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.
Fill that diary! 2
MANY of you will have systems in place to ensure that vehicles and plant are serviced on time i.e. in a diary, wall planner or computer-based system, which easily demonstrates to regulators that you have an interest in compliance. I see these systems working every week when assessing candidates for their WAMITAB qualifications throughout England and Wales but cannot say the same for similar systems that could be put in place for environmental management.
There are a number of key events that should be in every diary or planner, so why not use your planner or other system to provide a reminder? The list below is not exhaustive or in order of importance so I urge you to make a full list of the items that apply to your operations as failure to comply in most cases is a criminal offence.
1
Waste carrier, broker and dealer registrations need to be renewed every three years. The expiry date is on the certificate. Submit your application
50
before the deadline to ensure that it does not lapse.
Exemption registrations also need to be renewed every three years.
3 4 5
6
Scrap Metal Dealers Act registrations need to be renewed with your local council every three years.
Hazardous waste producer registrations still apply in Wales and are renewable on an annual basis.
Permits do not require renewal but often have a number of reporting requirements. Waste returns are often treated as a chore to get out of the way but incorrect reporting is an offence so, to ensure that the returns are accurate, ensure that you collate records early and don’t submit on the last day in case there is a problem.
Hazardous waste consignee returns are often late or overlooked, especially for waste taken to exempt sites. The returns are required if you accept hazardous waste at your site.
7
Do you have monitoring conditions in your permit that require sampling,
testing, etc? Test certificates for plant and equipment under PUWER i.e. PAT testing, LOLER certificates etc.
8 9
Does your EMS or other site documentation need a formal review annually or over another period?
Do your daily, weekly or monthly checks and record them in your site diary or other system you have agreed with the regulator.
10 11
Transfer notes. Use season tickets for regular contracts and try to have a renewal date for batches of transactions so that they can be renewed easily before expiry.
WAMITAB qualification Continuing Competence requires renewing every two years. Book your test with a few weeks to spare so that in the unfortunate (hopefully unlikely) event of failure you can resit the test. Missing the test means that your qualification is not current.
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