Due to the diverse nature of activities undertaken by Hawthorn Estates Ltd, a wide variety of wastes are produced and collected, ranging from general wastes and recyclable materials, through to special and hazardous wastes. The Company has a duty to ensure that all of these wastes are disposed of responsibly, using approved, registered waste contractors.

This policy sets the framework for all waste management carried out by HE. Detailed, up-to-date information on the correct disposal routes for all waste is contained within our environmental policies and procedures and the individual waste management plans that are prepared for all projects.

Policy Statement

The Company will adopt the principles of the ‘best practicable environmental option’ in the delivery of its waste management services. A Company ‘waste hierarchical approach’ will be applied to reduce, reuse, recycle and recover waste products in preference to the disposal of waste to landfill.

There is a legal requirement for all who produce, keep, or dispose of waste of any type to comply with the assorted regulations and the Duty of Care under Environmental Protection legislation. HE recognises the importance of meeting these legal requirements and to manage its waste responsibly to reduce the volume of waste sent to landfill and maximise the reuse and recycle avenues where possible.

Hawthorn Estates requires all staff and sub-contractors to comply with this Policy, to ensure compliance with all waste legislation.

Under this Policy Statement, Hawthorn Estates Ltd will fulfil the following Policy Objectives.

Policy Objectives

The objectives of this policy are:

  • To ensure the safe handling and storage of wastes at all office locations and construction sites.
  • To promote environmental awareness to increase and encourage waste minimisation, reuse, and recycling.
  • To reduce waste generation at the source and enable repair, reuse, and recycling over the disposal of wastes, where it is cost-effective.
  • To ensure that waste management is performed following all waste legislative requirements, including the duty of care, along with a plan for future legislative changes, and to mitigate their effects.
  • To provide clearly defined roles and responsibilities to identify and coordinate each activity within the waste management chain.
  • To secure where possible returns for recyclable material to reinvest into the expansion of recycling opportunities available to HE.
  • To appoint a competent person(s) to provide waste management advice.
  • To provide appropriate training for staff, sub-contractors, and clients on waste management issues.
  • To promote industry waste management best practice.



This policy applies to all activities undertaken by (or on behalf of) Hawthorn Estates Ltd including its staff, sub-contractors, and clients.

Organisation and Management

The organisational arrangements and responsibilities for this Waste Management Policy are arranged by a variety of personnel within the Company.


Managing Director

The Managing Director is accountable to the Board for the Waste Management and Environmental performance of the Company. In particular, this will require him/her to:

  • Ensure the Company has a comprehensive, up to date Waste Management policy and Environmental policy that meets statutory obligations.
  • Ensure that the policies contain a demonstration of their commitment by the inclusion of a signed and dated Policy Statement.
  • Review the Policies to ensure that they remain comprehensive, relevant, and up to date.
  • Assign duties to key personnel to apply the Policies throughout the Company.


Directors / Heads of Departments

All directors and heads of departments are accountable to the Managing Director for the implementation of this Policy in their respective functions. In particular, this will require them to:

  • Ensure the execution of the Company’s environmental management system and waste management policy.
  • Demonstrate their implementation of the requirements of this Policy
  • Ensure that the personnel under their control are competent and provided with suitable support, supervision, information, instruction and training to execute their work without risk to the environment and abiding by the contents of waste management plans specific to the projects that they work on.
  • Ensure that all activities for which they are responsible, including pre-contract and head office processes, are, where appropriate, subject to the production of a site waste management plan, formal hazard identification and risk assessment.


Personnel Manager

The Personnel Manager is accountable to the Managing Director for implementing the relevant requirements of this Policy. In particular, this will require him to:

  • Monitoring the training needs of employees and communicate this to the Directors.
  • Maintain records of employee environmental and health & safety training,
  • Provide all new employees with a copy of this Policy.


Supervisors and Managers

All managers and supervisors, including Site Managers, are accountable through the recognised chain of management for executing this Policy. In particular, managers and supervisors are required to:

  • Be familiar with and demonstrate their commitment to this Policy and promote continuous waste management performance.
  • Where appropriate activate a formal hazard identification and risk assessment for the activities under their control.
  • Ensure that a project waste management plan is published, maintained, and complied with for their Project and distributed to all relevant parties.
  • Assign specific waste management duties to members of their site management team and subcontractors.
  • Ensure that toxic, noxious, or offensive substance is not discharged into the atmosphere, waterways, or land. In a situation where it does occur employees should be training in the use of Spillage kits.


