According to Wamitab, the Environment Agency (EA) has provided the latest Continuing Competence guidance
TCM attendance during COVID-19 restrictions
- We understand that many operators will be concerned about how they can satisfy attendance requirements whilst sites are running on reduced staffing levels and staff may well be ill or self-isolating. We will be pragmatic in our approach.
- There is still a requirement to have a technically competent person as a requirement of the permit.
- The TCM attendance hours are within the guidance on GOV.UK and they are an indication that site activities are in being overseen by a technically competent manager.
- Where the TCM is self-isolating or sick and cannot attend the site. The operator should be able and capable of operating the plant or site safely through both their EMS and operations training.
Operators should:
- Review their training and capability structure to ensure roles, responsibilities and accident plans are in place and reviewed to ensure that they are fit for purpose.
- Ensure that remote systems are operational. Alarms systems where required, are fully operational.
- Have a responsive duty roster to respond to incidents.
- Notify us where the site cannot be safely monitored.
- Record if their nominated TCM(s) are self-isolating in the site diary.
Difficulties in taking Continuing Competence tests
Pearson VUE test centres are now open but not operating at full capacity due to the requirement to comply with social distancing guidelines. The EA will not regard the failure to complete and pass any of the assessments in the circumstances listed below as being a failure to comply with the CIWM/WAMITAB Operator Competence scheme until 30 September 2020; where:
- under a new permit, an operator is required to gain an Environmental Permit Operators Certificate (EPOC) or 4 specified units of a primary qualification within 4 weeks of permitted activities commencing
- under a new permit, an operator benefitting from the period of grace provisions cannot be assessed for their primary qualification within 12 months of their permitted activities commencing,
- a continuing competence assessment becomes due after 16 March 2020.
If any of these scenarios apply at your site then you should contact your local environment compliance officer as soon as possible.
To contact Wamitab to find out more, go to www.wamitab.co.uk
Update – Natural Resources Wales (NRW) – RD guidance on TCM
This guidance applies to Wales only.
Natural Resources Wales (NRW) – Regulatory Decision (RD) guidance on Technical Competent Management is provided below:
Continued Technical Competence
Pearson VUE test centres are now open but not operating at full capacity due to the requirement to comply with social distancing guidelines. In these circumstances, NRW will not regard the failure to complete a continuing competence assessment that became due after 16 March 2020 as being a failure to comply with the CIWM/WAMITAB Operator Competence scheme.
There will be a requirement to demonstrate you have registered with WAMITAB to undertake this test. If this applies to you or your TCM, please contact both NRW and WAMITAB as soon as possible to let us know. WAMITAB is keeping a log of those who have contacted them. NRW will be checking this list.
Where an application for a permit is made and continued competence was due after 16 March, we won’t take that as a failure to prove technical competence and we will determine the application as per normal.
There will be a requirement to demonstrate you have registered with WAMITAB to undertake this test and already have the relevant primary qualifications that align with the type of facility you are making an application for.
Where a permit already exists and obtaining continued competence is not possible. The details will be noted on a compliance assessment report, scored but that score held in suspension.
There is the risk to the operator who fails to achieve continued competence following the lifting of restrictions on gaining a qualification that that operator will be in breach of the permit or this may delay permit issue. In this instance, the operator will be expected to provide replacement TCM cover to remain compliant.
This Regulatory Decision will be reviewed by 1 September 2020.
Full details about technical competence and site attendance are available on the Natural Resources Wales website
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