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

Adam Hewitt
Combilift
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Training is key in helping to tackle metal crime

Robin Edwards, owner of ONIS Consulting, consultant to Industry and Law Enforcement agencies, and currently working with the British Transport Police, discusses why ATFs must operate within the requirements of the law, and why training is beneficial to tackling metal crime.

 

Training is key in helping to tackle metal crime f
Robin Edwards

I can’t talk about catalytic converter and metal crime without discussing the importance of training and how much impact this has on both the recycling sector and enforcement.

The new Scrap Metal Dealers Act was introduced in 2013. As I have already said, it made a considerable impact on metal crime and forced sections of the recycling sector to improve their processes and standardised business across the sector. In 2013, I spent a great deal of my time delivering training to police forces and local authorities on the new legislation to make sure enforcement was entirely up to speed when the act was introduced. However, I spent very little of my time working in the recycling sector, and the delivery of training was, as I recall, the responsibility of the relevant trade bodies and individual businesses.

The trade bodies did a great job of ensuring their members were up to speed in terms of their responsibilities under the SMDA 2013, and overall, the rollout went smoothly, and subsequent visits confirmed that the majority of businesses visited were mainly compliant. However, this was only those that were visited, so it’s not a true reflection but a snapshot of overall compliance. I’m not confident businesses that sat outside trade bodies received sufficient guidance and support to ensure they could fully implement the changes the act introduced. Most vehicle recyclers and scrap metal dealers adopted the voluntary measures introduced under Operation Tornado, so they should have at least been aware of the requirements of the new act. But it could be suggested that is an assumption that wasn’t supported with a full programme of compliance visits.

Unfortunately, the National Metal Theft Taskforce was disbanded in early 2014, and this didn’t allow sufficient time to train up all enforcement agencies and absorb metal crime activity into normal operational activity. It also coincided with the decrease in commodity process that did play its part in suppressing offending and diverting law enforcement attention towards other more pressing areas.

As metal crime remained low, enforcement resources were diverted elsewhere to deal with existing and emerging policing priorities which is a normal part of policing. The core of knowledgeable and experienced police and support staff was lost, and I suspect the same happened across other enforcement agencies involved in tackling metal crime.

Jump forward to 2019, and the rapid increase in commodity process and the inevitable happened – thefts began to increase across all sectors. As I have already mentioned, those with the knowledge and skill to step in and tackle the emerging problem had either changed roles, retired or had lost the skills they had learned, leaving a gaping hole in agencies’ abilities to deal with this emerging problem.

We must also look to the recycling sector and ask ourselves if enforcement was not active in tackling metal crime or working with the sector, what incentive was there for scrap metal dealers and vehicle dismantlers etc., to not only comply but seek refresher training? I would suggest that those who didn’t fall under the guidance and support of trade bodies, and, as a result, didn’t receive any formal training on the Act, slipped further away from being fully compliant.

This lack of knowledge and the required skills to enforce the legislation is not an easy void to fill. The same can be said of the recycling sector, and I again suggest what real incentive is there for those who are happy to be non-compliant to become compliant. If they are rarely if ever visited, and those that do visit don’t have the knowledge and skills to identify a deal with failings, why would they bother? A recent freedom of information request into mobile collectors identified a 70% drop in the numbers licenced compared to 2014. This may be because of a reduction in those operating, but I suggest the figures point towards a lack of licencing because of a lack of meaningful enforcement.

From early in 2021, I started delivering online training to police, partners and other agencies who have an interest or involvement in tackling metal crime. I was able to train several hundred individuals and provide them with guidance, documentation, and the support they needed to enforce the legislation and, as a result, identify issues and noncompliance. The results achieved during national weeks of action highlight the benefit of this online training and how effective it can be when tackling metal crime.

At the beginning of December 2021, I commenced a more detailed and widespread training programme for police, local authorities, and other partners. From the beginning of January, this has developed into much more comprehensive face-to-face classroom sessions that are being delivered nationally. This training will continue throughout 2022 and equip officers and staff with the skills they require to tackle metal crime. It will give them the knowledge and confidence they need to ensure compliance with the Scrap Metal Dealers Act, deal robustly with those who feel it is acceptable to ignore their responsibilities, their legislative obligations, and turn a blind eye or openly accept illicit material.

The next stage will be to work with industry, help them understand the legislation, highlight their responsibilities, and make sure they are not unwittingly putting themselves at risk through non-compliance. As I mentioned earlier in this article, I suspect sections of the industry didn’t receive any formal or at the most, very little training on the act and now almost nine years on its time to revisit this.

For vehicle dismantlers, ELV processors and scrap dealers, I see this as a real opportunity to fill any gaps in their knowledge in terms of the legislation and review their processes so they can be confident they are operating within the requirements of the law. However, I suspect, for some, it may be a step too far, and no amount of persuasion will see them participate, which would be a missed opportunity and real shame.

My advice would be to carefully consider participating as training that is designed to support industry and not inhibit the recycling sector. From speaking to scrap metal dealers, I know that some have either forgotten or didn’t really know when the act was introduced what they were supposed to do to be compliant. This puts them at risk of prosecution, possible revocation of licences or the potential of having future licence applications rejected, and, as a result, losing their ability to trade.

To contact Robin, visit www.onis-consulting.co.uk or call him on 0793 0115709.

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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.