ELV Training requirements and
Centre opportunities
Ray Burberry – Qualifications Manager
Assessor Forum 2014
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Continuing Competence training for
ELV TCM’s
• Historically, ‘Exempt’ activities have meant that few
ELV managers have been required to achieve a
WAMITAB qualification.
• Therefore: Minimal training has been provided to
this important sector.
• DEFRA/EA/NRW used the CIWM/WAMITAB Scheme
as the means to determine TCM requirements for
those ‘existing’ managers.
• ‘Waste Exemption Review’ relates.
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ELV Continuing Competence
requirements
• Specialism – ‘End of Life Vehicles’, often linked with
‘Scrap Metal’ merchant operations.
• Generic:
– Health and Safety
– Legislation
– Environmental Protection
• Often it is the ‘Generic’ questions that pose
problems to the Operator.
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Technical Documents (some key examples)
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ELV Regulations 2003
Scrap Metal Dealers Act 2013
Scrap Metal Dealers Act 2013 (Explanatory Notes)
Depolluting ELV (Cars and Light Goods Vehicles) Guidance for ATF’s
March 2011 – Defra/BIS
The safe recovery of petrol from ELV’s – HSE
Removal of LPG Tanks (BIS)
SRP’s 2008No20/2011No3 – Vehicle Storage, depolluting and
dismantling
How to Comply with Your Environmental Permit (EA)
Small Businesses: A Guide to the Hazardous Waste Regulations (EA)
EA Guidance – Waste Crime Innovation Programme – ELV
(information to Environment Officers)
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Environment Agency Report (England)
September 2014
• In 2013 - There were 312 breaches of permit relating
to competence
• In 2014 - 240 (to date) breaches of permit relating to
competence
• Over the period: 552 in total to date
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Categories of breach
• ‘No current competence’ (lack of attendance by
competent manager)
• ‘Wrong current competence’ – competence does not
relate to permitted operation.
• ‘No primary competence’ (COTC or equivalent) as a
result of ‘Waste Exemption Review’: ‘Transitional
activities’
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Waste Exemptions Review (extract)
Transitional activities:
• Operators who had exempt activities registered with us on 5
April 2010, that will move into permitting, will need to advise
us who these managers are at the time of their first permit
application.
• This applies to an operator who starts an activity that is
covered by one of our new Standard Rules permits (anaerobic
digestion activities are excluded), which have replaced
existing exemptions.
• The nominated managers must have had a responsibility to
control the activities covered by the registered exemption.
• All nominated managers must pass the test within 12 months
of the first permit being issued.
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In 2013, 312 (TCM Breaches)
Comprising:
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155 incl: Metals, ELV, WEEE
118 Inert treatment
19 Biological waste treatment
13 Landfill
5 Hazardous Waste
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Of the 552 TCM non-compliant
permitted sites, (2014) - 240 relate as
follows:
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37 Recommended for prosecution
12 Given a formal caution
66 Given a formal warning
112 Have received (EA) ‘advice and guidance’
13 There is no record of ‘formal’ activities
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Did you know?
• Continuing competence candidates tested ELV = circa
650 (2014)
• Number of permitted sites ELV: circa 2000
• Total number of permitted site circa 8- 10 000 (all
categories)
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How you can help? How to proceed?
Training opportunities!
• WAMITAB ELV Workbook - review
• Opportunity for Centres to offer focussed training for
ELV Operators
• EA/NRW Excel Spreadsheet: Contact list of services
throughout England and Wales
• WAMITAB ‘Accredit’ Training provision opportunities:
Web link opportunities
• Clearly, opportunities for remaining CC Topic areas
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Thank you
Questions?
WAMITAB
Peterbridge House
3 The Lakes
Northampton
NN4 7HE
Tel: 01604 231950
Email: [email protected]
Web: www.wamitab.org.uk
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