Environment Agency system to ease burden in waste transfers

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The Environment Agency has launched its electronic duty of care (Edoc) system, developed as part of the Government’s ‘Red Tape Challenge’ to review and streamline over 21,000 statutory instruments. The system is key to simplifying and reducing the burden faced under environmental regulation.

Edoc was unveiled on 29 January 2014 by the Environment Agency, having developed the system in partnership with waste industry operators and a number of other UK public bodies, including the Department for Environment, Food and Rural Affairs (Defra), the Waste Resources Action Programme and Natural Resources Wales. The system allows waste transfer notes (WTN) to be created, shared, edited, signed and stored electronically.

Under the Waste (England and Wales) Regulations 2011 (the 2011 Regulations), anyone handling controlled waste has a duty of care which means it must:

  • demonstrate it is taking reasonable steps to apply the prescribed waste hierarchy when transferring waste
  • ensure completion of WTNs to evidence the same.

In essence, a WTN is therefore a document providing a written description of waste on its transfer from one person or establishment to another. It ensures a clear audit trail throughout the process from waste production to disposal, as outlined in section 34(1)(c) of the Environmental Protection Act 1990, and is part of the overall duty of care.

The Environment Agency estimates that approximately 23 million WTNs are produced annually and, owing to record retention requirements, over 50 million WTNs exist at any one time. With the requirement that each WTN is retained for a minimum of two years, the ability to keep electronic records on edoc will considerably reduce the documentary burden facing businesses.

Edoc is a free-to-use system for any business in the UK that:

  • produces waste
  • is involved in transporting business waste


  • has a role in managing business waste.

Any user must register on edoc, but can choose whether to do so as an entire organisation or separately for different parts of the business. Although it remains voluntary to use, the online system appears relatively intuitive and user-friendly. Alongside the evident advantage of reducing the need to retain hard copies, other benefits include:

  • automatic email notifications to users when an action is outstanding and requires attention
  • a confidentiality feature, meaning only parties directly involved in the relevant transfer and the waste regulator can access the waste transfer records
  • an in-built action log relating to each WTN, allowing users to see who has undertaken actions required and when
  • the ability to create downloadable reports on waste transfers involved in/recorded on edoc.

Making the WTN process quicker and its recording easier has long been an aim of both Defra and the Environment Agency, with edoc appearing to be a ‘step’ in the right direction. However, further changes are expected in light of Defra and the Welsh Government’s consultation on amendments to WTN provisions in the 2011 Regulations. The consultation closed on 20 January 2014 and a subsequent report is expected.