Setting Up a Waste Transfer Station

Top 10 O Licence Failures Found at DVSA Audits — And How Waste Operators Can Avoid Them Waste operators face some of the toughest transport conditions in the industry: early starts, reactive jobs, unpredictable load times, heavy weights, busy tipping sites, complex vehicle setups, and dense driving routes. It’s no surprise that the DVSA and Traffic Commissioners frequently target waste fleets for audits — because historically, the sector has some of the highest rates of compliance failures. But here’s the truth many operators overlook: Nearly every major O Licence failure is preventable with strong systems and continuous Transport Manager oversight. This guide breaks down the top 10 failures DVSA find at waste operator audits — and more importantly, what operators must do to avoid them. 1. Poor Maintenance Systems (The Number One Failure Every Year) Waste vehicles — skip wagons, tippers, hook-loaders, and RoRos — suffer harsher wear and tear than most industries. DVSA expect above average maintenance standards, not lower ones. Common failures: PMIs not completed on time Missed inspections with no rebooking No maintenance planner No evidence of brake testing Safety items recorded as “advisories” MOT prep not documented No management oversight How to avoid failure: Use a 6–10 week PMI schedule (waste fleets need tighter intervals) Keep a printed and digital maintenance planner Ensure every PMI sheet is signed, legible, and challenged Include laden roller brake testing 4 times per year minimum Put a second person (not just the TM) in charge of chasing missed inspections A strong maintenance system is the backbone of your O Licence. 2. Ineffective Transport Manager (TM Not Providing Continuous & Effective Management) The DVSA and Traffic Commissioner now look closely at whether the TM is genuinely managing the fleet. Red flags: TM not on-site enough TM not holding regular compliance meetings Drivers don’t know who the TM is No audits of defect reports, PMI sheets, or tachos TM only reviewing data “on paper” How to avoid failure: Set clear TM hours (documented and realistic) Hold weekly compliance meetings Evidence TM actions: emails, audits, meeting notes Ensure the TM has authority to remove vehicles from service Waste operators with weak TM oversight are almost guaranteed to face Public Inquiry. 3. Defect Reporting Failures Waste fleets rely heavily on hydraulics, lifting gear, sheeting systems, chains, and chassis strength — so defects must be taken seriously. Common failures: Nil defects every day from the same drivers Missing defect reports Defects repaired without documentation Drivers not trained in defect checks Unsafe vehicles still being used How to avoid failure: Train drivers properly on walkaround checks Challenge repeat “nil defect” patterns Require defect forms even for minor issues Keep records of all repairs, including invoices Consider random gate checks to catch false reporting 4. Tachograph Infringements and Poor Drivers’ Hours Management DVSA expect operators to have tight control over drivers’ hours. Waste-specific mistakes: Drivers staying on “other work” when loading Drivers forgetting to change to break mode Drivers not taking the 45 minutes correctly Agency or foreign drivers misusing tachographs Rounds that make legal driving impossible How to avoid failure: Weekly tacho analysis Mandatory infringement signing and retraining Realistic route planning TM involvement in identifying frequent offenders If the DVSA find long-term infringement patterns, they’ll assume the TM is not managing the fleet. 5. Overloading — Especially in Skip Wagons, RoRos, and Tippers Waste loads are unpredictable. DVSA know this, and they target waste vehicles for this reason. Common failures: Overloaded containers Excessive heaped loads Incorrect use of chains or sheets No weighbridge checks Drivers “guessing” weight How to avoid failure: Train drivers on load assessment Use weighbridge data proactively Stop customers overloading skips Set rules for heaped loads Maintain sheeting equipment If DVSA find overloading, they will always check compliance systems next. 6. Lack of Training, Induction, and Competency Checks Waste operators have additional risks due to: Manual handling Complex equipment Hazardous waste Confined sites Urban collections Common failures: No induction training No driver handbook No H&S training linked to transport tasks No record of refresher training How to avoid failure: Issue and review a driver handbook annually Record all training in a matrix Provide toolbox talks monthly Use inductions for every new or agency driver Training failures often trigger repute concerns for the Operator Licence holder. 7. Poor Record Keeping DVSA often describe waste site paperwork as “chaotic” or “incomplete.” Common failures: Missing PMI sheets No calibration certificate Lost defect forms No OCRS monitoring Out-of-date policies How to avoid failure: Store records in a structured digital and paper system Introduce a monthly internal audit File tachograph data by week Keep PMI sheets by vehicle, not date Ensure the Transport Manager signs off checks monthly Good record keeping alone can save you at a Public Inquiry. 8. MOT Failures and Poor MOT Preparation Waste HGVs have higher than average MOT failure rates due to harsh operating conditions. Common failures: Brake imbalances Lighting failures Excess corrosion Worn suspension components Hydraulic leaks How to avoid failure: Conduct pre-MOT inspections Prepare vehicles 4–6 weeks before test Conduct voluntary brake tests Ensure workshop staff specialise in waste fleet needs TCs consider MOT failure trends as evidence of operator negligence. 9. Not Monitoring OCRS (Operator Compliance Risk Score) Many operators don’t understand their score — until DVSA turn up. Waste operators often fail due to: Frequent PG9 prohibitions Vehicle stoppages for insecure loads Defect-related prohibitions Driver hour offences MOT history issues How to avoid failure: Monitor your OCRS monthly Investigate every prohibition Act quickly on emerging trends A green score gives you breathing room; amber or red puts you on DVSA’s radar instantly. 10. Failure to Manage Contractors and Agency Drivers Subcontractors used for: Skip work Tipper jobs Haulage between waste sites Night shifts Peak periods …are often poorly supervised. Common failures: No checks on their O Licence No tacho data from subcontractors No training or induction No evidence they follow your procedures How to avoid failure: Request O Licence documentation annually Include contractors in audits Check their tachograph data where appropriate Induct them into site rules Keep evidence of monitoring Operators are responsible for anyone carrying waste on their behalf. Final Thoughts Waste operators face more transport risks than almost any other sector. But none of these risks excuse O Licence failures. With strong systems, competent management, and continuous oversight, every one of these failures is preventable. DVSA and the Traffic Commissioner expect: A proactive Transport Manager Strong maintenance Robust defect management Real tachograph oversight Proper driver training Clean record keeping Full control over subcontractors When you get the basics right, your fleet becomes safer, more efficient, and significantly less likely to attract enforcement or Public Inquiry. Need Support? I help waste operators with: O Licence audits TM support Drivers’ hours analysis Defect and maintenance system reviews PI preparation OCRS recovery Waste fleet driver training Strong compliance is the key to protecting your licence and your business.

