Phil Conran, a Director at 360 Environmental provides us with information on the difficulties faced within government bodies with regard to technically competent managers (TCMs) and how competence cover at sites can be achieved with the help of their team by implementing CMS.
‘Competence cover is a pain in the backside. We’ve found someone who’ll let us use their name, so we’re covered’.
Well no, not if the Environment Agency (EA) and Natural Resource Wales (NRW) have anything to do with it. Last year, they consulted on tightening the management of technical competence, stating that ‘certain technically competent managers (TCMs) are not acting in a proper manner. Some TCMs are spread too thinly, providing cover at many waste sites at the same time, whilst other TCMs are known to provide poor or wrong advice to waste operators or operators are fraudulently using a TCMs credentials without the TCM knowing’.
One of the problems the Agencies had was the lack of a central register of TCMs and they relied on individual sites providing information on their competence cover when asked. And competence cover was often ignored on Agency site visits and CARs, so for many sites, it was a question of what they could get away with.
The consultation led to the introduction of the Environmental protection (Miscellaneous Amendments) (England and Wales) Regulations in November last year which requires all permitted facilities in England and Wales (both pre and post the 2008 EPR regulations) to report their competence cover – and have a written management system – starting with their site waste returns this July for Q2. Whilst we don’t yet know the precise details of the information required, this will give the EA and NRW full transparency on competence cover and expose where sites are non-compliant.
The regulations require sites to meet competence cover through either WAMITAB or the more recent Competence Management System – CMS.
CMS offers a new style of competence cover. Similar to quality standards such as ISO14001. CMS is applied to the site rather than an individual and ensures that all relevant personnel engaged with waste at the site – from the weighbridge operator to yard staff to the Directors and site manager – fully understand the conditions of the permit and the site’s compliance requirements. Employees undergo annual training specific to the site and its operations and processes are put in place to ensure that the site is always operating under the conditions of the permit.
Any size of waste company can implement CMS because it is tailored to the business and its operation. A site does not need the ISO Standards of 9001 or 14001 either, just the management system that allows the proper function and monitoring of the site, as described in Condition 1.1.1 of the site permit.
Companies that have implemented CMS have found significant benefits that go beyond ticking the regulatory Technical Competence box. There is, of course, the removal of dependence on a single individual. Sickness, holidays or departure are no longer a problem as the site is permanently covered. But it is the business benefits that have been felt the most. Ensuring that the whole site fully understands the business, its operations and the legal compliance requirements imparts much greater ownership to employees. Site efficiencies improve. Staff look out for issues and deal with them before they arise. Problems are prevented from turning into major incidents. As an example, one site that had just implemented CMS had an incident where an articulated vehicle had its diesel tank ripped off as it went over the weighbridge. This would have led to a major pollution incident, but the site staff instantly reacted as trained, closed down the necessary drains and pollution, and likely prosecution was averted.
The MD of a recycling company that had implemented CMS stated ‘This has been a game changer for us. It has changed the culture of the company and the site has become more efficient and productive as a result.’
At present, there is only one UKAS approved Certification Body accredited for CMS – Lloyds Register. 360 Environmental has successfully implemented the system across a range of operators and works closely with Lloyds Register to deliver the optimum tailored result for each site.
Yes, competence cover is a pain, but this can be turned on its head to be a benefit. Sites now have no choice, so rather than treating it as a burden, sites should see CMS as an insurance policy that not only protects the site, but can help it to operate.
360 Environmental has successfully implemented CMS at many sites across the UK. 360 also provides support in waste exports, permit applications, management systems and fire prevention plans. More details are available at www.360environmental.co.uk