Essential information for end of life vehicle dismantling, depollution and recycling

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What happens once you have received your ELV permit?

Paul Downing, Environmental Consultant, provides ATF Professional’s readers with his expert advice on the steps a vehicle recycler needs to take after receiving an ELV permit to operate.

 

What happens once you have received your ELV permit? p two

The process of obtaining an ELV permit from the Environment Agency can be lengthy and costly. We have mentioned in previous articles the complexities of obtaining an ELV permit, complying with the fire prevention guidance and becoming registered as an ATF. You can now become operational & depollute vehicles legally, sell parts on eBay and buy CAT Bs from auction sites. However, what happens once you have received your permit and started operating? Does the red tape stop there? Is that the end of it?

Unfortunately, once you have received a permit to depollute vehicles from the EA, you are now registered on their ATF database, and as a waste permit holder, you will be subjected to an annual audit and review of your permit compliance.

Inspections from the EA usually happen annually, and these may occur as soon as you receive your permit or several months later. Compliance audits are usually (but not always) announced visits. The EA officer will review the conditions in your permit and associated documents, e.g. the FPP (fire prevention plan). These associated documents submitted with the permit application also become permit conditions once the permit is issued, so it is important to do what you said you would as part of the application process.

The EA officer will leave you with a compliance assessment report (CAR) which will identify non-conformances with your permit conditions. These may be major or minor breaches and these will have been discussed with you at the time of the visit. Each will have an associated improvement item next to it identifying what is expected to be done to get back into compliance. These are usually time-sensitive and will also have been agreed with you at the time of the visit.

Non-compliances may be related to minor paperwork issues or larger operational issues such as too much waste on site or the import of waste onto the site for which you don’t have the correct codes in your permit. Do not ignore the CAR report. If you do not comply within the given timescales, you may receive an enforcement notice or worse, a prohibition notice or stop letter. Always respond positively to the CAR report in writing with an indication of what you intend to do and when with an improvement programme for achieving compliance and when you expect this to be completed.

What happens once you have received your ELV permit? p
Paul Downing

The EA officer will check all or part of your permit compliance but may not have time to review everything. Just because something is not reported in the CAR report doesn’t mean that there isn’t an issue that might be raised at the next visit. If you know of compliance issues, it is probably best to get them sorted before they are picked up by the EA.

The review will also look at your quarterly returns to the EA, WAMITAB certificates, transfer notes, operational issues such as drainage and storage, as well as the physical amount of waste on-site and waste types at the time of the visit.

If you would like help or advice on applying for an ELV permit or help with ongoing compliance call Paul on 07790 147084 or email paul@pauldowningltd.co.uk

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Owain Griffiths

Owain Griffiths

Head of Circular Economy at Volvo Cars

Owain joined Volvo Cars in June 2021 to lead Circular Economy in the Global Sustainability Team. The company has committed to being a circular business by 2040 and has financial, recycled content and CO2 based targets for 2025, all of which Owain is working across the company to make happen. Owain previously worked for circular economy consultancy Oakdene Hollins where he advised businesses on evidence led circular economy implementation. 

Turning into a circular business and the importance of vehicle reuse and recycling.

The presentation will cover the work Volvo Cars is doing to achieve 2025 but mainly focus on the transformational work towards 2040 and the business and value chain changes being considered. Attention will be paid to the way vehicles are being dealt with at the end of life and the complexities of closing material and component loops. Opportunities and challenges which Volvo Cars is facing will be presented including engagement with 3rd parties and increasing pressure from stakeholders.

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The power of the network model means e2e has the ability to influence industry standards and is committed to continually raising the bar whilst redefining the role and perceived value of the salvage operator.  Network members adhere to robust service level agreements, against which they are audited, in order to ensure performance consistency and a market leading customer experience.  

The salvage and recycling operating environment is evolving rapidly, and e2e is anticipating, listening and responding to changing market needs.  Regulatory compliance, ESG, reclaimed parts, customer experience, EVs, new vehicle technologies, data and reputation risk are just some of many considerations linked to the procurement of salvage services.  e2e will drive further added value to clients and members through the adoption and application of emerging technologies, continuing to differentiate its proposition and position salvage services as a professional partnership. 

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