If you have an Environmental Permit for a waste operation, you’ll know the first paragraph holds the following key requirements for your operation:
1. 1.1.1 The operator shall manage and operate the activities:
1. (a) in accordance with a written management system that identifies and minimises risks of pollution, including those arising from operations, maintenance, accidents, incidents, non-conformances, closure and those drawn to the attention of the operator as a result of complaints; and
2. (b) using sufficient competent persons and resources.
Therefore, a legal requirement for your operation is to ensure that the site has adequate competency in the form of Technically Competent Manager (TCM) cover, whether it be an appropriately trained member of staff or an outsourced expert. However, the appointment of a TCM can’t be a tick-box exercise. TCMs have a responsibility to the site and the company to reduce the risk of environmental breaches.
There are currently two approved schemes through which you comply with the above competency requirements: CIWM/WAMITAB and EU Skills.
The attendance requirement for a TCM depends on the type of permit that is held by a site and the environmental risk presented by the site. You must have TCM attendance at your site at least 20% of the operating time in the first six months if you’ve got: either a standard rules permit or any other permit applied for before 1st April 2018 that had a fixed application charge. There is a 48-hour attendance cap at all sites.
These visits must be recorded. This includes the TCM signing in and out, recording the number of hours they
have been on site, and demonstrating, through a report or site inspection form, that they have carried out a thorough site inspection. Should any permit or environmental breaches occur, the TCM must inform the site manager and put the relevant control measures in place. If the breach is significant, the regulating body must be notified.
As a TCM, it is your responsibility to ensure the site operates within the rules set out in the Environmental Permit and approved management systems.
TCMs may create and implement a site Environmental Management System that identifies and minimises pollution risks. Ensuring operators receive informed and relevant information is a key part of the TCM Role, which is enabled by liaising with the regulators, keeping up to date with legislative changes and working alongside peers and working groups. Engaging with your peers is important for site operators and TCMs alike.
Tina Jackson from Jackson Consultants has recently formed the Technically Competent Managers Forum (TCMF) network. It was created as a support network for TCMs and anyone who is involved in compliance in the waste industry. It’s a platform to share knowledge, experiences, and challenges that the industry faces in the waste industry see TCMF on Linkedin or email Tina Jackson for more details – tina@jacksoncl.co.uk
The key to keeping TCM cover simple is to choose the right person for the role who understands your operations and is comfortable enforcing compliance. If you’re a TCM yourself, get involved in discussions with your peers to keep up to speed on legislative changes and best practices.
