WAMITAB Assessor Forum 2013
Standard Rules Permits: Small Company focus on
demonstrating Technical Competence
Presented by Ray Burberry – Qualifications Manager
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Overview
• Presentation is to help Centre’s understand
the stages and requirements for Operators to
meet Technically Competent
Person/Management, TCP/TCM, provision
(England and Wales)
• Centre personnel should be mindful that an
Operator may contact them at any stage.
• Operator knowledge of process may be
minimal
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Topics
• Stages in making an application for a Permit (SR or
Bespoke)
• Operator responsibility to determine type of site and
TCM requirements
• Fit and Proper Person Status
• Type of Site where Competence is required
• Registration Letter supplied by WAMITAB
• Grace Periods and relevance
• Continuing Competence arrangements
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Stages in determining TCM
requirements
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Site acquisition
Planning consents/change of use
Environmental Permit Application
The time at which Operators may contact a Centre
will vary – in early stages of process Operator may
not be aware of TCM requirements
• The Operator must know what waste activity they
are pursuing (obvious! But they may not always be
certain!)
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Standard Rules Permits (SRP)
• These provide a ‘menu’ driven process to identify
routine Permitted facility types
• Environment Agency (and Natural Resources Wales)
specify a range of Permit requirements to
consolidate and provide consistent approach to
applying for a Permit.
• Bespoke Permit applications (i.e. Where a SRP
cannot be directly complied with) can use SRP
competence arrangements in most instances
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Contact with Regulator
• When the Operator makes initial contact with the Regulator
(EA/NRW, Natural Resources Wales), if they are unclear
regarding the requirements for technical competence then
the Regulator is likely to just refer them to WAMITAB
• This is a ‘dangerous’ time as the information provided to the
Operator must be factual, but not such that it removes their
responsibility or implies they should go down a specific
route
• It is the Operator’s responsibility to determine their
competence arrangements specific to the site
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Completing the Permit Application
– Fit and Proper Person
• Part B1 of the SRP Application form covers:
Fit and Proper Person • Previous Offences
• Technical Competence*
• Financial Arrangements
*WAMITAB scheme only affects Technical
Competence
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Technical Competence
• It is imperative that the Operator understands
the type of activity to determine Competence
requirements
• Use of the Risk Tier Table along with
identifying the appropriate SRP from the
Agency listing will assist
• Part B1 of the Application Form determines
each type of Waste Activity
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TCM requirements are not relevant
to all SRP’s
TCM requirements are only appropriate to relevant
WASTE operations; compare:
• SR2008No19 - 250kte Non-Hazardous sludge;
biological, chemical and physical treatment site
• SR2009No4 - Combustion of biogas in engines at a
sewage treatment works
SR2009No4 is not classed as a relevant waste
operation and does not require evidence of a
‘relevant qualification’
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Simple check for Competence
If the Operator is uncertain as to whether
Technical Competence is relevant for a facility:
• Check the General Management Section of
the SRP Section 1.1.4 (if present!), will state:
• The operator shall comply with the
requirements of an approved competence
scheme
• Identify from the Risk Tier Table the relevant
units/qualification required
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WAMITAB ‘Registration Letter’
• The SRP Application Form requires the
Operator to provide a ‘registration letter’
from the Scheme Provider.
• This is a copy of the WAMITAB letter of
confirmation showing the qualification/units
the candidate is registered for.
• Can only be issued when the Centre registers
the Learner with WAMITAB
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New Permits Only – (Not
applicable to Landfill)
• The Operator may take advantage of a 12month period of Exemption (to hold TCM
qualification)
• EPOC – Environmental Permitting Operators
Certificate
• Achieve four (relevant) units of TCM Qual.
• Within 4-weeks of Permit being issued
• Does not cover ‘loss of TCM’
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Point at which Centres become
involved?
• Can be any time!
• Centre (or Assessor) should not guide the Operator
down a path of perceived TCM requirement
• It is the Operator’s responsibility to determine their
own competence requirements
• WAMITAB to help Operator identify questions to
pose to the Regulator for clarification
• Inappropriate guidance could have serious
consequences
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Continuing Competence
• Once Competence has been demonstrated,
the Operator must provide proof of
Continuing Competence at each 2-year period
thereafter
• This will become a ‘Rolling 2-year period’ from
1 March 2014
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Continuing Competence Changes –
What effects will these have?
• Handout on transition to ‘Rolling 2-year period
relates
• Certificates will be ‘date stamped’ with expiry date
• E.g. Certificate issued on 12 April 2014; Expiry Date
of 11 April 2016
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Continuing Competence changes
cont.
• I hold a current Certificate with expiry date:
28 Feb 2014
– When passed next Certificate will show 29 Feb
2016 (for all test passes dates up to 29 Feb 2016)
• I gained my Primary Qualification in the
current 2 year period (i.e. 1/3/12 – 28/2/14)
When do I need to achieve my Continuing Competence
Test?
– Within 2 years of the date shown on the
qualification certificate
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Continuing Competence Review
Expertise sought:
• Waste Electrical and Electronic Equipment ,
WEEE
• Contaminated Land
• Landspreading
• Closed Landfill
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Questions
WAMITAB Contacts:
Tel 01604 231950
Visit WAMITAB website www.wamitab.org.uk
Ray Burberry:
[email protected]
Mary Tonnison-Morgan: [email protected]
Mark Hyde:
[email protected]
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