embrace it and seek to deliver the best resource and environmental outcomes the better. Delivering sound outcomes will increasingly rely on true partnership with acceptance about our relative strengths and weaknesses and limitations to act. T is means sharing technical knowledge and data, intelligence and feedback loops. T at is why working in conjunction with UROC and other professional organisations, such as CIWM, is more important than ever.


Looking ahead, the focus on waste crime and entrenched poor performance needs to continue while there remains an incentive for producers and others to avoid costs or make money from by- passing the system. We have more waste ‘leaking’ out of the system with fl y-tipping on the rise again, or abandoned or hidden in bales or exported to be burned on beaches in foreign lands. T e latest fi gures estimate waste crime is costing the UK economy £604m per annum.


I fi rmly believe there is a lot more that can and should be done within our current legislative system to tackle waste crime and entrenched poor performance.


were 584 poorly performing permitted sites, 217 of which have been poor performers for more than two years, with 77% of pollution incidents occurring at sites categorised as poor performers.


Increasing compliance eff ort should pay big dividends and should be risk-based and targeted at entrenched poor performers rather than compliant operators. Importantly the costs of doing so can be recovered through fees and charges so that the polluter pays. T e more we do this the more we can prevent crime rather than tackle it aſt erwards.


“I fi rmly believe there is a


lot more that can and should be done within our current legislative system to tackle


Firstly, we must continue the move towards tougher and speedier enforcement action against those who deliberately fl out the law, including illegal sites operators, those who use exemptions as a cover for illegal activity, fl y-tippers and others who abandon waste sites, those who deliberately mis-describe their waste or pass it off as non-waste or otherwise breach their Duty of Care obligations. If the right people are targeted, we should remove their ability to operate. T ere is clearly a role for the industry to help inform and educate the 5.4 million private businesses in the UK that are subject to the Duty of Care to do the right thing and in so doing enhance their communities, reputation and business opportunities.


Secondly, we should make more use of existing permitting rules and site compliance and inspection to prevent poor standards of operation from becoming entrenched, such as ensuring the presence of technically competent management. In 2014 there


waste crime and entrenched poor performance.”


T irdly, there are or will be limited opportunities for legislative change in the short term. It remains to be seen whether HMRC’s proposals to apply landfi ll tax to illegally abandoned waste at sites will assist when it comes in next year. We still need to identify and track down the culprits. We are anticipating a Defra consultation on better enshrining the operator competence provisions in legislation, but changes will only be meaningful if they are enforced and if those providing the technically competent management are held more accountable for their acts or omissions. Here is another area where industry could be


at the forefront of enhancing professionalism in the regulated sector.


T ere are many other ideas that have been promulgated, such as overhauling the registration of carriers, brokers and dealers and the producer responsibility legislation and tightening up or removing exemptions. However, government resources are focussed on Brexit so there may be limited scope for change in the shorter term. Once we leave Europe the process of deciding which controls to keep and which to change or remove will begin. Post Brexit, I foresee some challenges to retain the controls most will agree are important, but also some opportunities to lighten the regulatory load on others.


So, if you get the chance to talk to ROJ please tell him what is wrong, but also how it could be improved if we worked better together. Many of us will be listening.


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