Mirror Hazardous Waste: How to Classify Correctly Using WM3 Correct waste classification is the foundation of every compliant waste operation. It underpins Duty of Care, pre-acceptance, transfer notes, storage, handling, and onward movement. But one area consistently misunderstood across the waste and construction sectors is mirror hazardous waste, where the same waste description may be hazardous or non-hazardous depending on its composition. Incorrectly classifying mirror waste is one of the most common failings identified by the Environment Agency (EA). Mistakes lead to enforcement action, permit breaches, rejected loads, increased disposal costs and, in some cases, unsafe handling of dangerous materials such as asbestos, coal tar, or contaminated soils. This detailed guide explains exactly what mirror hazardous waste is, how to use WM3 to classify it, and the steps operators must take to process it safely and legally. 1. What Is Mirror Hazardous Waste? Some waste types have two possible waste codes: One hazardous One non-hazardous The correct code depends on the actual content and contamination level within the waste. These paired waste codes are known as mirror entries. Example: 17 05 03* – Soil and stones containing hazardous substances 17 05 04 – Soil and stones other than those mentioned in 17 05 03 The only difference is the presence of hazardous substances. This means classification is not based on appearance but on evidence. 2. Why Mirror Hazardous Waste Is a High-Risk Area for Operators Mirror entry classification directly affects: Permit compliance Duty of care Waste acceptance procedures Storage and segregation Consignment note requirements Treatment options Disposal routes EA inspection outcomes Incorrect classification can result in: ❌ Illegal disposal ❌ Breach of permit conditions ❌ Enforcement action ❌ Site shutdowns ❌ Criminal liability The EA expects operators to have robust WM3 systems for every mirror code they handle. 3. The WM3 Methodology Explained Clearly The WM3 guidance sets out the classification process in a systematic format. Here is the simplified process: Step 1: Identify the Waste Source Where did the waste come from? Construction Demolition Utilities Roadworks Industrial processes The source helps determine which chapter of the EWC applies. Step 2: Identify the Waste Stream Description Choose the correct six-digit code based on: Activity Material type Composition For mirror entries, you will see: One code with "*" (hazardous) One code without (non-hazardous) Step 3: Determine If Hazardous Substances Are Present This is the core difference. You must assess whether the waste contains hazardous substances such as: Heavy metals Hydrocarbons Asbestos Coal tar Chemicals Oils Solvents PAHs Contaminated soils Adhesives This requires documentation or testing. Step 4: Assess the Concentration of Hazardous Substances It’s not enough to detect a hazardous substance — you must determine whether it exceeds the threshold for hazard classification. Key thresholds include: Carcinogens Mutagens Persistent organic pollutants Toxic metals EWC-defined hazard properties (HP1–HP15) Step 5: Assign the Correct EWC Code If hazardous substances: Are present AND Exceed relevant thresholds → The waste is hazardous. If hazardous substances: Are absent OR Present only at trace levels below thresholds → The waste is non-hazardous. 4. Common Mirror Hazardous Waste Streams in the Waste Industry Below are the most frequently misclassified mirror entries, with real-world examples. 4.1. Soil and Stones – 17 05 03* / 17 05 04 Soils may contain: Hydrocarbons from spills Asbestos fibres Heavy metals Contaminated made ground Treated wood fragments Coal tar fragments Industrial residues Operator mistake: Accepting soils “as inert” without WM3 testing. Correct approach: Pre-acceptance questionnaire Site investigation reports Lab analysis (TPH, PAHs, metals, asbestos) Waste classification spreadsheet 4.2. Mixed Construction and Demolition Waste – 17 09 03* / 17 09 04 Mixed C&D is a high-risk stream. Potential hazardous substances include: Asbestos Gypsum Chemicals Bitumen containing tar Contaminated soils Lead-based paint Treated timber Operator mistake: Treating mixed loads as generic construction waste. Correct approach: Load inspection Sampling where needed Quarantine for suspect materials WM3 classification if contamination is likely 4.3. Bituminous Mixtures – 17 03 01* / 17 03 02 Coal tar is one of the biggest compliance risks. Coal tar asphalt contains high PAH levels and is hazardous. Operator mistake: Accepting black asphalt without checking its age or PAH content. Correct approach: TAR testing Knowledge of road age Documentation from the contractor Rejecting or quarantining suspect loads 4.4. Insulation Materials – 17 06 03* / 17 06 04 Hazardous substances in insulation may include: Blowing agents Fibre irritants Hazardous adhesive residues Asbestos 4.5. Wood Waste – 17 02 04 / 17 02 01* Treated wood can contain: Creosote Chromated copper arsenate (CCA) Lead-based coatings This is particularly relevant for demolition wood. 5. What Counts as “Evidence” for Mirror Waste Classification? Operators often fail here. Classification must be based on evidence, not assumptions. Acceptable evidence: Site investigation reports Soil investigation data Producer declarations Photographic evidence Pre-acceptance questionnaires Historical land use data Lab analysis (WAC is NOT classification testing) Professional judgement documented properly NOT acceptable: ❌ A guess based on appearance ❌ A verbal description from a driver ❌ A generic waste transfer note ❌ “We’ve taken material from this site before” ❌ Assuming soil is clean because “it came from a garden” Your site must be able to prove classification decisions. 6. Testing Requirements Under WM3 Some materials must be tested before classification. Examples include: Suspect soils Made ground Coal tar asphalt Mixed demolition waste Soil with visible contamination Testing should assess: TPH PAHs Metals Asbestos Hazardous organic compounds Important: WAC testing is not classification testing. WAC determines suitability for landfill AFTER classification. 7. Quarantine Procedures for Suspect Mirror Waste Every permitted site must maintain a quarantine area. Waste should be quarantined if: It contains suspect materials It does not match the waste description It requires sampling It poses a contamination risk The driver cannot provide correct information Quarantine protects your site from illegal acceptance and potential regulatory action. 