WASTE RECYCLING ADAM WILSON, Managing Director at Severn Compliance
Adam is a former Envirnoment Agency Waste Officer and a HSEQ Manager for a leading National Plant Hire company. He now helps businesses comply with all aspects of environmental regulations, permitting, pollution prevention and ISO Management Systems
07790 040075 |
adam@severncompliance.co.uk
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RPS C2 and exceeding waste storage limits
AS I write this, my first column, we are into our fourth week of lockdown due to the coronavirus. With many waste companies suspending operations, running restricted services, HWRC’s closed and fly-tipping increasing, there are a number of areas I could focus on. One item that does stand out and is linked to the coronavirus outbreak is the guidance released by the Environ- ment Agency in the form of a number of COVID-19 Regulatory Position State- ments.
The Regulatory Position Statements (RPS) cover a number of areas from Environ- mental Monitoring, the Water Industry and Waste Management. The most relevant of these statements to the skip hire industry is: Exceeding waste stor- age limits at permitted sites because of COVID-19: RPS C2. This statement intends to allow operators of permitted sites to temporarily store more waste than their permit allows if they cannot remove waste from their site because of coronavirus (COVID-19) restrictions. If the conditions in this COVID-19 RPS are followed, operators can exceed waste storage limits without applying for a permit variation.
This statement shows that the Environ- ment Agency are being flexible with op- erators at a time where non-compliance may be unavoidable during the COVID-19 lockdown. So, what does this RPS cover?
This COVID-19 RPS only applies: •
if operator can demonstrate that they need to temporarily store more waste than their permit allows because of coronavirus (COVID-19) restrictions; and
•
to wastes they are authorised to store under their permit.
Operators must be able to demonstrate that they have taken all reasonable steps to comply with their permit. Reasonable steps include:
• •
contingency planning to avoid or minimise disruption to their business because of coronavirus (COVID-19);
coronavirus (COVID-19) response planning to minimise the impact and duration of not being able to comply with their permit or licence;
•
minimising how far they will exceed their waste storage limits.
The RPS goes into further detail about what is expected from the operator and the majority of these items would be covered in an amended Environmental Management System (EMS) and site- based Risk Assessments. This may also affect your Fire Prevention Plan, and if is the case this must be documented.
There are some key areas that must also be adhered to including, only storing waste in the permitted area, keeping the site secure, rotating stored waste and complying with all other conditions of your environmental permit.
So, a sensible approach in unprecedented times. However, operators must do what many fail to do and notify the Environ- ment Agency in writing, in advance of the types and quantities of waste they want to store over their permitted limits. As a former Environment Agency Waste Officer, I would say a large number of non-compli- ance scores come from a failure to notify and make the local officer aware that there is a potential problem.
In my opinion this is a helping hand from the Environment Agency and a sensible approach. But remember, update your records to show the changes, how you will manage the potential increased risk, keep these records for 24 months and notify the Environment Agency that you will be working to the COVID-19 RPS.
All COVID-19 Regulatory Position State- ments are available on the Environment Agency website.
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