By 29th February 2012, all Technically Competent managers running a waste facility that is permitted by the Environment Agency (EA) who have previously relied on a pre-2009 Cetificate of Technical Competence (COTC), were deemed competent or were assessed by the Environment Agency (EA) must show that they have kept their industry knowledge up to date.
To do this, they must take and pass a Continuing Competence test, which are managed by the Waste Management Industry and Training Board (WAMITAB).
But, according to CIWM, an assessment of the current situation has indicated that there could be a significant shortfall in the number of people who have taken the test compared to the number of sites. This shortfall could be as much as 75% for some types of facilities, it claims.
If site operators fail to take action by the deadline, the EA will no longer accept them as technically competent. This could result in some sites being unable to operate legally under their permit or having to make special arrangements to show that they are being managed by people who are still technically competent, according to CIWM.
Compliance
The EA confirmed last month that it is stepping up its compliance activity in this area.
Steve Eland, the EAs environment & business senior advisor, said: We are concerned at the low level of take up of the continuing competence test. As a result we are now stepping up our compliance activity to monitor uptake by operators.We will provide operators with advice and guidance on how to comply and will take enforcement action against those who are unwilling to comply with the requirements by 29th February 2012.
“Enforcement action can range from service of an enforcement notice to revocation of the permit.Any action we take in the event of non-compliance will depend on the circumstances in accordance with our Enforcement & Sanctions Position.
CIWM and other sector bodies are urging those who have yet to take the test to book a place now, while there is still availability.
Steve Lee, CIWM chief executive, said: There is no excuse for anyone to miss the deadline; the half-hour test can be booked in advance through WAMITAB and there are test centres across the UK. This sector has worked hard to improve its professionalism and image and should not be let down by those who are willing to risk criminal proceedings rather than demonstrate that they have kept their knowledge up to date.
Speaking for the metals sector, Howard Bluck, head of environment at British Metals Recycling Association (BMRA), said: Since January 2011, we have repeatedly reminded BMRA members that require an operator competence assessment to make the necessary preparations in good time and not leave things to the last minute. Also we have developed a refresher training course to help candidates ready themselves for the assessments.
“Despite this, we remain concerned that come the 29th February 2012, there will be a significant number of operators across the metals recycling sector who have failed to meet their competence obligations. We believe the Agency must take robust action against them; only a strong enforcement policy will help maintain the credibility of the competence scheme and demonstrate that free-loaders will not be tolerated.
More information can be found here.
Subscribe for free