BSD (Waste Tracking Form): what the project manager needs to know to avoid letting polluted soil leave without traceability — and risk criminal liability
“Supply BSD follow-up at the end of removals” — ACTION status. Behind this line at the end of the earthworks section lies a regulatory obligation whose breach can mean a €75,000 fine and 2 years’ imprisonment for the producing contractor, and can implicate the MOE who let the removal happen with no document.
Type | Phase | Actors | Impact | Stakes | Where |
|---|---|---|---|---|---|
Document | Execution | Contractor, MOE (project manager), OPC (scheduling coordinator), Client (MO) | High | regulatory | earthworks / waste-handling section of the CR |
1. Operational definition + common mistake
The Bordereau de Suivi des Déchets (BSD, “Waste Tracking Form”) is the regulatory document that accompanies and traces the transport of hazardous waste from its producer (the works contractor) to an approved treatment facility. For soil polluted with hydrocarbons or other substances classified as hazardous, the BSD is mandatory: it’s drawn up by the waste producer, signed by the carrier and the destination facility, and kept by all parties for 5 years (3 years for the carrier).
In this CR, the discovery of hydrocarbon-polluted soil during earthworks led to the removal of roughly 150 m³ of soil to a treatment facility. The MOE requires BSD follow-up as an ACTION item once removals are complete.
Many assume BSDs are just an administrative formality between the contractor and the carrier — in reality, the MOE is responsible for making sure the hazardous waste was actually tracked and sent to an approved facility. Without a BSD, the MOE cannot prove that disposal was compliant, which is a liability risk if pollution is later confirmed or an inspection takes place.
2. Where it appears
In a site meeting report — in the earthworks or waste section, particularly following the accidental discovery of polluted soil or the removal of materials classified as hazardous. The note can take the form: “Supply BSD,” “BSD follow-up to be sent.” In this CR:
“8/04/26: The contractor encountered a zone of soil apparently polluted with hydrocarbons. An assessment is underway via the engineering firm I3D.”
“15/04/26: The final pollution report has been submitted. The costing is approved. It calls for the removal of the polluted soil.”
“22/04/26: The polluted soil has been removed.”
“29/04/26: Supply BSD follow-up at the end of removals” — Obs.: ACTION
3. How to read this entry in the CR
If you read “Supply BSD” or “BSD follow-up” as an ACTION → ask the contractor for the original forms (or their Trackdéchets copies) for each load removed. Check that the destination facility is actually an approved regulated installation (ICPE) for this type of waste.
If the BSDs aren’t supplied within the deadline → escalate to REMINDER and inform the client: without BSDs, regulatory traceability is broken.
If the pollution discovery is new → report it to the client immediately, mobilize a specialist consultancy for diagnosis, and don’t remove the soil before you have the exact waste classification and an identified approved facility.
4. Who does what
Actor | What BSD means to them | Concrete action |
|---|---|---|
Earthworks contractor | Regulatory traceability obligation | Draw up a BSD per load; have it signed by the carrier and the facility; hand copies to the MOE |
MOE / OPC | Environmental compliance control | Require BSDs via ACTION; archive the copies; alert the client if missing |
Client (MO) | Ultimate responsibility for disposal | Ensure via the MOE that all BSDs are collected; keep the archive for 5 years |
Diagnostic consultancy | Pollution classification | Identify the nature and hazard class of the waste; approve the treatment facility |
5. What this changes in practice
A project manager who requires and archives BSDs can show at any time that polluted soil was properly disposed of through an approved facility. A project manager who allows soil to be removed without BSDs risks being unable to prove disposal compliance, which can trigger an environmental investigation if pollution migrates or an inspection occurs.
Failure scenario: the 150 m³ of polluted soil is removed with no BSD. Six months later, the regulated-installations inspectorate finds the soil was dumped at a landfill not approved for hazardous waste. Without BSDs, neither the contractor nor the MOE can prove traceability: both are implicated.
6. Example of real wording
“The polluted soil has been removed” — Obs.: PI
“Supply BSD follow-up at the end of removals” — Obs.: ACTION
7. Points of caution
A BSD is per load, not per project: each truck must have its own form.
A BSD is only valid if the destination facility is approved (ICPE) for that type of waste.
Digital tracking via Trackdéchets has been mandatory for certain hazardous-waste categories since January 1, 2022: paper copies alone are no longer sufficient in every case.
A BSD signed only by the carrier doesn’t close the chain: the destination facility must also acknowledge receipt.
The accidental discovery of polluted soil doesn’t suspend the BSD obligation: as soon as it’s identified, traceability must be in place before the first removal.
8. Not to be confused with
Related term | Key difference |
|---|---|
Bon de décharge (disposal slip) | Internal tracking document for non-hazardous waste removals — less demanding than a BSD |
BSDA | BSD specific to asbestos — distinct procedure and facilities |
Trackdéchets | Digital platform for BSD dematerialization — not a document in itself |
Pollution diagnostic | Prior study that classifies the pollution — the BSD is the traceability of the disposal |
9. Related terms
Same phase (earthworks/waste): Bon de décharge · Soil pollution · BRH · Hazardous waste · Trackdéchets
Same actor (MOE/contractor): ACTION · PM · Waste management plan · SOGED
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