Environment Agency to consult further on TCM attendance times

A consultation on changes to the attendance requirements for technical competent managers (TCMs) on waste sites found most respondents “generally agreed” new guidance was needed.

The Environment Agency requires that some waste operations have nominated TCMs on site for a specified amount of time each week (picture: Shutterstock)

The Environment Agency ran its online consultation for eight weeks from 14 June to 9 August 2021 (see letsrecycle.com story) before publishing the results on Friday (21 January).

The consultation received 75 responses, of which 32 came from site operators and companies with permits, 18 from trade associations and other organisations and groups, 12 from consultants, five from local authorities, and eight from individuals and members of the public.

Respondents included the Chartered Institution of Wastes Management (CIWM), the Environmental Services Association, and the Wood Recyclers Association, among others.

The Agency says “many” respondents highlighted the potential for “environmental benefits” should TCM attendance increase at poor performing sites.

However, the environmental regulator says the extent of this benefit would depend on the “specific circumstances”.

Approximately 75% of respondents supported the adjustment of the attendance requirement based on operator performance, the Agency says, with those in deteriorating or poor compliance bands requiring increased TCM attendance.

The Agency says the responses to this consultation will help shape a second, “more detailed” one.

The environmental regulator aims to publish the next consultation in the summer.


Operators who apply for an environmental permit for a waste operation must be members of a government-approved technical competency scheme.

Most existing waste environmental permit holders must also comply with a government-approved technical competency scheme through the conditions in their permits.

For operators that show competence through the scheme run by the CIWM and Waste Management Industry Training and Advisory Board, the Environment Agency requires that sites have nominated TCMs on site for a specified amount of time each week. This is called the attendance requirement.

Related link
Environmental permit competence requirements: changes to technically competent manager attendance

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