Waste security – a proposal for regulatory action

Waste security at producer sites is generally poor with waste carts overfilled and lids unlocked, broken or absent lid locks, and often some side waste.

Despite vast sums of money spent on the construct of HTM 07-01 that purports to be a pseudo Code of Practice, many producers still fail to manage their waste properly. Waste carts stored inside open bays, or simply in a distant corner of the car park, are particularly common.

Regulatory action is necessary, and this requires moving outside the confines of a comfortable office to deliver a bit of action instead of the usual huffing and puffing.

Many users cite the high frequency of broken or absent lid locks as the reason for failures in cart security. By contrast,  contractors complain that it is producers who fail to lock carts, or worse that the deliberately damage locks. Either way, this should be subject to regulatory action – a gentle reminder to get locks fixed or replaced may be all that is required though in recalcitrant cases formal action may eventually be required. That will soon feed back to producers, no doubt reinforced by increased or penalty charges, who will face increased charges for waste disposal is the necessary standards are not maintained.

Prompted by a marketing email offering supplies of replacement lid lock keys, it comes to mind that the existing regulatory oversight of contractors could be extended to address the problem of cart lid locking  errors, however they are caused.

  • Contractors having more than 4% of carts having defective or absent lid locks, or carts with defective lids that fail to secure and prevent access to the contents, however that is caused, shall face a statutory penalty.
  • To be fair, this would be qualified with a minimum sample number of 50 carts. But any more than 2 defective carts from a sample of 50 and a penalty shall apply or prosecution if the appropriate legal framework requires this.
  • The same statutory penalty or prosecution shall apply to waste producers having more than 4% of carts with defective or absent lid locks, or defective lids that fail to secure and prevent access to the contents, or carts that are unlocked while in  locations accessible by the public.
  • There will no doubt be a conflict at the point of transfer. That can be remedied by contractors checking for defective carts and fast-tracking them to repair or replacement. For carts that were simply left unlocked, contractors would be expected to lock them before uplift - after all, they will be charged a penalty if transporting or otherwise caught with them while unlocked. In such an event, a supplementary or penalty charge to producers might apply to 'encourage' the producer to perform to a higher standard.
  • Beyond the point of transfer the penalty would fall at the feet of the carrier. It should not matter that the carrier may have picked up carts that were left unlocked by one of their customers - this will create a potent driver to cooperative working to ensure better standards of cart maintenance and security.
  • Within a short time, the system would become self-maintaining; producers would not accept defective carts from contractors, while in their turn contractors would not uplift and transport unlocked or defective carts and instead put some resource to proper cart maintenance.


Though likely to be unpopular, at least initially, this approach will ensure both producers and contractors work together to ensure waste security and the correct use and storage of waste carts. Each will be policing the other to make certain that standards are maintained, and will work together to address and correct any failures at their root.

Of course, it does require that the regulatory agencies get off their butts and do something about it, but the additional effort is minimal. As with so many systems of this lind,  the effort required is likely to lessen substantially over time so lack of resources – so often an excuse for inertia – is no reason not to act.

There is, of course, a downside to all this, that it may be seen and, and be manipluated to create, a cash cow for the regulatory bodies. That must not happen.

We might anticipate that this approach can drive up standards without any real increase in costs. It will certainly encourage cooperative working toward better waste security.

Perhaps in time the regulators will consider this, and quite probably announce it as their own. That isn’t a problem, but remember that you heard it here first.

1 Comment

  1. A good example of this problem came across my desk this morning. Referring to an incident that occurred several months ago, the website http://www.london-se1.co.uk/forum/read/1/129077 records the concern of residents who found first yellow sacks, then smaller bins, and finally a large yellow Eurocart obstructing a pavement in Trinity Street, Southwark SE1.

    There were concerns regarding biosafety, but drugs and sharps are likely to have been present. Obstruction of the pavement seems to have been a hot issue, but for me the greatest and most immediate problem was that the cart was not only unlocked, but had a defectrive or absent lock. The producer, a dentist, claims to have reported the defective lock to the contractor TWICE. Shame on PHS to have delivered a cart in that condition, and yet more shame upon them that it reportedly took not one but two calls to get at least a promise of some action.

    Sadly, I suspect that most though not all other UK contractors would be much the same.


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