol 73/78 Convention if vessels are classified; or
    • created in the operation of local businesses
  • Dredged material- see the dredging section of the website
  • Construction created waste

Waste production, storage and disposal is controlled by a number of complimentary laws, however it can be quite confusing to understand the role that a vessel, operator or client has with waste on the Thames. There is a lot of recording of waste for all parties, and it is important to understand what you are required under your duty of care, therefore the EA, MCA and PLA have produced this guidance to help you identify your roles and responsibilities.

Port waste management planning

Port waste management planning is a requirement for vessels under Marpol 73/78 Convention, EC Directive 2000/59/EC & Merchant Shipping (Port Waste Reception Facilities) Regulations to:

  • notify the port before arrival of waste onboard and the amounts to be offloaded
  • offload all ship-generated wastes to terminal reception facilities, unless they are retaining wastes as indicated above
  • pay for the use of waste discharge facilities

Terminal operators must provide adequate waste reception facilities, and must have in place a port waste management plan.

Although fishing vessels are exempt from notifying ports of their waste, and of paying a mandatory charge, they must land waste into the facilities provided by the port or directly to a waste contractor through a private contract.

Smaller vessels not governed by this regime are expected to dispose of their waste in an appropriate manner without impacting on the environment.

Vessels must make sure that waste from exhaust gas cleaning systems is handled carefully. If the waste stream can be demonstrated not to have any environmental impact, discharge to shore may be permitted.

More information is available from the MCA, and in MGN_387.

Your waste: Your responsibility

The waste your operation produces on your vessel must be removed by a waste carrier licenced by the Environment Agency. Upon collection of the waste, whether general domestic waste, recyclables such as glass, cans, paper and plastic you must receive a 'Duty of Care Waste Transfer note' and retain records for minimum of two years. It is a legal requirement for a licensed waste carrier to produce a transfer note when collecting waste. If your waste is collected by an unauthorised carrier and not disposed of correctly you may face enforcement action. Waste should be stored safely and securely at all times.

This transfer note must contain specific information including:

  • Name of the waste carrier
  • Waste carriers licence number
  • Description of the waste, including a six digit EWC code
  • Where the waste will be taken for recycling or disposal
  • Volume or weight of the waste

It is a legal requirement for a licensed waste carrier to produce a transfer note when collecting waste. If your waste is collected by an unauthorised carrier and not disposed of correctly you may face enforcement action. Waste should be stored safely and securely at all times. If the waste you produce is classified as hazardous waste then further waste controls apply. For more information on your duty of care with waste see https://www.gov.uk/environmental-management/waste.

All waste must be disposed of at an authorised facility. These facilities must have an environmental permit or an exemption to operate from the Environment Agency. You can check if a facility has a permit, or if the waste carrier removing your waste has a licence on the public register at: https://www.gov.uk/access-the-public-register-for-environmental-information.

More information is available with this guidance note from the EA.

Hazardous Waste

Hazardous waste describes a number of different waste streams. This can include: Waste oil, chemicals, solvents, paints, batteries and waste electrical equipment including fridges and TVs. Any hazardous waste should be stored securely and where it can not cause pollution to the environment.

Hazardous Waste Consignment notes are different from collections of non-hazardous waste. These notes must be kept for three years and require the holder of the waste to sign the note stating the details upon it are correct. The consignment note must contain all the details of a duty of care waste transfer note including further details about the nature of the waste; whether it is solid, liquid or gas; the unique hazard code and what the hazardous component of the waste is. An example of a consignment note can be found here.

Once the waste has been removed the site that recycled or disposed of the waste must confirm this by sending you a quarterly return. This will include the details of all of the hazardous waste collected from your site and treated by this facility in that quarter. Often this comes in the form of the completed Part E section of the consignment note being returned to you.

Any non-hazardous waste that is mixed with hazardous waste will mean that the whole load is treated as hazardous which will often incur much higher disposal costs.

Hazardous waste must always be taken for treatment or disposal at licenced premises, by appropriate licenced waste carriers (not all are licenced for hazardous waste). If the consignment note is missing any of this information, speak to your registered waste carrier to ensure the consignment note is completed fully.

More information is available with this guidance note from the EA.