So many sites are not thinking ahead, and with the amendment to the Environmental Permitting Regulations comes in as of April 2019, sites will have to send to the EA information on their technically competent manager (TCM) along with their quarterly waste returns.
This will have a huge impact as the EA will be able to use this data along with having access to the WAMITAB database to check individual’s competencies and continuing competence. They will also be able to identify sites where there is no TCM or sites that are using a TCM who is claiming to cover a number of sites in which it would be impossible to cover correctly which is also a common trend. (tut tut)
Our WAMITAB trainer says “It’s already having an impact as the EA look to target checking TCM certificates and records, and I have had a lot of phone calls in the last two weeks as people have thought their continuing competence test was every 3 or 4 years and the EA quite rightly so will not stand for this and will give them a period to get compliant or action will be taken and people are struggling to book test’s in the time frames which is going to be costly for these individuals who are deemed competent and there is no excuse and ultimately could impact the permit holder / business owner!
Admittedly we do remind our clients but people need to start thinking ahead! PPP springs to mind, and a bit of planning can make for an easy compliant operation, having this old school mentality will result in expense and eventually closure of your business!
Another common trend is people who are providing the TCM cover or competence retiring or leaving the company and they have no plan B and all their eggs are in one basket with one TCM holder who is often employed and not the owner or part of the family and at a time where enforcement is really going to ramp up over the next 6 months to a consistent standard ensuring you have adequate competence within the business is vital and carried out correctly is going to reduce the potential for the regulator to take enforcement action against companies, which will have a direct saving.
They don’t want to spend money on additional qualifications which will improve compliance, safety and improve operational efficiency, but they are happy to pay fines or face prosecution from the HSE and EA for non compliance to then be forced to take the action they could of taken without the fines and prosecution!”
A prosecution also means you won’t manage to keep your Local Authority licensing!
Up and coming WAMITAB Level 4 Certificate in Waste and Resource Management – VRQ Open Course dates
18th to the 22nd of March – Beccles, Suffolk
29th of April to the 3rd of May – Beccles, Suffolk
13th to the 17th of May – Birmingham, Castle Bromwich
24th to the 28th of June – Bristol
15th to the 19th of July – Southampton
If you are a member and want to book these course dates contact us at firstname.lastname@example.org Time is running out.