Digital FIR for carriers: what to do from collecting to delivering the waste

Digital FIR: what changes for carriers

The FIR, the waste identification consignment note, continues to serve the same fundamental purpose: documenting the movement of the waste from the place of production or holding to the recipient. With the digital FIR, however, the way the information is created, added, signed and shared changes.

Three parties are mainly involved in the RENTRI operational flow: the producer or holder, who starts the FIR; the carrier, who adds and signs the information relating to the transport; the recipient, who completes the information relating to receipt and returns the completed copy.

The carrier, therefore, does not simply receive a document that is already finalised: it is one of the parties contributing to the creation of the digital FIR.

Before departure: what the carrier must check

One of the worst mistakes is treating the digital FIR as an activity to sort out after departure: checks must start before the vehicle leaves the loading point.

The carrier must check that the FIR is available and review the information needed to carry out the transport correctly. The data to check with particular care include: producer or holder, place of production or holding, waste transported, EWC code, stated quantity, carrier, vehicle used, recipient and place of destination.

This does not mean that the carrier must take the producer's place in classifying the waste, but it should not ignore evident inconsistencies.

• Example: the FIR states one destination facility but the driver is given a different address, or the registration plate shown does not match the vehicle making the collection.
• These are not details to be passed to the office at the end of the day: the situation must be checked before departure.

Who issues the digital FIR?

Normally the process is started by the producer or holder. However, the RENTRI operating procedures also cover situations in which the carrier may be involved in validating and completing the FIR on behalf of the producer/holder, under the conditions provided for.

It is important to distinguish who physically uses the RENTRI software or service from who remains responsible for the information within their own remit: entrusting an operational task to the carrier does not automatically transfer all the producer's responsibilities.

For businesses that make many collections from small producers, this aspect should be governed by a clear company procedure, avoiding informal arrangements that differ for each customer.

At departure: adding data to and signing the FIR

When it takes charge of the waste, the carrier must add the information within its own remit to the FIR. The RENTRI operational flow requires it to add the data at departure, to sign the digital FIR and to be able subsequently to add information relating to events that occurred during transport.

The signature has a substantive function: it links the party to the information entered in the form, so it should not be regarded as a mere technical step.

• Before signing it is worth checking at least: the waste (does it match what is declared?), the producer (am I collecting from the expected party and place?), the carrier (are my company's details correct?), the vehicle (is it the expected and authorised one?), the recipient (is the facility the one I am heading to?), the quantity (is the figure consistent with the load?) and the documentation (is any information missing or inconsistent?).
• This check takes a few minutes and can avoid problems that are far harder to correct after departure.

Do I need a smartphone to transport waste?

The digital FIR does not mean that every driver must become an IT expert. RENTRI provides web services and the RENTRI FIR Digitale app, as well as the option for companies to use their own interoperable management systems.

A transport company with many vehicles might use management software integrated with RENTRI; a smaller business might use the system's services directly. What matters is that the solution works in the reality of daily work: a system that is perfect in the office but unmanageable by the driver during a collection is not a good procedure.

Must the digital FIR physically accompany the vehicle?

“Digital” does not mean that the availability of the form's information can be ignored during transport. The system is designed so that the FIR can be managed and consulted during the different stages of the movement.

The company procedure must ensure that the necessary information is available during the journey and in the event of an inspection. This is one of the reasons why training drivers matters at least as much as configuring the software.

What the carrier must do during the journey

The digital FIR does not necessarily stay unchanged between departure and arrival: the carrier may have to record events occurring during the movement, such as technical stops, transshipments and changes or events provided for by the operating procedures.

The practical rule is simple: if something happens during the journey that changes the relevant information of the movement, do not wait until you are back at base to wonder how to document it. The business should have established in advance whom to contact and which procedure to follow.

Arrival at the facility: is the carrier's work over?

Not yet. At the destination the recipient comes into play, adding the information within its own remit to the digital FIR and signing it: this is the moment when the outcome of the handover is documented.

Depending on the circumstances, the recipient may accept the waste or handle different situations such as partial acceptance or rejection: situations that should not be treated superficially.

Practical case on weight: it is normal for the quantity estimated by the producer not to match the weight determined by the facility; the actual figure is established during the destination operations, and a quantitative difference does not automatically mean that the FIR is wrong. Substantial anomalies that cast doubt on the correspondence between the waste declared and the waste transported are a different matter.