8. Storage and Treatment Requirements for Mirror Hazardous Waste Hazardous waste may require: Sealed containers Covered storage Segregation Impermeable surfaces Specific drainage controls Limited storage time Appropriate labelling Never mix hazardous and non-hazardous waste streams — you will contaminate the entire load and breach your permit. 9. Duty of Care and Documentation for Mirror Waste You must maintain: Correct EWC code Hazard statement WM3 assessment Transfer note or consignment note Testing results Site investigation details Evidence of classification Missing documentation is one of the main reasons EA takes enforcement action. 10. Frequent EA Enforcement Issues for Mirror Waste The EA regularly issues warnings and enforcement for: ❌ Accepting hazardous soils as inert ❌ No WM3 assessment ❌ Incorrect EWC codes ❌ Incorrect storage of hazardous waste ❌ No evidence of testing ❌ Allowing contaminated waste into recovery operations ❌ No quarantine controls ❌ Poor staff training ❌ Treating hazardous waste under non-hazardous permits Mirror hazardous waste mistakes are taken seriously because they directly affect environmental protection. 11. How to Build a Robust WM3 Classification System 1. Pre-acceptance questionnaires Gather site history, photos, and waste descriptions. 2. Load inspection procedure Reject if waste does not match description. 3. Sampling and testing protocol Trigger testing when contamination is possible. 4. Classification spreadsheet Document WM3 calculations and decisions. 5. Training and competency Staff must understand: Hazard properties Mirror codes Visual contamination detection Investigation requirements 6. Record keeping Keep everything — classification is only defendable with evidence. 12. What Good Looks Like: EA Expectations for Mirror Waste A compliant operator will demonstrate: Clear classification evidence Strong acceptance controls Quarantine for suspect loads Correct EWC codes on documentation Competent TCM oversight A complete EMS covering classification Good stockpile and segregation practices Full duty-of-care compliance When operators get mirror waste classification right, their entire site compliance improves significantly. Final Thoughts Mirror hazardous waste is one of the most complex and misunderstood areas of waste management. Getting it wrong can result in illegal disposal, permit breaches, and enforcement action. Getting it right protects the environment, strengthens your permit position, and ensures safe, compliant operations. The key is simple: base every classification on evidence, not assumptions. Need Support With WM3 Classification? I help waste operators with: WM3 assessments Waste classification training Pre-acceptance systems Soil and asphalt testing coordination Quarantine procedures EMS development EA inspection preparation Robust classification protects your business — and your permit.

Construction & Demolition Waste: How Sites Can Reduce Contamination and Improve Outputs Construction and demolition (C&D) waste is one of the largest waste streams produced in the UK. On paper, it should be one of the easiest to recycle because a huge proportion is recoverable — hardcore, brick, concrete, soil, metals, and inert materials. But in practice, C&D is also one of the most contaminated and operationally challenging waste types a site can receive. Poor segregation on construction sites, inadequate waste descriptions, client pressure, time constraints, and mixed loads mean most transfer stations spend far more time than expected removing contamination that shouldn’t have been there in the first place. Reducing contamination and improving recycling outputs is not just good for compliance — it directly impacts profit, environmental performance, and permit stability. This guide explains how waste operators can implement practical, effective controls to maximise recovery while maintaining strong Environmental Agency (EA) compliance. 1. Why Construction & Demolition Waste Is So Difficult to Manage The construction industry produces large volumes of waste quickly. lts challenges typically include: 1.1. Poor segregation at source Builders often throw everything into one skip: Brick, block and concrete Timber Plasterboard Plastic Metal Insulation Flooring Packaging Soil and tarmac This creates huge inefficiencies at waste sites. 1.2. Inconsistent waste descriptions “Mixed construction waste” is rarely accurate. 1.3. High contamination risk Common contaminants include: Gypsum/plasterboard Asbestos Paints and sealants Tool batteries Foams and insulation Bitumen and tar 1.4. Consequences for operators Reduced recycling rates Higher processing costs Lower quality outputs More waste going to landfill EA concerns around disposal vs recovery Increased fuel and labour costs More manual picking required For sites already under permit conditions limiting waste types or requiring recovery evidence, high contamination can compromise your entire operational model. 2. Understanding C&D Waste Streams and Their Compliance Requirements The EA classifies C&D waste under specific waste codes: 17 01 – Concrete, bricks, tiles 17 02 – Wood, glass, plastic 17 03 – Bituminous mixtures 17 05 – Soil and stones 17 06 – Insulation materials 17 08 – Gypsum-based materials 17 09 – Mixed C&D waste Some of these are mirror hazardous codes, meaning they require WM3 assessment to determine if they are hazardous or non-hazardous. Operators must demonstrate correct classification, segregation, and treatment practices to stay compliant. 3. Why Reducing Contamination Should Be a Top Priority for Waste Sites 3.1. It protects the quality of your recovered products Contaminated 6F2 or screened soils may fail testing, become unsuitable for sale, or require reprocessing. 3.2. It reduces disposal costs The more contaminants you remove early, the less waste you send to landfill. 3.3. It improves chances of permit acceptance Sites producing high-quality products with strong segregation demonstrate genuine recovery. 3.4. It strengthens your EMS and inspection performance The EA routinely inspects: Picking lines Segregation Quarantine Load rejection Waste sampling Reducing contamination demonstrates control and operational competence. 4. Practical Strategies to Reduce Contamination at Waste Sites Below are measures that actually work in real waste-transfer settings. 