UPDATE from the Environment Agency – TCM attendance during Coronavirus (Covid-19) Restrictions – 7th December 2020
External briefing on technical competence during the pandemic
We understand that many operators will be concerned about how they can satisfy attendance requirements whilst sites are running on reduced staffing levels and staff may well be ill or self-isolating. We will be pragmatic in our approach.
- There is still a requirement to have a technically competent person as a requirement of the permit.
- The TCM attendance hours are within the guidance on GOV.UK and they are an indication that site activities are in being overseen by a technically competent manager.
- Operators are required to make provision for alternative TCM cover to cover all forms of absence but that may not always be possible during the current pandemic.
- Where the TCM is self-isolating or sick and cannot attend the site, the operator should be able and capable of operating the plant or site safely through both their EMS and operational training.
- Operators should:
- Review their training and capability structure to ensure roles, responsibilities and accident plans are in place to ensure that they are fit for purpose
- Ensure that remote systems are operational and any alarms systems where required, are fully operational
- Have a responsive duty roster to respond to incidents
- Notify us if the site cannot be safely monitored
- Record if their nominated TCM(s) are self-isolating in the site diary
- All other obligations, permits, permit conditions and registrations remain applicable as appropriate. You must keep records that evidence the impacts of Coronavirus (Covid-19), such as impact on staffing, systems, contractors and supply chain failure, specific to your company/site/issues.
Complying with technical competence schemes during Coronavirus (Covid-19) restrictions
Operators of permitted waste facilities relying on the CIWM/WAMITAB scheme to demonstrate Technical Competence are required to gain qualifications and pass assessments according to a timeframe set out in the scheme. Classroom based training and test centres required for some of these have limited availability due to the implementation of social distancing measures.
We expect candidates to try to book the relevant training and assessments in advance of when they are due but recognise that in some cases that may not be possible. We will not regard the failure to complete and pass either:
- an Environmental Permit Operators Certificate (EPOC) within 4 weeks of permitted activities commencing, or
- a continuing competence assessment
as being a failure to comply with the Wamtab/CIWM competence scheme until 1 April 2021 provided that:
- the EPOC or continuing competence assessment is not overdue by more than 6 months
- the candidate has made a booking for the earliest available date
- the operator has notified their local regulatory officer
- in the case of a continuing competence assessment, the operator has notified WAMITAB as well so that they can keep a database of affected candidates.
Where these circumstances arise in connection with an application for a permit, the applicant must still provide evidence of registration/booking for the appropriate qualification and/or training within their application as usual.