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.


ENVIRONMENTAL


More evidence, please


WE are approaching a period of intense focus on technical competence at permitted sites by our regulators in England and Wales, their attention being targeted at those that do not have a suitable technically qualified manager (TCM).


It may also be that the site manager(s) have not yet gained their qualification which, for most, is either a WAMITAB Operator Competence Scheme qualification for medium and high-risk sites or a CIWM EPOC (Environmental Permitting Operator’s Certificate) for low-risk sites.


To operate a permitted


waste site there are many documents that you need to be familiar with as a site manager.


I covered this issue a few months ago and know from experience that a significant number of sites are not complying with the above requirement and could be subject to enforcement action for non- compliance.


Low-risk sites can solve the problem by putting managers through the EPOC


50


course, which will be quicker than doing the equivalent WAMITAB qualification for many sites. This is because, whilst many sites have experienced staff, getting them through their qualification is not always straightforward. This can be because of a lack of operational evidence for the portfolio that candidates must provide.


• Environmental Permit and waste returns;


• Environmental Management System and Fire Prevention Plan;


• Planning Permission; • Health and Safety Policy / Site Rules;


• Risk Assessments – Health and Safety and Environmental;


• Waste Carrier Certificates and system for checking the public register for other carriers, permits and exemptions;


• Incoming/Outgoing Transfer Notes Waste Records;


This shortfall is the cause for greatest concern because not having the evidence is often due to a lack of implementation of systems - such as an environmental management systems and health and safety management systems - that should otherwise be in place or non-compliance with systems that are in place. Putting those systems in place has the knock-on effect of not only being compliant with legislation but also providing learners with a body of evidence they can use.


There’s not sufficient room to cover portfolio building in this article but below is the essential list of evidence to get some way through the assessment process. To operate a permitted waste site there are many documents that you need to be familiar with as a site manager and reliance on paper or electronic records is necessary to be able to demonstrate compliance. These are not in order of preference but should provide you with an understanding of what is required.


• Rejected/Quarantined Waste records;


• Daily Site Inspection Records/Site Diary – Demonstrating environmental and health and safety compliance;


• Vehicle and equipment inspection and maintenance records;


• Regulator inspection forms and associated correspondence;


• Staff Training records – Induction, toolbox talks, formal training;


• Records of accidents, incidents, complaints, etc.


The main thread of the evidence is that it demonstrates that you as the candidate manage the site. Don’t wait for the regulator to come knocking and have a look at WAMITAB’s website if you haven’t already started a qualification that you need.


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