4.1. Strengthen Waste Acceptance and Pre-Acceptance Systems What the EA expects: Waste descriptions that match the load Pre-acceptance for regular clients Rejection procedures where contamination is unacceptable What operators should implement: Request photos before collection Require builders to describe waste more specifically Use “high contamination risk” tags for large demolition jobs Refuse loads with gypsum, insulation, or chemical residues mixed throughout On arrival: Visual checks at the weighbridge Vehicle inspection before tipping Clear communication with drivers regarding contamination A strong acceptance process is the first and most important line of defence. 4.2. Improve Yard Layout for Better Sorting Efficiency Your site layout directly affects contamination control. Best practice for C&D handling areas: Designated bays for brick/concrete Separate bays for wood, metal, plastics, and soils A separate plasterboard-only area Clear signage and colour coding Hardstanding surfaces for easy sweeping A large, clearly marked quarantine area Segregation must be maintained at all times — if your site visually appears mixed or uncontrolled, the EA will take that as evidence of poor management. 4.3. Use Mechanical Processing to Improve Recovery Mechanical plant dramatically improves both output quality and labour efficiency. Essential equipment for C&D recovery: Screeners Separate fines, oversize, and recoverable materials. Crushers Produce 6F2, 6F5 and other aggregates. Magnets Pull out nails, rebar, and metal components. Picking stations Remove plastics, wood, insulation, and contaminants. Trommels Efficient separation of mixed soils and rubble. Benefits: Cleaner product Reduced labour cost Higher throughput Less residual waste Better compliance evidence Mechanical processing alone does not ensure recovery — but it makes proper recovery achievable. 4.4. Implement a Strong Contaminant Removal Strategy Common high-risk contaminants must be removed consistently. Plasterboard (Gypsum) One of the biggest compliance risks. When mixed with biodegradable waste, it creates hydrogen sulphide gas. Strategy: Collect separately Quarantine if found mixed Train pickers to identify gypsum fragments Asbestos Often hidden in artex, soffits, cement sheets, floor tiles, lagging fragments. Strategy: Maintain asbestos-awareness training Stop work and create a cordon Place suspect material in the quarantine bay Have a formal sampling procedure Insulation materials Foam, PIR boards, fibreboard. Strategy: Remove early on picking lines Store separately Wood, plastics, packaging Lower-risk but high-volume contaminants. Strategy: Good picking line operation Regular bale removal Frequent staff rotation 4.5. Boost Staff Training and Competence Training is a key part of EA compliance. Staff must understand: Waste codes Contaminants Rejection procedures Quarantine Picking line expectations Health and safety Asbestos identification WAC/WM3 basics A competent team increases product quality and reduces residual waste. 5. Improving Output Quality: What the EA Looks For High-quality recovered products show that the site is carrying out recovery, not disposal. To the EA, good output looks like: Clean crushed aggregate Consistent sizing (e.g., 6F2 meeting specification) Minimal visible contamination A reliable end-user market Laboratory testing or grading certificates Poor output looks like: Mixed rubble with wood and plastic Aggregates with packaging or metals inside Soil with plasterboard contamination Outputs that need further treatment Stockpiles mixed with raw waste If your output does not resemble a usable product, the EA may challenge your permit compliance. 6. Recording Evidence of Recovery Record keeping is critical. You must document: Input tonnages Output tonnages Waste rejection Contamination levels Product testing results End-user destinations Training completed If you cannot demonstrate your recovery through records, the EA may reclassify your operation as disposal. 7. Improving Soil Recycling Outputs Construction waste frequently contains soil mixed with rubble or contaminants. Key steps to improve soil recovery: Screen to remove stones Remove wood, plastics, and fines Test for contamination Quarantine suspect loads Identify topsoil vs subsoil Maintain separate stockpiles Clean soils are highly marketable — don’t let contamination downgrade them. 8. Managing Mixed C&D Waste (17 09 04) This is one of the hardest waste codes to recover effectively. To improve outcomes: Early mechanical separation Manual picking to remove contaminants A focus on clean aggregate diversion Dedicated stockpile space Avoid overmixing on arrival With a strong process, even heavily mixed loads can produce a high recycling rate. 9. Benefits of Reducing Contamination in C&D Waste Processing Strong contamination control delivers: Operational benefits Higher throughput Less downtime Reduced staff fatigue Lower plant wear Financial benefits Higher-value products Lower landfill costs Better site efficiency Compliance benefits Stronger position with EA inspections Easier permit variations Better local authority relationships Demonstration of recovery, not disposal Good contamination control is the foundation of a profitable, compliant site. 10. What a “Best Practice” C&D Recycling Site Looks Like A well-run site will demonstrate: Clear segregation of wastes Colour-coded bays A functioning picking line High standards of housekeeping Plant operators trained in load inspection Proper PPE and safety systems Regular EMS audits Strong stockpile rotation A visible quarantine area High-quality recovered aggregates Sites like this rarely struggle with EA inspections because they demonstrate obvious operational control. Final Thoughts Construction & Demolition waste will always present challenges due to its diversity and contamination risk. But with strong acceptance systems, good mechanical processing, effective staff training, and well-designed site layouts, waste operators can dramatically improve output quality and overall recycling rates. High-quality recovery strengthens your permit position, reduces operating costs, and boosts commercial success. The key is evidence — clear, consistent, documented control from acceptance to end product. Need Support Improving C&D Recycling Performance? I support waste operators with: Site audits Permit applications & variations Waste acceptance systems Picking line optimisation EMS development C&D process mapping Recovery evidence documentation EA inspection preparation Strong contamination control starts with strong systems — and I help operators put those systems in place.