They will:

  • Consider at time of tender, the information contained in the enquiry related to waste management issues.
  • Consider the possible impacts on the project by current legislation, approved codes of practice and other specific site constraints.


All employees are accountable through the management structure for conforming to the requirements of this policy and of statutory requirements.

In particular, every employee is required to:

  • Be familiar with and implement this policy.
  • Take care and attention of the environment.
  • Co-operate in fulfilling the company’s pursuit of continuous environmental and waste management improvement.
  • Follow the requirements of the project environmental and waste management plan, where applicable.


Glossary of Terms

 Best Practicable Environmental Option (BPEO)

The Best Practicable Environmental Option refers to the assessment of different methods of waste disposal. The preferred option is the one which minimises harm to the environment as a whole, considering what is affordable and practicable.

Clinical Waste

Any waste which consists wholly or partly of:

  • Human or animal tissue.
  • Blood or other body fluids.
  • Drugs or other pharmaceutical products other than controlled or cytotoxic drugs.
  • Swabs or dressings.
  • Syringes, needles, or other sharp instruments. Unless rendered safe may prove hazardous to any person coming into contact with it. It also includes any other waste arising from medical, nursing, dental, veterinary, pharmaceutical or similar practice, investigation, treatment, care, teaching or research, or the collection of blood for transfusion, being waste which may cause infection to any person coming into contact with it.

Environmental Protection Act 1990 (EPA 1990)

This is the single most important piece of environmental legislation and it controls many aspects of how the environment is protected and regulated. The EPA 1990 (amended 1995) provides the main statutory framework concerning waste. The majority of waste leaving the Site is controlled waste. This is described in the EPA 1990 as the waste arising from a household, commercial or industrial premises.

Controlled waste includes waste from offices, food handling, shops, and other domestic activities. EPA 1990 Section 34 imposes a “Duty of Care” on producers and handlers of waste, “to take reasonable measures to prevent the unauthorised deposit, treatment or disposal of waste.” This means the following:

  1. The Site must keep records of how much waste it is generating.
  2. The Site must ensure that a registered carrier collects their waste.
  3. The Site must ensure that all transfer notes are completed and filed detailing the type of waste for disposal. These must be kept for three years.
  4. Ensure that all waste is dealt with in accordance with the “Duty of Care”. Breach of the Duty of Care is a criminal offence and can incur penalties of up to £20,000 or an unlimited fine if convicted on indictment.

Hazardous Waste

These are the most dangerous wastes as they can cause the greatest environmental damage or are dangerous to human health. These wastes are listed in The List of Wastes (England) Regulations 2005. Some common hazardous wastes are listed below:

  • Acids Pesticides Fluorescent Tubes
  • Alkaline Solutions Photographic Chemicals Televisions
  • Batteries Waste Oils Paint
  • Solvents Computer Monitors

Other hazardous wastes, such as asbestos and radioactive substances, are subject to their specific legislation.


The diversion of waste away from landfill or incineration and the reprocessing of those wastes either into the same product or a different one. This mainly includes non-hazardous wastes such as paper, glass, cardboard, plastic, and scrap metal.

Responsible Person

The person who oversees the wastes to be removed from the premises at which it was produced or is being held.


The legal definition of waste comes from Section 75(2) of the Environmental Protection Act 1990 (EPA 1990). It defines waste as any substance or object which the holder discards intend to discard or is required to discard. The EPA 1990 refers to ‘controlled wastes’ which are split into four categories: Household, commercial, industrial and clinical waste. The Site produces waste in all four categories. There is some waste which is exempted as they have their separate legislation e.g. radioactive wastes.

Waste Hierarchy

The hierarchy lists different ways of dealing with waste in order of preference.

  1. Reduce
    Also known as waste minimisation, to reduce the number of waste materials being produced.
  2. Re-use
    To continually re-use an item to eliminate the use of resources in making new items.
  3. Recovery
    Recycling – The collection and reprocessing of wastes either into the same product or a different one. Composting – biological decomposition of organic material to create a soil conditioner. Energy – waste is incinerated, and the heat is recovered to generate energy.
  4. Disposal
    Waste is sent, untreated, to landfill.

Hawthorn Estates may update this policy from time to time.

Copies will be available on our website, in our employee handbook and our ISO 14001/2015 Environment Manual.


Signed by – Kevin Millar

Position – Managing Director

Date – 31st January 2020