Dental Waste Disposal

Waste transfer notes and hazardous waste consignment notes for dental practices

Updated 6 November 2026 · By the Dental Waste Disposal team

Short answer: Dental practices need a waste transfer note for non-hazardous waste such as offensive tiger-bag waste, kept for at least two years, and a hazardous waste consignment note for each collection of hazardous waste such as amalgam, X-ray chemicals and infectious waste in England and Wales, kept for at least three years. Scotland uses special waste consignment notes and Northern Ireland has its own hazardous waste rules. Digital waste tracking does not yet replace these notes.
Waste transfer notes and hazardous waste consignment notes for dental practices

Why the paperwork matters

Under the Duty of Care in section 34 of the Environmental Protection Act 1990, a practice that produces waste must take reasonable steps to make sure it is stored safely, transferred only to an authorised person, and accurately described. The notes are your evidence. Regulators, and inspectors from the CQC, HIW, Healthcare Improvement Scotland or RQIA, may ask to see them, and missing or inaccurate paperwork is one of the most common waste compliance failings in healthcare.

Which note for which stream

The type of note depends on whether the waste is hazardous. Most dental practices produce both kinds every month, so they need both kinds of paperwork in their records.

Waste streamClassificationPaperworkKeep for
Amalgam and separator wasteHazardousConsignment noteAt least 3 years
Infectious wasteHazardousConsignment noteAt least 3 years
Medicinally contaminated sharpsHazardousConsignment noteAt least 3 years
X-ray fixer and developerHazardousConsignment noteAt least 3 years
Offensive tiger-bag wasteNon-hazardousWaste transfer noteAt least 2 years
Non-cytotoxic medicinesNon-hazardous, incineratedWaste transfer noteAt least 2 years
Gypsum and lead foilsNon-hazardousWaste transfer noteAt least 2 years

This table reflects England and Wales. Some clinical streams are coded and documented differently depending on how they are described, so always follow the classification your contractor confirms on the note.

What a consignment note should show

  • Your practice name and address as the producer
  • Your SIC code, for dental practice activities usually 86.23
  • A clear description of the waste and where it came from
  • The List of Wastes code, such as 18 01 10* for amalgam
  • The quantity and container type
  • The hazardous properties and, where relevant, the UN number for transport
  • The carrier's name and registration number
  • The destination site and its permit details
  • Signatures and dates from you and the carrier

Check each note before signing. If the waste code, description or quantity is wrong, ask for it to be corrected rather than filing it.

Regular collections and season tickets

Most practices have collections on a regular schedule, and the paperwork can reflect that, but the rules differ for hazardous and non-hazardous waste.

For regular non-hazardous collections of the same waste, an annual waste transfer note, often called a season ticket, can cover repeat collections for up to 12 months as long as nothing changes. Hazardous waste needs a consignment note for each movement, although carriers on a collection round can use a multiple collection consignment note that lists several producers on one journey. You still receive your own copy each time. If anything changes, such as the waste type, the carrier or the destination site, a new transfer note is needed, so tell your contractor whenever your services change.

Scotland, Wales and Northern Ireland

  • England and Wales: Hazardous Waste Regulations 2005 and their Welsh equivalent, regulated by the Environment Agency and Natural Resources Wales
  • Scotland: Special Waste Regulations 1996, with special waste consignment notes and SEPA as regulator
  • Northern Ireland: Hazardous Waste Regulations (Northern Ireland) 2005, regulated by the Northern Ireland Environment Agency

The record-keeping principles are the same everywhere: accurate descriptions, the right note for each collection and records kept for the required period.

Digital waste tracking

Mandatory digital waste tracking began on 1 October 2026 in England and Wales, starting with waste receiving sites, which must record each load they receive. Wider phases bringing in other parts of the chain are planned from 2027, and Scotland and Northern Ireland are expected to follow. For now, waste transfer notes and hazardous waste consignment notes are still required alongside the new service, so practices should keep receiving and filing them. Ask your contractor how they will share tracking information with you as later phases begin.

Common paperwork mistakes

  • Notes filed without checking the waste code and description match the container
  • The practice address or SIC code missing or wrong, especially after a move or change of owner
  • Notes signed in blank before the collection
  • Hazardous streams collected on a waste transfer note instead of a consignment note
  • Missing notes for one-off collections such as X-ray chemical clear-outs
  • Notes kept by one staff member who then leaves, with no central file
  • Records thrown away before the minimum retention period ends

Keeping a simple waste file, either a folder or a shared digital folder, with notes filed by month and by stream, makes it easy to spot a missing collection and to answer an inspector's questions quickly.

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