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.
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.
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 firstname.lastname@example.org