WASTE RECYCLING
MARCO MUIA BSc (Hons) MSc MCIWM, Managing Director
at Oaktree Environmental Limited. Marco specialises in all aspects of waste planning and regulation consultancy. He also holds the level 4 COTCs for Hazardous Waste Treatment and Transfer.
01606 558833 |
marco@oaktree-environmental.co.uk Twitter @wastechat.
Business Clinic
ENVIRONMENTAL
COVID-19 position statements
DURING these difficult times, some flexibility is clearly needed with regard to the regulation of permitted sites and it is no surprise that the Environment Agency (EA) and other regulators have produced a number of Regulatory Posi- tion Statements (RPS).
I will concentrate on the EA positions (12 currently) which are available HERE, which will expire on 30 June 2020 unless the date is extended.
It should not be a surprise that there are no Get Out Of Jail cards here and most of the concessions for transfer stations relate to monitoring, recording and reporting as you will still be expected to comply with the other conditions of your permit, unless another COVID-19 RPS applies. Your activities should not cause environmental pollution or harm human health.
I have to say that some parts of the statements are vague and confusing so, if you do need clarification, obtain expert advice or contact the EA (preferably your inspecting officer) to discuss compliance with conditions. Several of the statements
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require agreement from the EA in any event.
RPS C10 covers reporting for waste sites including keeping records about staff absences, contractors being unavailable and supply chain failures but does not go into detail about what the actual enforcement response will be if you have those problems - just that the EA will not normally take enforcement action if you comply with the RPS. It states that the EA “will monitor how operators use and comply with this COVID-19 RPS through its proportionate, risk-based inspection and monitoring activity”. Given that CAR forms are part of that risk-based system, it doesn’t fill me with confidence as every area has a differing approach and attitude.
RPS C2 covers exceeding waste storage limits at permitted sites and requires agreement if the waste above the limits in your permit is stored for longer than three months, in which case you must agree an action plan with your inspecting officer. Most of the officers we have dealt with so far have been very cooperative. This RPS has detailed requirements which can’t be
covered here so please check it out as I think it’s the most important one. Many sites already appear to be using it.
Both NRW and the EA have sent question- naires to permitted sites and it should be noted that the requests for a response are not a formal legal notice, but it may be useful to respond if it suits your circum- stances.
Other ‘normal’ RPS are available HERE and the EA are emailing operators about other changes, including extending the dead- line for submission of Q1 waste returns to 31 May.
Natural Resources Wales, the Scottish Environment Protection Agency and the Northern Ireland EA all have made it easier to check what guidance has changed as the result of the pandemic, with a link to their COVID-19 approach on their website home page.
Keep checking the web site as these state- ments are likely to be updated. Stay safe.
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