If you are regulated by an ELV permit (End of Life Vehicles Permit) by the Environment Agency, then at some point you will have a visit and compliance assessment of your activities and paperwork to measure compliance against the conditions in your permit.
The reasons for the visit are primarily regulatory, i.e. the Environment Agency wants to see how you are measuring up against the conditions imposed on your operation, but they will also want to get to know you and your operation as part of their ongoing regulatory remit.
The Compliance Classification Scheme (CCS) that is used by the Environment Agency records non-compliances against the various conditions of the permit. The categories of non-compliance are classed as follows;
Category 1 – A Non-compliance at a regulated site that could foreseeably result in pollution classified as category 1 in the Common Incident Classification Scheme (CICS) used by the EA.
Category 4 – A Non-compliance at a regulated site that cannot foreseeably have any impact on the environment.
There are two other categories in between with grades between the higher and lesser categories above.
Not all conditions of your permit will be looked at or assessed during each visit but the ones that are will be recorded on the CAR report and an assessment of compliance made as indicated below.
Permit Conditions and Compliance Summary
b) Infrastructure 1. Engineering for prevention & control of pollution C3 2.3.5(b)i
2. Site drainage engineering (foul & clean) A
There will be a number of different sub-criterion e.g. “Infrastructure”, “management” etc. that you will be assessed against. As in the example above the infrastructure, sub-criteria will contain a number of elements such as site drainage. In the example above this has been recorded as “A” assessed, whereas the “Engineering” sub-criteria have been recorded as a C3 breach against permit condition 2.3.4(b)i.
How will the visit be conducted?
You will usually be notified in advance (but not always) by your area EA officer who will give you an indication of the scope of the visit and what areas they will be looking into. When the visit takes place, they will want to look at your paperwork including your management system records for training & record keeping as well as walking through your site to look at infrastructure and how the yard is being managed.
It is always best to be courteous and respectful, if you are fully compliant with your permit then you have nothing to fear and it will help to build a good working relationship with your local officer. It is likely that issues will be identified that require correction. Discuss these with your local officer and agree on a timescale for implementing the corrective actions. Don’t take these findings too personally, it is part of how the EA regulates and improves business compliance by identifying areas for improvement.
Your CAR report will be sent to you within a reasonable timeframe of the visit, clearly identifying the breaches (if any) and outlining what is expected of you within a pre-defined timescale. There will be a written summary of the visit and also an indication of what further action (if any) the Environment Agency plans to take at this time.
For more information on dealing with Environment Agency visits or ELV permits, please contact Paul Downing on 077901 470 84 or visit www.pauldowningltd.co.uk.