Waste Rules for Plumbers, Electricians and Trades

A plumber replaces a boiler and drives away with the old one in the back of the van. An electrician rewires a house and leaves with a bag of cable offcuts, old fittings and a box of fluorescent tubes. Neither thinks of themselves as being in the waste business, and neither is. But the moment that material goes into the vehicle, it is controlled waste in the hands of a business, and the rules about carrying, describing and recording it apply. This guide covers what trades need to know, from registration to hazardous items to the tip run.

Whose waste is it?

Many tradespeople assume the rubbish belongs to the customer and that taking it away is a favour. In general it does not work that way. Waste you produce while carrying out a job, such as old pipework, offcuts, packaging and stripped-out fittings, is your business waste, even though the work is at a customer's home. Under the controlled waste rules, waste from construction work is treated as industrial waste, and the contractor who produces it is responsible for it. That responsibility is the duty of care in section 34 of the Environmental Protection Act 1990.

The practical result is that you cannot put it in the customer's household bin without their agreement, and you cannot take it to a household recycling centre as if it were the customer's waste. If a customer has asked you to take away something that is not part of your own work, such as an old sofa or garden clutter, you are carrying their waste, and that has a different registration implication.

Do you need to register as a waste carrier?

In England, anyone who carries waste they produce from construction or demolition work needs to be registered with the Environment Agency, even if it is only an occasional load in the back of a van. Plumbing, electrical and joinery work generally falls into that category. There is no minimum quantity below which registration is unnecessary. In Wales the register is run by Natural Resources Wales, in Scotland by SEPA and in Northern Ireland by NIEA, each with their own rules and fees.

If you also take waste away for other people, as a favour or as a paid service, you will normally need the upper tier registration. Our guide to upper tier and lower tier waste carriers explains the difference. Fees, renewal rules and the format of registration vary, and the carrier regime is under review, so check the current position on gov.uk before you rely on an old registration.

Carry a copy of your registration, and if you hand waste to another carrier such as a skip firm or a waste collection company, check their registration on the public register before you do.

What each trade typically produces

Most trade waste is non-hazardous and can be dealt with using standard transfer notes. Each trade has a few items that are not, and those are where mistakes happen.

The items that need extra care

Hazardous waste is any waste listed with an asterisk in the List of Wastes, or any waste that tests hazardous under the classification rules. For tradespeople, the most common culprits are:

• Asbestos. Old boilers, flues, pipe lagging, insulation board, fuse board backing and textured ceilings can contain it. If you suspect asbestos, stop work. Do not break, cut or sand it, and do not put it in the van. Asbestos waste has its own specialist rules.
• Fluorescent tubes and compact fluorescent lamps. They contain mercury and must be kept intact and collected as hazardous waste.
• Batteries. Emergency lighting, tools and alarms use batteries that need recycling, not binning.
• Ionisation smoke alarms. They contain a small radioactive source and are managed through waste electrical equipment routes. Ask the manufacturer or your waste contractor how to handle them.
• Solvents, sealants, adhesives and part-used aerosols and foam cans. These are commonly classified as hazardous when they contain solvents or are not empty.
• Oil and oil-contaminated waste. Heating oil tanks and the oil left in them, and oily rags, are hazardous.

Hazardous waste from business premises needs a consignment note rather than a standard transfer note, with rules on who can carry and receive it. If a job is likely to produce hazardous waste, agree the route with a specialist before you start. Redundant electrical equipment is also covered by the waste electrical and electronic equipment (WEEE) regulations, which has its own take-back and handling rules.

System water and sludge from power flushing a central heating system is a waste you produce on a customer's premises. Do not tip it on the customer's drive or into a surface water drain, and ask your waste contractor or the receiving site what they accept and how it should be classified.

Scrap metal and cash

Copper pipe, lead, cable and radiators have value, and trades often sell them to recover some of the cost of a job. Selling scrap is regulated. Under the Scrap Metal Dealers Act 2013, dealers must be licensed by their local authority, must check the seller's identity and keep records, and cannot pay in cash. If a dealer offers cash, they are breaking the law, and you should use a different one. Check the licence on the public register before you sell. Our guide to the scrap metal dealer licence shows how.

Never burn cable to recover the copper. Open burning of waste is controlled, it can be an offence under environmental legislation, and the smoke is a health hazard.

Tip runs, transfer stations and season tickets

Many council household waste recycling centres do not accept trade waste, vans or trailers, or limit what they take. Some run a paid trade waste scheme. Commercial transfer stations and waste sites take trade waste, usually by weight through a weighbridge, and they should give you a ticket and be willing to complete a waste transfer note.

A weighbridge ticket is not automatically a compliant waste transfer note. It will show date, weight and vehicle, but it may not include the description, the EWC code and both parties' details. Check what it records, and complete a proper note if it does not.

If you tip regularly at the same site with the same type of waste, a season ticket can cover all your visits for up to 12 months, as long as the waste, the parties and the arrangement stay the same.

Using a skip or a man with a van

If you hire a skip or use a collection firm, you remain responsible for the waste until it is properly handed over. Check the carrier's registration before you hand anything over, ask where the waste will be taken, and keep the transfer note. Fly-tipping from a cheap collection can be traced back to the producer, and a quote that is far below the market rate is a warning sign, not a bargain.

If the customer hires the skip for the job, agree in writing whether your waste may go in it, and tell the skip firm what will be in there, particularly if any of it is hazardous. Do not put trade waste in a customer's skip without their agreement.

Paperwork and customer arrangements

Every handover needs a waste transfer note with a clear description, EWC code, quantity, date and time, the parties, and the carrier's registration. Keep them for at least two years. For hazardous waste, consignment notes are kept for longer, in line with the regulations.

On the customer side, put a waste line in your quote. Say whether waste removal is included, how you will dispose of it, and that you hold a waste carrier registration. A short job record, with the address, the date and where the waste went, is also useful. If an enforcement officer asks about a fly-tipped load that matches your type of work, those records show you handled it properly.