Who returns the completed copy of the digital FIR?

In the digital flow it is the recipient who returns the completed copy of the FIR to the parties involved in the movement: a change worth understanding well for anyone used to the logic of the old fourth copy.

The return takes place through the system provided by RENTRI within two days of taking charge; once it is made available, the parties involved must download it within the periods set by the system.

Digital FIR and transmission to RENTRI: watch out for hazardous waste

One point that causes confusion is the difference between managing a FIR in digital format and transmitting the FIR data to RENTRI: they are not the same thing.

According to the RENTRI operating guidance, transmission of the digital FIR data concerns hazardous waste, in accordance with the obligations provided for the different parties. It should not be assumed that completing the form automatically amounts to fulfilling every transmission obligation.

What happens if RENTRI is not working during transport?

This is the situation that worries drivers most, but the answer is not “the lorry must stop”: specific operating procedures exist for the unavailability of the RENTRI services. It is necessary to understand when the problem arises.

If it is not possible to issue or complete the digital FIR: the unavailability procedures provide for the use of the paper FIR; in this case the carrier returns the completed copy to the producer by direct delivery or PEC.

If the digital FIR has already been issued but cannot be updated during transport: the carrier uses the printout of the digital FIR, updates it with the necessary information and signs it by hand; from that moment the FIR is managed as a paper one under the emergency procedure, and the producer/holder must be informed of the change of method.

If the problem concerns data transmission only: operators carry out the transmission on the first working day after the end of the unavailability event.

So “RENTRI is not working” does not identify a single situation: you need to understand which service is unavailable and at which stage of the movement you are.

Does the driver need to know all these rules?

The driver does not need to become an environmental consultant, but must know what to do in the situations that can realistically arise. An effective procedure for drivers can be very simple.

• Before departure: 1. check that the FIR is available; 2. check the waste, the destination and the transport details; 3. add the data within your own remit; 4. sign according to the company procedure; 5. leave only when the documentation is consistent.
• During the journey: 6. record any events to be documented; 7. if the system is not working, do not improvise: apply the company emergency procedure.
• On arrival: 8. check that the handover is managed correctly by the recipient; 9. report rejections, partial acceptances or other anomalies immediately; 10. make sure the office can verify the return of the completed copy.

Three organisational mistakes to avoid

1. Giving the credentials to everyone without defining roles: having access to the system does not mean knowing which information can or must be entered; clear roles are needed.

2. Training only the office: the FIR is also used when the lorry is far from base; if the driver does not know how to deal with an anomaly, the procedure does not work.

3. Not planning for when the system is unavailable: the emergency procedure must be prepared before the emergency. A one-page operating sheet in the vehicle with essential contacts and instructions can be more useful than a fifty-page manual kept in the office.

Practical example: collection from a construction company

A carrier must collect waste produced during a demolition. The producer prepares the digital FIR; the driver arrives at the site and checks the form, verifying that the producer, the place of collection, the EWC code, the vehicle and the destination facility are correct.

The carrier adds the information within its own remit and signs the FIR. No particular events occur during the journey. On arrival the facility weighs the vehicle, completes the information and signs the form; the recipient makes the completed copy available through the digital flow.

This is the simple case: real company organisation is needed to handle everything that can turn out differently from the simple case.

Digital FIR checklist for carriers

If some answers are “we do not know”, it does not necessarily mean that the company is not compliant, but that the procedure needs to be clarified before the problem arises during a transport.

• We have chosen how to manage the digital FIR: RENTRI services or management software.
• The users are correctly enabled.
• The drivers know how to access the necessary information.
• We have defined who checks the FIR before departure.
• We know how to record events during the journey.
• We know what to do in the event of a rejection.
• We have a procedure for RENTRI unavailability.
• The drivers have a company contact to call if there is a problem.
• The office checks the return of the completed copy.
• We have checked the obligations to transmit data relating to hazardous waste.

Digital FIR: for carriers the problem is not only the software

The move to the digital FIR is often presented as an IT change, but for a transport business it is above all an organisational change. Software, apps and RENTRI are tools.

The real question is whether the producer, the traffic office, the driver and the recipient know what to do when the transport starts, when something changes and when the load arrives at its destination. A simple procedure known to everyone is worth more than a technologically advanced system used badly.