However, the Agency has warned that it cannot carry out many inspections as the £154 fee it charges for registration is insufficient to fund auditing of every waste carrier.
The audits see carriers registered under the carrier, broker and dealer (CBD) system checked for competence, knowledge and compliance.
An example of a video audit with accompanying paperwork has emerged in Ipswich, Suffolk. It is thought to be one of the first times the Agency has carried out more detailed checks on the CBD system in this way. The system has faced criticism for being too lax in terms of registration and monitoring.
In the Ipswich example, an Agency officer emailed the registered waste carrier to tell them it intended “to audit your companies activities under the CBD License” via a video call.
Responses
The audit, which is to take place on 14 September, is to focus on the waste carrier’s responses to an audit form, the Agency officer said in the email to the carrier.
Alongside notification of the video audit, the Environment Agency also sent the registered waste carrier an audit form.
Waste sector expert Phil Conran OBE, a consultant at 360 Environmental, said the audit approach is “potentially hugely significant”.
This is potentially hugely significant because people are registered with virtually no checks carried out
– Phil Conran OBE, 360 Environmental
The form sent to the Ipswich carrier looks to ascertain the origin, nature, quantity and destination of the waste dealt with by the carrier, as well as how they fulfil their duty of care responsibilities.
It asks questions such as which types of waste the carrier transported in the past year, how much, and where it came from. It also asks what checks are made before arranging for the collection, transport, disposal or recovery of non-hazardous waste.
Format
Explaining the audit process, an Agency spokesperson told letsrecycle.com that “the Environment Officer sent the operator audit questions in advance so the operator could prepare. We undertake waste carrier audits throughout the country every year and the format of these audits can vary based on local circumstances.”
They added: “Each EA area team carries out compliance work according to risk, or to support other compliance and enforcement work.”
It costs £154 to register via the CBD system, with the only disqualifying criteria being that an individual should not have been convicted of an environmental offence.
Auditing will be undertaken according to local priorities and will be risk-based
– Environment Agency spokesperson
With regard to the Ipswich company check, the Agency spokesperson said failure to complete the form would not see registration revoked. Instead, if a company has issues completing the paperwork, the Agency would “assist to remove any barriers” and “request the information in a different way”.
Consultation
The Agency spokesperson told letsrecycle.com it currently had 305,863 active registrations, of which 135,635 are ‘upper tier’ and 170,228 are ‘lower tier’.
A consultation on the registration process is due to be issued later this year, with the Department for Environment, Food and Rural Affairs under pressure to strengthen the carriers regime as part of its work to clamp down on waste crime. The Agency spokesperson told letsrecycle.com the audit had no relation to the consultation and added that the £154 fee was not enough to cover auditing every waste carrier.
They added “The fee covers the registration costs and provides some resource to undertake a relatively small number of audits. Auditing will be undertaken according to local priorities and will be risk-based.”
Notorious
The CBD registration process is notorious for its lack of stringency. In May 2017 Mike Brown, managing director of Eunomia, registered his dog Oscar, a West Highland terrier who died 10 years previously, as a waste carrier without any background checks.
Mr Conran, who is also the former chair of the government’s advisory committee on packaging, welcomed the Environment Agency’s proactive approach.
He told letsrecycle.com: “This is potentially hugely significant because people are registered with virtually no checks carried out. For £154 you’re buying yourself credibility when you actually have no credibility at all.”
He added: “A lot of people have a waste carrier’s licence, and there’s no guarantee that the person collecting waste isn’t carrying out an illegal activity. If someone flashes a badge the public won’t know if people are genuine.”
Mr Conran also said that the Agency’s use of an audit form was to be welcomed and that he had not seen it used before. But, he questioned whether some waste carriers would be able to answer the questions. “Most waste carriers won’t have a clue about whether they’re doing the right thing,” he said.
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