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EA publish response to TCM consultation

Between 14 June to 9 August 2021 the EA ran a consultation on the attendance requirements for technically competent managers (TCM) on permitted waste sites. The two main areas requiring feedback were:

  • options for proposed changes to the methods of calculating TCM attendance and other proposed changes to the attendance requirements
  • proposed implementation timescales

Three of the key conclusions that relate to AD plants are summarised below.

  1. Approximately 75% of all respondents supported adjusting the attendance requirement based on operator performance, with those in deteriorating or poor compliance bands having an increased attendance requirement. Respondents clearly supported proposals to increase TCM attendance where operators are poor performers. In response the EA will develop these proposals further in their second consultation. They agree that increasing TCM attendance should not be the sole focus of efforts to improve a site. However, the root causes of permit non-compliances are regularly recorded as poor training, and inadequate implementation of management systems and associated management plans. Managing these are an important role for the TCM as part of the overall technically competent management.
  2. 50% of respondents suggested that 1 year would be an appropriate timescale to implement any changes to the TCM attendance requirement. This is to allow companies to train and/or recruit additional staff if required. In response the EA will proceed with developing attendance proposals on the basis of a 12 month implementation period.
  3. If a 24 hour operation is carried out, rather than calculating attendance on a 24 hours a day fully automated treatment process alone, the EA propose operators calculate this based on their typical operational hours for:
    • waste acceptance
    • waste input
    • waste dispatch activities

This is providing the operator has remote or telemetric systems to raise an alarm, with appropriate personnel on call, should an incident occur during unmanned hours. These procedures must be explained in the operator’s management system.

The full response can be found here

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