DON’T LOSE OUT WITH YOUR WASTE MANAGEMENT LICENCE
Waste Licence Limitations
During the current Continuing Competence training program for BVSF members it has become clear that some members have Waste Management Licences (now termed Environmental Permits) that permit the storage and treatment of wastes other than just ELVs. Such Permits often allow the intake of general scrap metals, and some also sanction batteries, oils, timber, plastics and inert wastes etc.
This is seen to be particularly the case where a Permit was issued over 5 years ago.
Permits are extremely valuable documents and are very hard to acquire, and if you are currently dealing only with ELVs you may be inclined to overlook any additional permitted wastes for your site.
However, future changes in economic and commercial circumstances may lead you to seek to take advantage of your broader Permit, and unless you take steps to ensure its continuation in full you may find yourself disbenifited.
Consequently, you need to look closely at the terms and conditions of your Permit, if it provides for more than just ELV treatment, you should ensure that you include all the appropriate ‘Activity Specific’ elements when enrolling for your Continuing Competence Test . That is, you should not only enroll for the ELV activity specific element but also Metal Recycling (MRS), Non-Hazardous Waste Transfer &Treatment and/or Hazardous Waste Transfer &Treatment – as appropriate.
If you do not do this you could lose your currently agreed Technical Competence for the Activities you omit to take. Such competences may be ‘deemed’ or following earlier technical assessments (EA or WAMITAB) and their loss would mean that unless you subsequently replace the lost competency(s) by some other method (likely to be much more expensive and long winded than simply satisfying the Continuing Competence Test!) you would not be able to respond quickly to any changing commercial ambitions.
Level of Site Attendance by the Technically Competent Person(s)
Contrary to popular belief, it is rare for the EA to require the on site attendance of the Technical Competent Person (TCM) for the full duration of the working week.
Attendance is ‘OPRA’ based and subject to EA tables which provide for variations depending upon the nature and scale of the waste management operations. For ELV and MRS sites it is unlikely to require a TCM to spend more than 40% of the working hours of the week at a particular site. Thus, a TCM may look after more than one site, or work away from the site – providing the Site Diary clearly shows his attendance at the appropriate level for that site.
TCM Numbers at a Site
The EA may suspend operations at a waste facility if the TCM attendance level at that facility is less than specified.
Since most TCMs will be on holiday, on a training course or off sick etc for more than one week every year it is highly desirable that each Company ensures it employs at least two EA recognised TCMs. In fact, many firms (including BVSF members) are taking steps to ensure they have at least three TCMs in place in order to further ensure compliance with this key statutory requirement and avoid the possible penalties of non-compliance.