Inert Waste Recycling: How to Demonstrate Recovery Instead of Disposal Inert recycling is one of the fastest-growing areas of the waste industry, driven by increasing landfill tax, demand for secondary aggregates, and tighter regulations on construction waste. But for operators seeking an Environmental Permit — or for those already running a site — one issue continues to cause confusion: How do you demonstrate that your activity is “recovery” rather than “disposal”? The Environment Agency is sharply focused on this distinction. Sites that fail to prove genuine recovery risk enforcement action, poor compliance ratings, permit refusal, or being pushed into more restrictive conditions, including additional monitoring and limits. This long-form guide explains exactly how operators can design, document, and evidence a compliant inert recycling operation. It is written from the perspective of a waste consultant who has supported multiple inert sites through permitting, variations, audits, and post-inspection improvements. 1. What Counts as “Inert Waste” — and Why the EA Treats It Differently Inert waste is defined as material that does not undergo significant chemical, physical, or biological changes. Common examples include: Soil Rubble Brick Concrete Stone Hardcore Excavation waste Sub-soils and non-contaminated spoil Operators often assume inert waste is “low risk,” but the EA disagrees — inert can easily become non-inert once contamination enters the picture. The EA considers contamination from: Plasterboard Asbestos Wood Plaster Plastics Metals Gypsum Tarmac containing coal tar Sites that do not control contamination are considered to be carrying out disposal, not recovery. 2. Understanding Recovery vs Disposal in Inert Recycling The distinction between recovery and disposal is essential. Recovery You are producing a usable, quality secondary aggregate or soil for legitimate end use. Disposal You are merely transferring, depositing, or stockpiling materials without creating a beneficial output. The EA expects operators to demonstrate: A process (sorting, crushing, screening, blending) A specification (6F2, 6F5, Type 1, Type 2, BS topsoil) A verified end user (construction, utilities, backfill, engineering projects) A reduction in landfilled material That the end product replaces virgin aggregates If your site cannot clearly demonstrate these outcomes, the EA will deem your operation a disposal activity. 3. The Core Requirements for an Inert Recycling Permit To operate compliantly, you must demonstrate: 3.1. Waste Acceptance Procedures Every load must be: Pre-assessed Described correctly Checked at the weighbridge Inspected on tipping Rejected if contaminated Loads arriving from streetworks, demolition, or utilities must be treated with suspicion — these streams frequently contain gypsum, plastics, timber, asphalt, and asbestos. 3.2. Segregation of Waste Streams Stockpiles must be: Clearly separated Labelled Managed so cross-contamination cannot occur Operators often undermine recovery by mixing clean and contaminated piles, making the entire stock unsuitable for treatment. 3.3. Suitable Treatment Equipment Typically required: Screening plant Crushing plant Trommels Magnets Picking station Loading shovels Grab vehicles Your permit application must demonstrate that your plant is capable of producing quality aggregates — simply piling material into a corner is not recovery. 4. Demonstrating Recovery Through Process Design To meet recovery definitions, operators must define their process clearly. 4.1. Step 1 — Pre-Acceptance Requested documentation may include: Site investigations Geotechnical reports Hazardous waste assessments WM3 classification Photographs of waste prior to collection 4.2. Step 2 — Arrival and Initial Screening Inspecting for: Asbestos Gypsum/plasterboard Wood Plastics Tarmac containing tar Contaminated soils Municipal waste fragments Rejection criteria must be documented and enforced. 4.3. Step 3 — Mechanical Processing Processing may include: Screening to remove fines Crushing to create uniform size grading Magnetic separation of ferrous metals Manual picking for contaminants Blending to meet specification 4.4. Step 4 — Testing and Quality Control The EA expects: Sampling of output material Gradation testing Contaminant checks Moisture content (for soils) Certificates of analysis Documentation issued with each batch Many operators skip this step — but without testing, you cannot prove recovery. 4.5. Step 5 — Storage of Finished Products Outputs must be: Stockpiled separately Labelled clearly Protected from cross-contamination Tracked by batch 5. How to Demonstrate an End Use (The Most Common Operator Weakness) The EA demands evidence of legitimate use. This is where most operators fail. A compliant end use must: Replace virgin aggregate Have a real market Be usable without further treatment Be accepted by the end user knowingly Examples of legitimate recovery: 6F2 supplied to a construction project Type 1 used for road foundations Clean topsoil used in landscaping Screened fines used for backfill Crushed concrete used as piling mat material Non-compliant end use includes: Filling voids on your own land without engineering design Stockpiling indefinitely without sale Depositing material on farmland Sending “low-quality product” to landfill after processing The EA will view these as disposal. 6. Waste Classification: Essential for Demonstrating Recovery WM3 assessments are vital. You must classify: Incoming waste Outgoing products This includes: 6.1. Mirror Hazardous Codes E.g.: 17 05 03* (soil containing hazardous substances) 17 05 04 (soil and stones, non-hazardous) 6.2. Gypsum and Plasterboard Waste containing gypsum may require separate collection under: 17 08 02 17 08 01* 6.3. Asphalt Containing Coal Tar 17 03 01* 17 03 02 These materials contaminate the entire load and prevent inert recovery. 7. Monitoring and Record Keeping To prove recovery over disposal, your site must keep: Weighbridge records Waste description forms Pre-acceptance assessments Processing logs Output testing results Sales receipts Transfer notes End user confirmations Training records Maintenance logs Strong record-keeping demonstrates that your site is structured, controlled, and compliant. 8. The EA’s View on Stockpile Management Stockpile control is a major compliance indicator. The EA expects to see: Defined maximum stockpile heights Separation of raw and processed stock Stock rotation Records of input/output balances No mixing of waste and product No excessive build-up Large, unprocessed stockpiles are a red flag that the site is operating disposal. 