6 key ways to keep your waste site compliant
By Jessica Morgan-Smith, principal consultant at MPG and Tina Jackson, TCM and owner of Jackson Consultants.
The duty of care legislation makes provision for the safe management of waste to protect human health and the environment. Below is our guide to the six key ways to keep your site compliant:
1. Appropriate Environmental Permit and planning permission
Before operations commence, it is vital to ensure you have the correct permits and permissions in place. It is also essential that you read them and understand the conditions they contain. The rules or conditions of your permit tell you what you must do to protect the environment and people. You must keep copies available on site and be able to refer to it at any time. Anyone working on site must have also read the relevant sections applicable to their work.
2. Technically Competent Manager (TCM)
Your site must ensure that it has adequate TCM cover, whether it be an appropriately trained member of staff or an outsourced expert (who can ensure their qualification is suitable for the operation). However, the appointment of a TCM can’t be a tick-box exercise. TCMs have a responsibility to the site and the company to comply with the law and minimise risk and the impact of your activity on people and the environment.
3. Robust waste acceptance procedures
The law requires anyone dealing with waste (producer, haulier, broker, or receiver) to keep it safe, make sure it’s dealt with responsibly and only given to businesses authorised to take it.
The receiver will have waste acceptance procedure in place. For landfill and recovery sites, that includes a robust pre-acceptance procedure to ensure the waste being imported are chemically suitable for the type of site, inert, non-hazardous or hazardous. Waste Classification and WAC testing is required to satisfy the operator that the waste material meets their permit conditions.
Each load of waste must be accompanied by a Waste Transfer Note (WTN) or Consignment Note and be presented to the operator on arrival. The note must be completed correctly, including the appropriate EWC which is suitable for the facility. The weighbridge operator must ensure the waste stream coincides with the information on the WTN before the load can be tipped.
4. Management systems
Management systems should be appropriate for the specific site and its operation – they cannot be generic. They must be reviewed annually or at the time of incident/breach. You need to make sure that all staff are aware of what they are and where to find them.
Management systems must be trained out to all appropriate staff in order for them to be effective. Finally, management systems should include a schedule for carrying out site inspections and the detail of what is being inspected either daily or weekly and a thorough accident management plan.
5. Training – for new starters and ongoing
As with all things, knowledge is power, and it is crucial that new starters and existing staff are trained. Training should cover the following areas: waste acceptance, duty of care, and Environmental Management System (EMS) and must be refreshed on an at least annual basis to ensure staff are up to date and aware.
6. Audits – internal & external
A good audit will ensure that your site is compliant with relevant laws and regulations. This reduces the potential for incidents and therefore the risk of prosecution. It also helps to foster a culture of compliance within your organisation, which can lead to improved standards across the board. Both internal and external audits have value and are an essential tool to helping you remain compliant.
Do you require our assistance in relation to a waste matter?
At MPG, we specialise in producing bespoke planning and environmental permit applications for waste operations. Find out more, here.
If you’d like help keeping your site compliant, or want to get in touch about another mineral, waste, renewables, environmental planning or permitting matter, please contact our friendly team by phoning 01274 884599 or emailing headoffice@mpgyorks.co.uk. Alternatively, drop us a note on our contact us page.
For TCM requirements, please contact Tina Jackson on 07779 654256 or tina@jacksoncl.co.uk.