Chemical waste for multi-academy trusts

The chemicals themselves are no different from those in a single school. What changes is the spread. One secondary may hold four hundred containers while a small all-through school holds sixty, and a sixth form centre may hold organic reagents nobody else in the group uses. We work from a list per school, so each site can be priced, packed and documented without the others holding it up.

Stock that cannot be priced from a list stays out of the shared plan. Dried picric acid and other unstable stock, explosives, radioactive sources, compressed gas cylinders, asbestos and controlled drugs go to a manual enquiry at the school concerned. Some trusts hold an explosives certificate that covers all their schools, as the DfE guidance notes, so your central team may already know which sites have relevant stock.

• a list of schools with postcodes, and which ones have a science store
• the name of the lead technician or responsible person at each school
• the latest stock list for each site, in whatever layout it exists
• any school with known concerns, such as old alkali metals or unidentified bottles
• term dates for each school, if they differ across the trust
• your purchase order route and the budget split you want on the invoice

Local variation is normal. A trust formed by merging two groups may have one store in immaculate order next to another with no list at all, and the plan should allow for that from the start.

This is the point trusts most often misjudge. A trust is one organisation, but hazardous waste is controlled by the place it leaves. Each school needs its own note, with its own code and its own address in Part A, and in England a note's code can only be used once from that address.

There is one useful exception to the idea of separate journeys. Under the GOV.UK consignment note guidance, a multiple collection is hazardous waste collected from two or more premises, on a single journey, by one carrier, going to one consignee. Each note then carries a shared round number and a collection number. Neighbouring schools in a trust can sometimes fit this pattern, but it depends on the carrier and the waste, and it does not remove the note for any school.

It looks tidy on paper: bring the waste from five schools to the largest prep room, then book one visit. We advise against it. The same guidance says a consignment note is needed for movements from one premises to another within the same business. A van from the estates team carrying old reagents between schools would be moving hazardous waste as a carrier, with the registration and record duties that follow, and unstable or poorly closed bottles should not travel at all without assessment.

The receiving school also inherits a storage and security problem that it did not have before. Its inventory no longer tells the fire service what is really in the store.

Usable stock is a different matter. A trust can do a great deal of good by moving sound, identified chemicals to a school that will use them, before they are ever listed as waste. Central purchasing helps here, because the trust can see that one school is about to buy what another is about to discard.

Most trust audits fail because they ask technicians for a format they do not use. We suggest agreeing a small set of fields and applying them everywhere: chemical name, quantity, container count, room, date opened if known, condition, and whether the department still wants it. A shared layout matters more than a shared tool. It lets the central team compare schools and spot the store with no opened dates at all, which is usually the store needing attention first.

Sequence the audit by risk, not by geography. Start with the sites that have lost a technician or merged departments, or those that have not had a clearance in living memory. Those stores usually hold the older stock, and a chemical store assessment may be a better first step than a list.

Technicians shared between schools need particular care. A person covering three prep rooms cannot hold every store in their head, and the written list is what survives when they leave. Our register gives the trust one view across schools with each site's stock kept separate, although a consistent spreadsheet does the same core job if that is what you have.

Trust finance teams generally want a single purchase order and one invoice, while each school's budget holder wants to see what their department cost. Our invoice is raised against a purchase order and paid by BACS, with lines split by school. There are no card payments to reconcile.

The legal record stays with the school. In England, the register of consignment notes and consignee returns must be kept for three years at the premises that produced the waste. Many trusts also keep a central copy, which is sensible, but a central folder alone does not meet that requirement. If a school later leaves the trust, its waste history should go with it.

A trust with schools in both England and Wales runs two sets of rules. Natural Resources Wales requires premises producing or storing over 500kg of hazardous waste a year to register, and allows several sites in one organisation to be registered in bulk. The Welsh consignment code also has a different format, so a template built for an English school will not carry over.

Trust boards rarely need the chemical list. They need to know which schools have an up-to-date inventory, when each store was last audited, what has been removed and what is still waiting on a decision. The waste duty of care code of practice applies to anyone who produces or holds waste, and it expects you to check that those you pass waste to are authorised. Keep that evidence with the job file, because it is the first thing a new estates lead will ask for.