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

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Management Systems and Environmental Permits for ATFs – Part Three

In final series of articles regarding Management Systems and what vehicle recycling businesses must do to secure environmental permits, WAMITAB trainer and assessor Linda Waite provides her expertise on why keeping records is a necessary aspect to your Management System.


Management Systems and Environmental Permits for ATFs – Part Three f
Linda Waite

Part of your Management System (MS) requires you to keep records if you manage, treat or dispose of waste. If you are a waste operator, you must record the following for each delivery of waste to your site: its quantity (weight or volume); its List of Waste (LoW) Code; its origin (for example, the location the waste sent from); the identity of the producer of the waste (for example the company name); the date the waste arrives at your site; the date the waste was first produced, if the waste is likely to cause odour; and any quarantined materials that are part of the delivery, and what you did with them.

You must also keep records to show that you are meeting your Duty of Care requirements as a business that produces waste and comply with the site record and return requirements for hazardous waste. 

If you have a permit for waste, you will need to have a site condition report to record the condition of land or the quality of groundwater on your site. Keep this up to date through the life of your permit, and include details of any historic spills or contamination and what was done in response to those incidents and/or evidence of the effectiveness of any measures you have taken to protect land or groundwater since you started operating.

If you want to cancel (surrender) your permit you will need to show you have taken the necessary measures to avoid any pollution risk from your activities. You also need to show that you have returned the site to a satisfactory state. This means that the condition of land and groundwater has not deteriorated as a result of your activities.

Sites for waste may have to include an odour management plan; an emissions management plan; a noise and vibration management plan and/or a pests management plan.

You need to review your MS so you must have a procedure for checking you comply with your permit, procedures and the management system. Record what checks are carried out, who did them and what action was taken. You must review and update your MS when you make changes to your site, operations or equipment that affect the activities covered by your permit, for example, if you install a new boiler; whenever you apply to change (‘vary’) your permit; after any accident, complaint or breach of your permit; if you encounter a new environmental problem or issue, and have implemented new control measures to control it.

You must keep a record of changes to your management system, particularly major changes such as a change to the maximum amount of waste stored on your site; a new noise screen; new waste treatment equipment, e.g., a Trommel; and implementation of new control measures.

The EA/NRW may also review your management system and make recommendations for improvements after any accident, permit breach or other incident. It may also ask you to improve your management system if it thinks you have not identified or minimised risks from pollution.

If you decide to close your site or cancel part of your permit, you can do this at any time. You must still pay for your permit until you cancel it. You can apply to cancel all or part of your permit by filling in the EA/NRW forms as well as completing the ‘surrender’ section of your Site Condition Report. Your MS will need to be updated to show any changes apart from full surrender.

You will need to submit the site closure parts of the Site Condition Report when you stop operating.

Your staff must have access to and understand any sections of the management system that deal with activities they carry out. It is up to you how you do this, such as printing the system out or providing electronic copies. You must be able to show the Environment Agency your management system if asked. If you have an overarching management system for a number of sites, you can provide both an overview or summary of the whole system and/or copies of the sections that relate to the activity type or aspect of the management system that the Environment Agency has asked about

Consider whether you need to provide information to interested parties such as neighbours and your local community to explain how you manage your activities to comply with your permit.

Once your management system has been completed, you can submit it to the EA/NRW with your permit application. They will ask to see it periodically to ensure that you are keeping it up to date and you are doing what you said you would do.

To read Linda’s previous articles, click on the following links:

Management Systems and Environmental Permits for ATFs – Part One

Management Systems and Environmental Permits for ATFs – Part Two

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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.