Managing Hazardous Waste Competence

waste

Gordon WalkerGordon Walker will be presenting on the topic of organisational waste management in the Strategy, Regulation and Compliance theatre at EMEX on Wednesday 27 November at 13:50 – 14:20.

Changing focus

Waste is quite an emotive subject at present, ably assisted by the recent spate of publicity and programmes depicting plastics (amongst other things) floating in the oceans and wreaking havoc with biodiversity.

That said there are a number of us stalwarts who have been managing our waste operations in relative silence for many years with the subject of waste and its management tending to be the often forgotten portion of the Safety, Health and Environment world. 

Given this surge of interest we are no longer seemingly consigned (pardon the pun) to a small corner of the office or left to our own devices. There is now an active interest in what we actually do and how we go about doing it. We are now firmly in the limelight and we should take the opportunity to shine while we can.

But whilst there is a newfound focus on waste activities, and in particular where waste ends up, it has been a steady path of similarity for most of us in the industry who continue to manage our (or others) waste activities.

Managing waste

Waste can take many forms and can often be rather complex and difficult to manage. Where an organisation produces or handles hazardous waste, more stringent rules apply and an organisation must ensure their hazardous waste causes no harm or damage. Waste is generally considered hazardous if it is harmful to humans or the environment and an organisation must segregate items of waste of differing types – i.e. don’t mix hazardous waste with non-hazardous waste or mix different categories of hazardous waste with each other1. 

If an organisation uses, recycles, treats, stores or disposes of waste they may well need to have an environmental permit issued by their regulatory body and will need to fulfil specific criteria both to apply for, and keep that environmental permit. For example, an organisation must be the legal operator of the facility (this will include such things as having day-to-day control of the facility and making sure permit conditions are complied with) and they must be considered to be a competent operator by the regulatory body governing the permit.

Technical competence

The operation of a waste activity will not only require an environmental permit but the organisation will also be required to have appropriately qualified staff to manage the waste activities and they must be members of a government approved technical competency scheme. 

Depending on the scheme this may require keeping records of the operating hours and ensuring the qualified manager is on site (in person) for specified amounts of time per week. There are currently two government approved schemes2: 

The scheme run jointly by the Chartered Institution of Wastes Management (CIWM) and Waste Management Industry Training and Advisory Board (WAMITAB).

The scheme run jointly by the Energy & Utility Sector Skills Council (EU Skills) and the Environmental Services Association (ESA) – commonly known as Competence Management System (CMS).

Each scheme operates in a different way. The CIWM and WAMITAB scheme requires managers to work towards gaining the scheme’s qualifications and you need to pass a continuing competency assessment every 2 years. The EU Skills scheme considers the competence of an organisation as a whole and to join this scheme an organisation must have a competence management system in place certified by one of the scheme’s approval bodies.

The requirements to record the operating hours of your waste facility and how much time your technically competent manager is on site apply if you are a member of the CIWM and WAMITAB scheme, however they do not apply if you are a member of the EU Skills scheme.

One size doesn’t fit all

It may come as a surprise, but the complex nature of waste is further compounded by having to determine which technical competence scheme works for your organisation, as they are very different.

CIWM and WAMITAB

The type of waste activity an organisation operates and its associated risk will drive the type of permit required. This, along with the operating hours of the site itself, can affect the qualifications required and the number of hours a competent manager is required to physically be on site if you use (or intend to use) the CIWM and WAMITAB scheme. If the waste activity is spread across a number of sites then the organisation could require several technically competent managers (TCM) to manage their waste activities. That said, the CIWM and WAMITAB scheme is completely independent of an organisation and its specific activities and as such is transferable to other waste facilities run by the organisation or to other organisations altogether.  

There are varying levels of technical competence under this scheme based on the level of risk and type of waste facility being operated, but it is much more wide ranging than just managing waste. For example, the WAMITAB Level 4 – High Risk Operator Competence for Managing Transfer of Hazardous Waste – training typically includes maintaining health and safety, managing the impact of the work activities, organising transport of loads, managing the delivery & storage of wastes, controlling maintenance and other engineering operations, procedural compliance and maintaining systems for responding to emergencies. 

