4. How to use the Record-keeping forms
Keeping records of hazardous waste generation, storage, transportation, treatment, and disposal is important to ensure hazardous waste is properly managed. Businesses benefit by having a clear "audit trail" that can be presented to regulatory authorities, and also by having access to information to help pinpoint waste generation practices. Transporters and treatment and disposal facilities usually keep records on the materials they accept (often through invoices or manifest systems). However, these records are often not to a consistent standard. Standardised record-keeping forms can be used to ensure common understanding in hazardous waste management. Record-keeping information can also feed into regional and national waste minimisation and management programmes and waste statistics.
Under existing legislation, handlers of hazardous substances are often required to maintain consistent records. For example, the Hazardous Substances and New Organisms Act (HSNO) 1996 requires tracking of highly hazardous substances from cradle to grave. The definition of "hazardous substances" in the HSNO Act does not generally include hazardous waste - this is particularly true if the hazardous waste is mixed or of unknown composition.
The Land Transport Rule: Dangerous Goods 1999 requires documentation to be held during transport of dangerous goods specified in NZ Standard 5433:1999 Transport of Dangerous Goods on Land. Similar to the HSNO tracking requirements, this record-keeping system does not require documentation to be kept on hazardous waste transport in most cases; therefore a separate system is required to effectively implement hazardous waste record-keeping.
In this section, we propose a standard record-keeping form to be used by generators, transporters, and treatment and disposal operators dealing with hazardous waste. The form is intended to be a guide to consistent record-keeping, and may be modified to fit within existing invoicing and manifest systems. The required information needed to ensure consistency is indicated and explained in the following pages.
