EA carrying out audits on waste carriers


The UK carrier/broker/dealer (CBD) registration process has long been recognised as being extremely weak. For £154, virtually anyone can register as has been previously demonstrated when Eunomia registered their dog. The only criteria is that the person registering should not have been convicted of an environmental offence. There are no background checks, no checks on the operator's knowledge of duty of care, whether they have a suitable vehicle for carrying waste or whether they even have the ability to understand and complete a waste transfer note. Registration is therefore no barrier to illegal activity but so long as you have one, you can carry, broker or deal virtually any waste including hazardous materials.

The past has seen little scrutiny of registered operators with only reactive checks made in the event of a problem or - as widely publicised by the EA - when they have joint operations with the police setting up check points looking for unregistered carriers. But to the best of our knowledge, the Agency has never proactively checked operator competence, knowledge and compliance. Until now, it seems.....

A regional officer has recently sent out the email below to a registered waste carrier along with this audit form.  It would be interesting to see how many waste carriers could answer all the questions.........

EA email

Waste (England and Wales) Regulations 2011, Regulation 34 - inspection of registered waste carriers, brokers and dealers

As a registered carrier/broker/dealer of waste you have certain responsibilities concerning the way you carry, keep, handle, transfer and dispose of that waste.

This email is to advise you that we intend to audit your companies activities under the CBD License.

I would like to complete this audit via video call (MS Teams) on 14/09/2021 at 13:00.

If this is not possible then please advise ideally another time that day, or another day and time when this audit could be completed.

The aim of the audit is to provide you with advice and guidance on, as well as assess your degree of compliance with, legislation that applies to you as a carrier/broker/dealer of waste.

We will inspect information and records for waste movements you have transported, arranged or are in control of so please make sure they are available.

Documents required include:

  • Example Waste Transfer Notes (Producer to Carrier, and, Carrier to Site)
  • Records of Waste Transported (Including totals for 2020)
  • Operating procedures (carrier focused)

If the person normally responsible for management of these activities will not be present on the day of our visit, it would be helpful if the information and documents are made available in their absence.

The audit will focus around the attached form.

If you have any queries about this audit, please contact myself via the information below.


Environment Officer | Ipswich Waste Team | East Anglia Area

Environment Agency | Iceni House, Cobham Road, Ipswich, IP3 9JD