9. Meeting Permit Conditions and Operational Techniques Operators must demonstrate: Dust and noise control Surface water management Silt traps Bunding Spill management Staff training Competent management (TCM) Infrastructure integrity Inert doesn’t mean low risk — dust complaints, water pollution and poor stockpile control are three of the most common causes of enforcement. 10. What the EA Looks for During Site Inspections Inspectors will assess: 10.1. Waste Storage Areas They expect clear segregation and no mixing. 10.2. Picking and Processing Lines Is material actually being sorted? 10.3. Output Quality Does it resemble a real product? 10.4. Fire Prevention Controls Inert sites still pose fire risks due to: Fuels Machinery Spark-producing equipment 10.5. Environmental Monitoring Dust suppression and water controls must be active, not theoretical. 10.6. TCM Involvement Evidence of training, audits and inspections. 11. Common Pitfalls That Cause Recovery Claims to Fail Top reasons the EA disagrees with operators: ❌ Minimal or no processing taking place ❌ Contaminants not being removed ❌ Mixed stockpiles ❌ No testing or product specification ❌ No end user or weak sales evidence ❌ Excessive accumulation of material ❌ Incomplete paperwork ❌ No pre-acceptance procedure ❌ Incorrect waste classification When one or more of these issues appears, the EA reclassifies the operation as disposal. 12. What Good Looks Like: The EA’s Ideal Inert Recycling Site A compliant site demonstrates: A well-structured layout Quarantined contaminated loads Laboratory-tested output products Efficient stock rotation A documented quality management system Competent staff operating machinery A TCM actively involved in daily operations Housekeeping that reflects control Real sales and legitimate end users Good sites look clean, organised and professional. Poor sites look chaotic — and are often treated as disposal operations. 13. Final Thoughts: Recovery Is About Evidence and Control To operate a compliant inert recycling facility, operators must move beyond the mindset of simply taking in waste and producing a “pile of something.” The EA wants: A controlled process A quality product Clear segregation Evidence of recycling A real market A competent management system If you can demonstrate these factors, your operation will be recognised as recovery — increasing credibility, reducing regulatory scrutiny, and raising commercial value. Need Support With Your Inert Recycling Permit or Operation? I support operators with: Permit applications and variations Waste acceptance systems Site layout design Quality protocols WM3 waste classification Environmental management systems TCM cover and audits EA inspection preparation Strong evidence and good systems are the foundation of a compliant inert recycling site — and ultimately the foundation of a successful, profitable operation.

Why Your Transport Manager Must Be ‘Continuous and Effective’ — Not a Name on Paper In the waste and recycling sector, transport operations are fast-paced, often reactive, and carry a higher-than-average level of compliance risk. Skip wagons running multiple collections per day, hook loaders moving waste between sites, roll-on roll-off containers, tippers, grab wagons, cage vans and articulated bulkers — all create complex maintenance demands, variable driver behaviours, and constant time pressures. For this reason, the Traffic Commissioner expects every Operator Licence holder to have a Transport Manager (TM) who provides continuous and effective management, not someone whose name appears on the licence simply to satisfy a legal requirement. In recent years, the waste sector has been a repeated feature in Public Inquiries where the TM was either absent, overwhelmed, part-time without oversight, or completely disengaged from the fleet. This blog explains exactly what “continuous and effective” means — and why the waste industry must take it seriously. 1. The Legal Definition of ‘Continuous and Effective Management’ Under the O Licence regime, a Transport Manager must: Have real authority over fleet decisions Be involved day-to-day Be able to demonstrate control Ensure legal compliance is maintained at all times Take action when drivers or management fail to comply This means the TM must be: Available Informed Engaged Resourced Empowered And — most importantly — seen to be actively managing compliance The Traffic Commissioner will not accept: “They only come in once a week.” “They only look at the tachograph data.” “I didn’t know the maintenance was overdue.” “The drivers don’t report defects to me.” If a TM cannot prove active involvement, the operator and the TM both risk regulatory action. 2. Why Waste Operators Are Under Extra Scrutiny Waste transport is inherently high-risk. The Traffic Commissioner regularly highlights the following industry challenges: Frequent stops and starts Skip wagons and tippers experience higher brake wear and suspension stress. Heavier load weights RoRo containers, bulkers and hook-loaders often run near gross limits — sometimes unknowingly exceeding them. Contaminated and uneven loads C&D waste, scrap metal, soils and RDF all affect load stability. More complex defect patterns Cracked springs, worn sheeting systems, split air lines, bent bin lifts, tailgate issues and hydraulic leaks are common. Drivers under pressure Multiple collections per day encourage shortcuts in walkaround checks and load security. Because these risks directly link to road safety, waste operators are expected to have above-average transport supervision, not less. 3. What Continuous and Effective Management Looks Like in Practice Here is what an effective TM should be doing routinely at a waste fleet: 3.1. Maintenance Oversight Ensuring PMIs are booked and completed on time Reviewing inspection sheets for recurring defects Checking brakes, suspension, hydraulic systems and lifting gear maintenance Verifying MOT pre-checks Challenging any missed or delayed PMI 3.2. Driver Management Reviewing daily defect reports Managing drivers who repeatedly submit “nil defects” Conducting tool-box talks and refresher training Addressing high tachograph infringement rates Ensuring walkaround checks are actually being completed 3.3. Tachograph & Drivers’ Hours Weekly or fortnightly review of infringements Action plans for repeat offenders Analysing working time patterns Ensuring agency and foreign drivers understand the rules 3.4. Record Keeping Up-to-date maintenance planner Evidence of defect rectification Calibration records Vehicle files and audit trails Driver training files 3.5. Load Security & Weight Compliance This is especially important in waste operations: Securing skips, containers and sheeting operations Ensuring drivers understand how C&D waste settles Monitoring overloading risks through weighbridge data Correct use of chains, nets and sheeting systems 3.6. Auditing & Reporting A TM must complete internal audits on: PMIs Tacho data Defect reports Maintenance provider performance And must report issues directly to the Operator / Director with corrective action plans. 