The purpose of the Compliance Scheme Code of Practice is to apply a benchmark to compliance schemes against which they can assess their operating procedures
Draft Code of Practice
The code has been developed by regulators and representatives from industry sitting on the Agencies and Industry Packaging Operations Liaison Group in a bid to standardise the wide range of approaches currently adopted to meeting regulatory requirements.
It covers everything from ensuring that packaging weight data is as accurate as possible to maintaining a good understanding of the PRN system and a draft version was sent out for producer compliance schemes to comment on in late November.
In an email accompanying the draft, John Turner, chairman of the government's Advisory Committee on Packaging, explained that the code would not be mandatory but that if schemes worked towards it, the Agency would incorporate this into their risk profiling for schemes.
This would mean that they would be subject to a lower level of monitoring, which could ultimately lead to reduced fees, he added. This is expected to be welcomed by both schemes and their members.
He said: “The environment agencies and the ACP are supportive of the concept of a Code of Practice being established for packaging compliance schemes.
“The code is seen as one route for industry to agree on standards which in many cases go beyond or expand the minimum required in the regulations.”
Draft
Mr Turner asked for any comments regarding the first draft to be sent to Defra before December 4 and that a second working draft would then be sent out in later December.
After that, he explained that schemes could decide for 2010 whether and how they intended to work to the Code of Practice and this could either be worked into their Operational Plan or appended to it.
He said: “2010 will then be viewed as a pilot year to review its impacts on both compliance schemes and the agencies.”
The draft code is split into two main areas:
Member information: This includes having systems in place to confirm that data received from each member is accurate and have a system in place of advising and training members on data collection and submission. It also includes thorough compliance monitoring.
Scheme management: This includes PRN and PERN procurement plans which enables alternative sources to be considered if the plans fail due to market conditions, understanding the PRN market and planning for future years.
The document said: “The purpose of the Compliance Scheme Code of Practice is to apply a benchmark to compliance schemes against which they can assess their operating procedures and to give the Agencies a basis against which to assess scheme standards.
“It is intended to provide one mechanism against which the agencies can assess compliance risk and determine appropriate levels of monitoring.”
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