When the Environment Agency turns up at your site, it’s rarely some dramatic disaster that gets flagged first. It’s the small stuff. The stuff that was “on the list.” The stuff you meant to sort.
And that’s the problem.
At Envirologistics Consulting, we’ve seen time and time again that the biggest compliance failures start with the smallest oversights. This blog isn’t about scare tactics — it’s a reality check. Most operators aren’t deliberately breaking the rules. They’re just busy. And when things get busy, the basics get missed.
Here’s a checklist of the most common (and avoidable) things we see going wrong — little things that carry big consequences if you don’t stay on top of them
🔍 Small Gaps, Big Risk: The Compliance Checklist
Missing or Expired Duty of Care Paperwork
You need to keep Waste Transfer Notes for at least two years. Simple enough, right?
But here’s the question — can you get to them in two minutes if someone asked?
One company we helped scanned all their notes to a shared server, shredded the paper copies to “save space”… then the users files was deleted. No backup. No records. No proof of compliance.
You can guess how that went down after an EA visit, was requested soon after.
Tip: Digital is fine. Just make sure it’s secure, backed up, and accessible. Or keep the paper as a failsafe.
Fire Prevention Plan Gathering Dust
So, you’ve got an FPP. When did you last read it?
We’ve had sites show us beautifully bound plans from 2019 — and then take us outside to see stacked waste that breaches every fire break in the book.
If the EA asks “how are you implementing this plan?” and you say “uh…” — that’s your permit in trouble.
Tip: Review it, walk the site with it, and make sure the team actually knows what’s in it. this again is one of the EA common things to ask employees about the documents they should have been made aware of,
And these documents can cost a small fortune so Use It,
Daily Site Checks Not Documented
Operators always say, “We do walkarounds every morning.” And we believe you.
But… if it’s not written down? It never happened — at least as far as the regulator’s concerned. not the only regulator to adopt that comment !!
One client was running a tight, clean site. But when a complaint triggered a visit, they had zero inspection records. No logs. Nothing to show they’d been keeping on top of things. They got pulled up despite doing the right thing — because they couldn’t prove it.
Tip: Use a simple checklist. Date it, sign it, keep it in a folder or digital log. That’s all it takes, and don’t forget to log the Weather !! If the odour complaints come in this can be your get out of jail card !
Weighbridge Totals Not Matching EA Returns
It’s easy to miss a decimal or a load when you’re busy. But if your records don’t match what you submit on your quarterly returns, it’s a raised eyebrow for the EA — and it can trigger an investigation.
Even worse? If they find out you didn’t even realise the data was off.
Tip: Have someone double-check returns before they’re submitted. Cross-check with weighbridge data monthly, not just quarterly.
No Visible Site Rules or Safety Signage
Lack of signage isn’t just bad form — it’s a risk.
We’ve seen sites where even the fire assembly point wasn’t marked. Staff didn’t know where to go. Contractors just “followed the others.” It takes minutes to fix — but can land you on a non-conformance report instantly.
Tip: Walk your site like it’s your first day. What’s obvious to you isn’t obvious to new drivers or visitors.
No Staff Training or Induction Records
Training logs are one of the first things the EA or HSE will ask for after an incident. If you can’t produce them — it doesn’t matter how well-trained your team actually is.
Tip: Log inductions, toolbox talks, and refresher sessions. Even a simple spreadsheet will do — just make sure it’s kept up to date.
Unknown or Unclear Permit Conditions
You’d be surprised how many operators haven’t fully read their permit — or don’t know what waste codes are authorised.
This one’s a silent killer. One misclassified load, one wrong storage area, and suddenly you’re looking at a breach. The excuse “we didn’t realise” doesn’t hold up.
Tip: Make your permit usable. Break it down, highlight the limits, and train your team on the key conditions.
Overloaded or Unmarked Storage Bays
Temporary overloads quickly become permanent habits. We’ve seen bays filled past capacity, waste spilling into walkways, and no clear labels. It’s a visual red flag — and a regulatory one too.
Tip: Stick to your limits, keep bays marked, and update your site plan if things change. even if the guidance is 350 cubic meters and no higher than 4 mitres high, If you have a bay that is half that size, that’s your limit, its important to future proof your site,
No Non-Conformance or Incident Log “aka” The Site Diary
No site runs perfectly all the time — and that’s fine. What matters is how you handle it.
If you’re not logging issues (like blocked drains, damaged fencing, or near misses), you’re not showing due diligence. And when something does go wrong, there’s no record of proactive action.
Tip: Keep a basic incident log. Doesn’t have to be fancy — just consistent.
What Now?
If you’ve read this far and thought “yep, we’re slipping on a few of those” — you’re not alone. The good news? These problems are fixable. The bad news? The EA won’t care why they happened — only that they did.
That’s where we come in.
Get Proactive — Not Reactive
At Envirologistics Consulting Ltd, we work with operators across the UK to stop the small stuff turning into big problems. Whether you’ve got a Technically Competent Manager already or you’re running solo — we offer support to fill the gaps and keep you out of hot water.
- Compliance audits
- Waste return reviews
- Daily/weekly inspection templates
- FPP and EMS support
- Permit condition mapping
- Staff training and record-keeping systems
We don’t just keep you compliant — we make it easy to stay that way.