4. Warning Signs the TM Is “Name on Paper Only” Traffic Commissioners see the same patterns repeatedly in PI cases. You may have a paper TM if: Drivers don't know who the TM is The TM hasn’t been to site for weeks No tool-box talks or driver meetings take place Tacho infringements go unchallenged Nil-defect reporting is the norm The TM doesn’t understand waste-specific vehicle risks PMI intervals drift without action There is no maintenance planner Records are missing, incomplete, or unorganised These issues almost guarantee a Public Inquiry. 5. Consequences for Having a Non-Effective TM Operators often believe the TM carries the risk — but Traffic Commissioners regularly prosecute both when compliance fails. Operators risk: Licence curtailment Licence suspension Licence revocation Fines Increased DVSA targeting Loss of contracts Transport Managers risk: Loss of repute Disqualification Requirement to re-sit CPC A ban on acting as a TM anywhere in the UK Public Inquiry outcomes are published publicly and reputational damage can be significant, especially within local authority and large contractor frameworks. 6. How Many Hours Should a TM Spend Managing a Waste Fleet? Hours are not fixed in law — they depend on: Fleet size Vehicle type Operation complexity Number of depots Agency driver usage However, waste fleets generally require more time than standard haulage due to higher defect rates, load risks, and driver turnover. A typical guideline: Fleet Size Recommended TM Hours/Week (Waste Fleet) 1–2 Vehicles 2–4 hours 3–5 Vehicles 4–6 hours 6–10 Vehicles 6–10 hours 11–20 Vehicles 10–20 hours 20+ Vehicles Full-time TM If your TM hours look unrealistically low, the TC may view this as non-compliant. 7. What Waste Operators Should Put in Place Immediately 7.1. Written TM Agreement Clearly define: Duties Hours Reporting structure Authority 7.2. Weekly Compliance Meetings Short meetings to cover: Defects PMIs Infringements Overloading Incidents 7.3. Proper Walkaround Check Training Waste vehicles have unique hazards: Bin lifts Chains Hook-arms Sheeting systems Rear steer lift axles Generic walkaround videos are not enough. 7.4. Internal Auditing Process Evidence is everything. 7.5. A TM with authority The TM must be able to say: “That vehicle is parked until repaired.” “That driver needs training.” “We’re increasing PMI frequency.” If the TM is ignored, the TC will view the operator as non-compliant. 8. How Transport Managers Can Prove They Are ‘Continuous and Effective’ During DVSA audits or Public Inquiry, TMs must evidence: Records of actions they have taken Emails, reports, or meeting minutes Internal audits Driver training notes Defect challenge logs Corrective actions for the same drivers repeating issues Traffic Commissioners are very clear: If it isn’t written down, it didn’t happen. Final Thoughts The waste sector needs strong transport management more than most industries. Heavy loads, high turnover, busy routes, tight urban access, and difficult waste environments all demand consistent and proactive supervision. A Transport Manager cannot simply be a name on an O Licence. They must be: Present Active Knowledgeable Empowered Documented Accountable Without genuine TM oversight, operators expose themselves to enforcement risks that can close a business overnight. Need Support? I help waste operators with: TM audits O Licence compliance systems Driver training Transport compliance reviews External TM services Public Inquiry preparation Strong transport management isn’t optional — it’s the backbone of a safe and legal fleet.

Managing end-of-life tyres (ELTs) is one of the more tightly controlled activities in the waste sector. The risks are well-known: fire, stockpile collapse, arson, environmental harm, and commercial operators entering the market without suitable controls. As a result, the Environment Agency (EA) places a heavy emphasis on robust management systems, site design, fire prevention controls and technical competence long before a permit can be issued. With 24 years in the waste industry and extensive experience preparing permit applications, this guide sets out exactly what operators need to know before applying — and what the EA expects to see before they will even consider granting permission. This article is purposely written in a practical, straight-talking way for operators, recyclers, hauliers, and new entrants to the tyre sector. 1. Understanding the Regulatory Scope for End-of-Life Tyres End-of-life tyres are regulated as non-hazardous waste, but the regime surrounding them is far more restrictive than most non-hazardous streams due to two primary risks: Fire Stockpile instability and abandonment The EA regulates tyres through: Environmental Permitting Regulations (EPR) 2016 Fire Prevention Plans (FPP) Guidance Specific waste codes related to tyres 16 01 03 – End-of-life tyres Control of major accident hazards (COMAH) thresholds, where applicable Duty of care and storage limits Most tyre operations will require a bespoke environmental permit rather than a Standard Rules Permit because ELTs typically breach SRP limits or require treatment not covered under standard rules. If you intend to: Store tyres Shred tyres Treat tyres mechanically Bale tyres Export tyres Produce shred, chips, or crumb rubber …then a permit will be required. Operators who underestimate the regulatory load associated with tyres are very unlikely to progress through permitting smoothly. 2. Common Activities Involving End-of-Life Tyres Most tyre businesses fall into one or more of the following categories: 2.1. Storage Only Tyres are stored before onward transport to recovery or recycling. Permits limit: Maximum tonnage stored Stack height Stack footprint Separation distances Fire compartments Even a “storage only” operation requires a full Fire Prevention Plan. 2.2. Mechanical Shredding Includes shredding whole tyres into: 150mm shred 50mm shred PAS 107 specification products Mechanical treatment increases fire risks and therefore requires detailed engineering controls, ATEX consideration and strict maintenance systems. 2.3. Baling or Processing Required for export or commercial resale. Baling has caused some of the most serious tyre site fires in the UK due to inadequate separation and overstocking. 2.4. Mobile Plant Tyre Shredding Requires a mobile plant permit registered by an operator with a fixed base, including waste acceptance and tracking systems. If your site does any combination of storage and treatment, the EA expects a high level of management sophistication. 