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#FindingsFriday: ISO 14001 - Waste Transfer Notes

The Finding

When central heating systems are removed from premises and scrap taken for disposal at scrap metal dealers these are not currently accompanied by a waste transfer note

Some Context to the Finding

Normally in our #FindingsFriday post we reference the actual clause cited by the assessor. However, not all Certification Bodies write their reports in the same way.

The heating and plumbing company being assessed in this example was undergoing a stage one assessment against three different Standards at the same time. They were being assessed against ISO 9001 (quality), ISO 14001 (environmental) and OHSAS 18001 (which has since been supersded by ISO 45001 (health and safety)).

Although the assessor's report did not explicitly refer to ISO 14001, waste is typically regarded as being an environmental issue, hence we've identified that Standard in the title of the report, although, had the company only been working towards ISO 9001, it could arguably have been considered a failing under clause 4.1 of ISO 9001, which requires the organisation to determine internal and external issues relevant to the organisation, and whereby note 2 states that "the external context can be facilitated by considering issues arising from legal, technological, competitive, market, cultural, social and economic environments, whether international, national,regional or local."

Putting ISO 9001 to the side for a moment, and focussing on ISO 14001, there are potentially a number of clauses that could have been cited:

  • Clause 4.1: Understanding the context of the organisation. As above, there is a requirement to determine external issues.

  • Clause 6.1.3: Compliance obligations. This is where the organisation is required to determine what obligations apply, how, and what needs to be done to manage them.

  • Clause 8.1: Operational planning and management. This is probably the clause that would have been cited, as the company had actually identified the relevant legislation and did have processes in place, having had consultancy support. However, it was the actual day to day lack of adherence to the processes that caused an issue.

Action taken to address the finding

As there was a documented process in place, this was a simple case of reminding staff of the process, and the company's legal obligations in relation to retaining waste documentation.

At the Stage 2 assessment, the company was found to be following the process effectively, with plenty of recent examples being well maintained and easily retrievable from the company's server system, and the assessor was therefore confident that they would be retained in accordance with the legal requirement of two years.

Lessons to take from this finding

  1. One non-conformity may actually fall across multiple clauses (and Standards).

  2. It is not enough to document processes and procedures. Staff need to be trained in exactly what they need to do in order to meet the requirements.

  3. Waste transfer notes are legally required when dealing with controlled wastes and must be retained for a period of at least two years.

  4. Storing records electronically helps to increase their accessibility and retrievability.


Waste management is a huge topic, with many pieces of legislation to consider, and there are variations that apply, depending on where your organisation is located. (Scotland, for instance, still has Special Waste, whereas England and Wales have Hazardous Waste streams). If you need help understanding your waste management obligations, you can call us on 029 2070 3328 or email us at


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