Changes to the attendance requirements for technical competent managers (TCMs) on waste sites are being proposed by the Environment Agency, partly with the aim of tackling poorer standard waste and recycling sites.
In a consultation issues this week, Defra is inviting “comments on options for changes to the attendance requirements for technically competent managers (TCMs), on rules associated with the attendance requirements and implementation timescales”.
The consultation – which applies to England – runs until 9 August and is available HERE and is organised by the Agency’s Waste Treatment Team.
Defra points out that operators who apply for an environmental permit for a waste operation must be members of, and comply with, a government approved technical competency scheme. And, most existing permit holders must also comply with such a scheme.
Competence
Defra says that those who show competence through either the Chartered Institution of Wastes Management and its WAMITAB organisation, the competent manager has to be on site for a specific amount of hours each week.
The attendance requirement is currently based on 20% of operational hours for standard rules permits, or for bespoke permits the Operational risk appraisal (OPRA) guidance. However, the OPRA guidance has been withdrawn, except for the sections on attendance requirements for TCMs. Sites are graded according to their performance by CCS banding with A being the best.
Choice
There is another option for competency meaning the CIWM/WAMITAB route is not the only one available, giving industry an alternative choice. This alternative is via the Environmental Services Association and EU Skills approved Operator Competence Scheme. The time requirements do not apply formally to the alternative approvals but the Agency says that “we expect key site personnel to be on site at similar levels of attendance to TCM(s) operating under the WAMITAB/CIWM Operator Competence Scheme. This should be demonstrated through the operator’s management system.”
The Agency says that it has ruled out the option of continuing with the current TCM attendance requirements to simplify the system and make sure that “poor performers receive additional supervision by TCMs to rectify non-compliances and reduce risk”.
New options are suggested for sites which are operating at an A and B level under the OPRA system. These range from requirements linked to a charging band, a standard baseline attendance and tailored baseline attendance.
C-F level
Sites in bands C-F would face a tougher regime under the proposals.
The document says: “Under the current TCM attendance requirements, an operator may agree a reduced TCM attendance with us after the first 6 months of normal operations. If that site is performing poorly the site must revert to the standard attendance requirements.
“This approach is not considered robust enough. We propose that the attendance requirements include additional operational hours attendance at sites in CCS bands C to F.”
“This approach is not considered robust enough. We propose that the attendance requirements include additional operational hours attendance at sites in CCS bands C to F. This would be calculated on the basis of a percentage increase in the attendance requirement, dependent on the compliance band of the site. The attendance requirement would still be limited by the 48 hours per week attendance cap.
“In very exceptional circumstances where the operator has a history of good permit compliance, we may agree in writing to no increase in the attendance requirement. This would include for example where the non-compliance was easily rectified and additional TCM attendance would provide no tangible benefit. The decision to waive the additional attendance requirement would be solely at our discretion.
“We consider the increased requirement for TCM attendance for deteriorating and poor performers will lead to the TCM taking on increased responsibility for improving performance, including the implementation of management systems, operational procedures and staff training.”
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Source: letsrecycle.com Waste Managment
