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Further consultation required for TCM attendance guidance

According to the summary of the recent Environmental permit competence requirements: changes to technically competent manager attendance, further consultation will be required to help the Environment Agency (EA) develop the attendance requirements for technically competent managers (TCMs) guidance.


Further consultation required for TCM attendance guidance f
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For this consultation, which ran for 8 weeks from 14 June to 9 August 2021, the EA consulted with stakeholders to hear their views on proposed options and changes to the attendance requirements for TCMs.

The consultation explained:

  • how the current technical competence attendance requirements work
  • options for proposed changes to the methods of calculating TCM attendance and other proposed changes to the attendance requirements
  • proposed implementation timescales

75 responses were received and reviewed, and a second consultation will be produced that will provide further detail.

In the summary of the main findings and their actions, it was generally in agreement that new guidance was needed to explain the attendance requirements for TCMs. Views were given on which of the 3 options were preferred for calculating the attendance requirements:

Option 1: attendance linked to charge bands – 36%

Option 2: standard baseline attendance for all waste facilities – 16%

Option 3: tailored baseline attendance for waste operations and waste installations – 30.67%

No preference – 14.67%

Two respondents (2.67%) did not provide an answer to this question.

Many highlighted the potential for environmental benefits should TCM attendance increase at poor performing sites. However, according to the consultation outcome, the extent of this benefit would depend on the specific circumstances. Approximately 75% of respondents supported the adjustment of the attendance requirement based on operator performance, with those in deteriorating or poor compliance bands requiring increased TCM attendance.

Some respondents told the EA that applying attendance requirements for the Environmental Services Association (ESA)/Energy & Utility (EU) Skills technical competence scheme would undermine the purpose of this scheme.

In general, respondents supported other proposals on the 48-hour attendance cap, 24-hour operations, multiple regulated facilities and mothballed sites.

For permit transfers, some respondents highlighted situations where transfers were ‘administrative’ and in those instances, respondents did not support previously agreed TCM attendance requirements reverting back to those required by the guidance.

For closed landfills, nearly 40% of respondents agreed with the proposals, whilst 50% did not have a view. The EA anticipate the majority of the 50% who did not have a view do not operate activities involving closed landfills.

Most did not have a view on the proposals for mobile plant attendance requirements. Around one-third of respondents supported the proposals on mobile plant and less than 10% disagreed.

Nearly half of the respondents supported a 12 month implementation period for the new guidance. Because, for example, this would give operators time to understand the new guidance and train or recruit additional TCMs if required.

For further information about this consultation, contact

According to the consultation outcome, the responses to this consultation will help develop the attendance requirements for TCMs guidance. And that this will provide further details for option 1: attendance linked to charge bands, and other rules associated with the attendance requirements for technically competent managers.

The EA aim to publish the next consultation in summer 2022.

To see the full document of the most recent consultation, including the responses, go to

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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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