In the company he is one of the great protagonists of waste management: the Loading/Unloading Register. It is an accounting document in which all the loading and unloading movements of the waste themselves are noted, in chronological order. We speak of “loading” when waste is produced and “unloading movements”, when the waste is delivered to a transporter to be disposed of.
Loading movements must be marked within ten working days from the date of actual placement of the waste in the temporary storage, while unloading movements must be noted within ten working days from the date of collection of the waste by the transporter. In the event of checks by the authorities, it provides proof, together with the form, of the correct management of the life cycle of the waste.
The methods of managing the register are governed by theart. 258 Legislative Decree no. 152/06 , which points out that anyone who fails to keep or keeps incomplete the register of loading and unloading of non-hazardous waste, is punished with an administrative fine of between 2,000 and 10,000 euros. In the case of hazardous waste, however, the penalty is much higher: from 10,000 to 30,000 euros. In the most serious cases , the optional ancillary administrative sanction of suspension from one month to one year from the office held by the person responsible for the offence and from the administrative office is applied.
But who are the subjects required to fill out this document? Here are the types of entities and companies required to fill in the form (art. 190, paragraph 13, art. 189, paragraph 3 and art. 184, paragraph 3 letters c), d) and g) of Legislative Decree no. 152/2006):
- Entities and companies that initially produce hazardous waste;
- Entities and companies producing non-hazardous waste with more than 10 employees deriving from: industrial and artisanal processes from waste recovery and disposal activities, sludge produced by drinking water and other water treatments and wastewater purification and fume abatement;
- Anyone who carries out professional waste collection and transport activities;
- Bodies and companies that carry out waste recovery and disposal operations;
- Waste traders and intermediaries without detention.
On the other hand, for non-hazardous waste only, initial producing companies and entities that have no more than 10 employees are exempt; companies that collect and transport their own non-hazardous waste (Article 212, paragraph 8); finally, entities and companies producing special non-hazardous waste deriving from agricultural and agro-industrial activities, demolition, construction and excavation activities, commercial, service and health activities.
The records relating to the transport of waste must be kept for 3 years from the date of the last registration and the data present must be kept or made accessible at each production plant.
Now let’s see how a Load must be filled in detail (leaving out the home page).
FIRST COLUMN: (type of operation Unloading-Loading): tick the Loading box.
Just below the crossed out box, enter the date of the Load operation and the operation number. (The numbering is always progressive, e.g. 01/21, 02/21, 03/21…)
If more than one register is used during the year, the first number of the second register will be numerically later than the last number of the first register. With the new year, the numbering starts again from 01 (e.g. next year 01/22).
SECOND COLUMN: (Waste characteristics): enter the CER code that identifies the product category. Under “Description”, report the description of the waste as per the European catalogue. Next, you will find the wording “Physical state”, in which you will have to indicate whether the waste is powdery solid, non-dusty solid, sludge shovelable or liquid. Under “Hazard class”, you must indicate the hazard class(s) (HP) corresponding to the waste.
THIRD COLUMN: (Quantity): enter the quantity in Kg, Lt or mc. (It is recommended in Kg as the data must be grouped in the MUD which provides only the weight as a unit of measurement).
FOURTH COLUMN and FIFTH COLUMN: Data relating to the origin of the waste and the intermediary or trader. Annotations: Report any additional information.
As for the compilation of the Discharge, this is the correct method:
FIRST COLUMN: (type of operation Unloading-Loading): Tick the Unloading box. Immediately below the crossed box, enter the date of the unloading operation (which coincides with the date of the start of transport) and the number of the operation. Here too, the numbering is always progressive. Under “Form”: enter the number and date of the Form, while under “Ref. loading operations”, it is necessary to report the register number referring to the loading operation of the same waste. Clearly, there can be multiple loading operations for a single unloading.
SECOND COLUMN: (Waste characteristics): enter the CER code that identifies the product category. Under “Description”: indicate the description of the waste as per the European catalogue. “Physical state”: indicate the physical state of the waste (as done above). In the “hazard class” section: indicate the hazard class(s) (HP) corresponding to the waste. Under the heading “Refusal intended for”: report the data indicated in the Form (R or D).
THIRD COLUMN: (Quantity): enter the quantity of the Waste delivered to the transporter and indicated in the form
FOURTH COLUMN: “Intermediary/Trader”: enter it only if expressly indicated in the form.
FIFTH COLUMN: The “Annotations” section: Report any additional information that may be considered useful.
Very often, the difficulty of compiling these documents lies in the categorization of the waste itself and in the identification of the percentages of substances (identified by the reference legislation), harmful or toxic. In the event that you do not know how to identify, it is good not to rely on approximation and contact a company such as Eurocorporation, capable of carrying out sampling and analysis of substances, at the end of which a categorization sheet will be issued and all the necessary information for the future management of that type of waste.
N.B. It should be remembered that the loading/unloading register, before its use, must be endorsed by the competent Chamber of Commerce and that for the management of waste of medical origin, it is necessary to comply with the specific provisions of the reference legislation.
