Over the last 12 to 14 months, we have seen an upsurge in exempt site owners being talked into requiring technical competence cover at great expense, with a notable upsurge since the consultation on exemptions and associated changes was published earlier this year (For more information on the changes to exemptions, visit the link to read our blog: https://www.hsecservices.co.uk/waste-exemptions-consultation-outcome-supplementary-government-response-updated-6-february-2023).

So, if you manage an exempt facility or know someone who does, even if it’s an exemption which is due to be removed within the next year or so like the T9 and you are planning ahead and applying for a permit, you do not need anyone with the required technical competence and if your being told you do, your probably being ripped off!

You only require technical competence if you’re managing a permitted facility!

Now it’s always good to plan ahead, get costs, even start the required qualification, possibly even complete it depending on the route, access to a surrogate site and other factors if you’re applying for an environmental permit to help spread the cost or avoid the need for temporary cover once the permit is issued and operational, but you don’t need external cover if as above your operating an exempt facility!

So far, we have seen a bit of a trend in that the majority of sites are dealing in scrap metal, and some appear to have decided to apply for a permit or they are in the early stages and looking to apply for one due to the pending changes to various exemptions! 

People are abusing the system to make money and con people, who are possibly unsure of what’s required!

So here are some quick tips to ensure you don’t get scammed!

1. If approached even if your concerned by what you have been told such as a change in requirement, don’t panic, don’t agree to anything, don’t allow yourself to be pressured, say to them you will think about it and come back to them!
2. Seek advice from a number of reputable sources such as CIWM (WAMITAB) or one of their centres, consultants, the Environment Agency or Natural Resources Wales.
3. Once you have all the facts, you can then make an informed decision!
4. Talk about it, speak with friends, colleagues and others, share this blogg or social media post so we can raise awareness!

Tips for those operating a permitted facility, who may require temporary technical competence cover (Also referred to as COTC or TCM cover):

1. Always check the individual’s certification is legitimate and suitable for your facility, with social media being at the centre of so many peoples lives, people regularly share their achievements including certificates, so copies are easy to obtain, people are more aware of how to use picture editing software and the risk of fake certificates is likely to increase regardless of the sector or industry! You can check a CIWM (WAMITAB) certificate by scanning the unique QR code available on the back of the certificate, or email info.admin@ciwm.co.uk and they will provide advice and tell you what they need to confirm the certificate as being legitimate! This along with checking a legal form of ID, will ensure the person providing the cover is suitably qualified and is the person stood on site! Also don't forget to ask for their continuing competence certificate, if the original certificate is more than two years old!
2. If you don't know the attendance requirement for your facility, speak with your local Environment Agency or Natural Resources Wales officer, to ensure the person providing cover is able to attend site for the required amount of time, this also ensures your not paying for more than you require, or paying for cover and still falling short of any attendance requirement!
3. Get references or do some research, do they have a good reputation, has anyone else you know used them?
4. Be careful when dealing with individuals or organisations who provide you everything directly, be it qualifications and technical competence cover, or a mixture of services because there can be a conflict of interest, and we have seen learners we have taken on from other centres who have been on program achieving their qualification for far longer than they should, because their original assessor was also providing technical competence cover, which was far more financially lucrative and their progression was stalled, so while it might seem a cost effective solution, it’s possibly not longer term!