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.
ENVIRONMENTAL
01606 558833 |
marco@oaktree-environmental.co.uk Twitter @wastechat
The point of no return
IT’S here: the dreaded new waste return form which includes questions relating to the Technically Competent Manager (TCM) for your permitted site. Yes, anyone having to complete a Q2 (April to June) 2019 return now has to provide additional details to their regulator when they submit their return.
Curiously, the Environment Agency and Natural Resources Wales have opted for slightly different approaches for sites that follow the WAMITAB/CIWM scheme.
What are they actually asking for?
For England, a separate tab on the spreadsheet asks for the following for each TCM:
• The name of all TCMs used • Their date of birth
For Wales a new Section 2.5 on the site information tab asks for:
• Certificate number • The name of principal TCM • Expiry date of continuing competence
Scotland and Northern Ireland have not followed suit yet.
On an unrelated note, I liked that Northern Ireland have an interesting six- digit end-of-waste-product code guide which enables reporting of non-waste products leaving the site, which balances the books more effectively.
It makes sense from a regulator’s point of view to ask for the expiry date for continuing competence, but both could have gone further and asked for the actual primary award held by the TCM and the activity specific test undertaken.
It would be nice if either regulator had written to sites for which they had received returns and told them which qualification applies to their site and which continuing competence test to do
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to remain compliant. This could easily have been made part of the inspection regime and entered on the CAR form for the sites, which would have eased the situation we will find ourselves in when the returns are collated i.e. hundreds of sites will be non-compliant for the following reasons:
• TCM covering too many sites and therefore not spending sufficient time on site;
• TCM does not hold the correct qualification for the site;
• TCM has not completed the continuing competence test i.e. certificate is out of date;
• TCM has completed the wrong continuing competence test;
• TCM does not actually visit the site but the certificate is being used with or without permission.
The returns ask for less information than the revised permit application forms. Surely the information provided in the returns and applications should be consistent? What is clear is that the regulators will have a huge task collating and checking the data in the format requested and initial feedback from some inspecting officers is that they are not in a rush to take enforcement action as they want to assess the overall situation first.
If you have any issues relating to this article I will cover them in a FAQ article in September.
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