EU Skills

The EU Skills scheme enables operators to demonstrate technical competence of their permitted activities themselves. The scheme is based on the recognition that individual competence contributes to the overall performance of a site rather than having reliance on specific trained individuals. 

In order to demonstrate your organisation operates responsibly you have to demonstrate you have processes in place to manage your waste activities. Training is of course required, but rather than being wide-ranging and general it is bespoke to your organisational activities and tailored towards an individual’s role – it also doesn’t require a formal qualification.

As technical competence is based on individual contribution it tends to promote wider staff awareness of environmental issues, knowledge of permit conditions and increased awareness of emergency requirements. It also helps identify employee skills gaps and assists in creating standardisation if the operation spans several sites.

What size fits me?

Which scheme an organisation should use is entirely their own choice and will be driven by such factors as the mechanics of internal operations, where waste fits in the organisation (its relative importance – likely to be based on risk factors), the type of waste activities undertaken, number of locations involved (and distance between them), scale of activity and how the organisation intends to manage legal and permit compliance. 

At Northern Powergrid, we migrated from the CIWM and WAMITAB scheme to the EU Skills CMS scheme. Not because we necessarily wanted to but due to external drivers altering our operational and compliance requirements.

Northern Powergrid is responsible for the distribution network that delivers electricity to some 3.9 million homes and businesses across the North East, Yorkshire and Northern Lincolnshire. To deliver the electricity we have to undertake work on our assets which can generate thousands of tonnes of waste including items such as asbestos, batteries, oil, plant & equipment, paper, food, wood, and spoil.

We operate around 30 separate facilities many of which include hazardous waste bulk storage areas. Up until recently though, we only required two bespoke waste permits which were adequately managed via an outsourced WAMITAB trained competent person, which had been our operating model for many years.

The introduction of the Waste Framework Directive (and in particular the application and interpretation of the term ‘discard’) set out a number of situations where permits and consignment documents would be required. These included:

Sites used to store used insulating oil prior to reprocessing;

Sites used to reprocess the oil as well as mobile reprocessing plant;

All transport movements of used insulating oil;

Registering of substations consigning more than 500kg of oil per annum.

Whilst the requirement to register substations consigning more than 500kg of oil per annum was removed with the repeal of RPS 025 in April 2016, the requirement to consign used insulating oil and permit facilities that are used for bulk storage of such oil still stands. 

This significantly altered the way the electricity distribution network operators managed their oil operations, and in particular in relation to the number and type of environmental permits required for their numerous and widespread facilities. 

The issue of consignment notes aside, the industry was now faced with the requirement to hold environmental permits for bulk storage of oil and oil-filled transformers. For Northern Powergrid that has meant us migrating from 2 bespoke environmental permits, which covered our operating area of Yorkshire, Northern Lincolnshire and the North East of England, to 7 permitted sites and numerous exemptions to store lower quantities.

As we journeyed to this new way of working we continued with our management of the permitted sites via the use of a WAMITAB trained competent manager. As the number of sites grew so did our requirement for additional competent managers – more sites means more time on site overall so eventually the requirement for one technically competent manager grew to several as there are only so many hours in a week.

At this point it was abundantly clear that we would require a more robust approach to meeting our expanding waste needs than just to contract-in another trained competent manager when needed. We needed a more robust and enduring solution and there were many internal debates on whether to train internal staff or continue to contract the service provision or even to alter our operations.

We decided it would be preferable to remove the reliance on one individual per site and adapt a more holistic approach including the education of a large proportion of our operational staff. 

For us the EU Skills Competence Management System scheme provided a mechanism to build internal resilience to future changes and waste permit expansion by using our own trained and competent staff. The added benefit for us was all our staff involved in hazardous waste activities received enhanced and updated training on waste management, completing consignment notes, permit conditions and achieving compliance.

The EU Skills Scheme was adopted by Northern Powergrid and it was embedded across the organisation as we started to own technical competence. In August 2018, we became certified to the EU Skills Competence Management System Scheme and continue to be the only UK electricity distribution network operator to be certified to the scheme. 

1An environmental permit can be obtained for mixing waste if you can demonstrate that the mixing of these wastes is the best available technique.

2Schemes approved by the Environment Agency for permits issued in England.

3Environment Agency regulatory position statement RPS 025 – Premises notification for the Hazardous Waste Regulations.

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