3. What the EA Looks for Before They Approve Tyre Sites End-of-life tyre permits attract heavy scrutiny. Inspectors will typically assess: 3.1. Technical Competence (TCM Requirements) Operators must demonstrate: A suitable TCM with relevant WAMITAB units Continuous cover (not a TCM “on paper”) A CPD plan The EA views tyre sites as higher risk, so they expect technical leadership to be robust and demonstrable. 3.2. Fit and Proper Person Test The EA will consider: Past compliance history Financial competence Criminal convictions Previous site abandonment Insolvency events Tyre operations have historically been associated with rogue operators, so the EA’s tolerance for risk is extremely low. 3.3. Fire Prevention Plan (FPP) No tyre permit will be granted without an FPP fully accepted by the EA. Your FPP must demonstrate: Maximum storage tonnage Stack dimensions 6m separation distances Site layout Ignition source control Quarantine areas Firewater containment Access for emergency services Stock rotation strategy Maximum dwell time Tyre-related fires are notoriously difficult to extinguish, and many have burned for days or weeks, causing millions in damages. This is why the EA scrutinises the FPP more aggressively than any other part of the application. 3.4. Waste Acceptance Procedures Before tyres arrive on site, operators must have: Inspection procedures Load rejection criteria Controls against contamination Acceptance documentation Tracking and storage location systems Tyres often arrive mixed with: Rims Rubber strip Metal wire Plastics General waste Contamination causes fires, sparks, and equipment hazards. 3.5. Firewater and Pollution Risk Your application must include: Pollution inventory Secondary containment Surface water protection Drainage plan Accident management procedures The EA will reject applications that cannot demonstrate secure control of firewater run-off. 4. Site Design: The Foundation of a Successful Permit Application Tyre sites must be designed with: 4.1. Clear traffic flow Separate pedestrian and vehicle routes, turning areas for HGVs, and clear signage. 4.2. Adequate surface infrastructure Concrete surfaces free from cracks and potholes are essential for fire control and drainage integrity. 4.3. Sufficient space for stack separation Operators regularly underestimate how much space 500 tonnes of tyres requires. 4.4. Security High fencing, anti-arson measures, and CCTV. Tyre sites are frequent targets of arson. 4.5. Power supply Mechanical shredders have high load demands. A common reason applications fail is that the operator tries to make the site fit the permit, instead of designing a permit that fits the site. 5. Management System Requirements Your management system (MS) should demonstrate: Training and competency Daily inspections Tyre rotation and stock tracking Housekeeping checks Maintenance records At least one named senior manager responsible for environmental performance TCM involvement and oversight The EA expects management systems to be site-specific, not generic templates. 6. Demonstrating Financial Competence Operators must prove they can: Manage site operations Fund fire prevention measures Maintain shredding machinery Cover clean-up costs if stockpiles must be removed Abandoned tyre sites are one of the largest financial liabilities in the waste sector. Expect the EA to scrutinise your financial modelling and contingency costs. 7. Maximum Storage Capacity and Throughput You must define: Maximum storage on site Maximum operational stock Annual throughput Retention and dwell time The EA will assess whether your stated throughput is realistic when compared to: Shredder capacity Staffing Operating hours Export markets Site size If you cannot demonstrate that tyres will not accumulate, your application will be refused. 8. Common Reasons Tyre Permit Applications Are Rejected After supporting operators through many tyre permit applications, these are the most frequent reasons for regulator refusal: ❌ FPP not acceptable ❌ Stockpiles too large ❌ Inadequate site drainage ❌ Lack of genuine TCM involvement ❌ Unrealistic throughput claims ❌ History of poor compliance ❌ Inadequate financial evidence ❌ No demonstrable storage rotation strategy ❌ Sub-standard infrastructure (gravel yards, broken concrete) Tyre permits are awarded only to operators who can clearly demonstrate control and stability. 9. Preparing a Successful Application: What Operators Should Do Step 1 – Commission a Feasibility Assessment Identify: Whether the site is suitable What infrastructure is missing Compliance gaps Step 2 – Prepare detailed site drawings Including stack layout, drainage, fire access, quarantine area. Step 3 – Develop a robust Fire Prevention Plan Expect several rounds of EA feedback. Step 4 – Create a site-specific EMS Housekeeping, acceptance, training, maintenance, and contingency controls. Step 5 – Outline your TCM structure Demonstrate continuous and effective management. Step 6 – Engage with the local Fire & Rescue Service Their comments can strengthen your FPP. Step 7 – Submit a high-quality permit application Include everything the EA expects up front. Step 8 – Maintain compliance from day one Permit conditions are legally binding the moment the permit is issued. 10. What a Good Tyre Site Looks Like (From a Compliance Perspective) A compliant facility has: Hardstanding Clearly marked stacks 6m separation Good drainage No vegetation Daily inspection logs A high level of housekeeping Competent staff Controlled access CCTV and security measures Shredder maintenance logs A safe loading/unloading system Good sites look organised. Bad tyre sites look cluttered, chaotic, and unstable — and the EA can spot the difference instantly. 11. Final Thoughts: Should You Enter the Tyre Sector? Tyre recycling is a growing industry with strong demand for: Shred Crumb Reuse Export Civil engineering applications However, it is also a sector with: High regulatory scrutiny Serious fire risks High equipment costs Strict compliance expectations If you cannot demonstrate operational discipline, this is not the area to cut your teeth in. But for operators who invest properly, demonstrate competence, and maintain control, tyre recycling can be a profitable and future-proof waste stream. Need Support With a Tyre Permit? I support operators with: Feasibility assessments Environmental permit applications Fire Prevention Plans Site layout design EMS development TCM oversight Pre-application EA engagement If you want your tyre permit to progress smoothly, professional preparation is essential.

What Documents Should Be On-Site During an Environment Agency Visit?

Learn how to manage fire water on waste and tyre recycling sites. Hart Waste Consultancy designs compliant Fire Prevention Plans and containment systems across the Midlands.

Avoid losing your waste exemption. Discover the top 5 mistakes that lead to Environment Agency revocations and how to stay compliant with expert help from Hart Waste Consultancy.