In this month’s article I have moved away from H&S and into the realms of the “environment” ...don’t worry, I have checked with Enviroman to make sure that I am not standing on his cape!
There are quite a few changes that you will need to be aware of and Marco will no doubt address some of these at some point, with the two that I wanted to cover being changes to the way that competency is demonstrated and also the introduction of Continuing Competence. These do not get a great deal of coverage in the Regulations, but they will have a big impact on many of you.
Competency
The statutory requirement for a COTC has been removed and has been replaced with (currently) two schemes, although only one has been developed fully so far. This is the scheme by CIWM/WAMITAB and is based around the current vocational competence system, with some significant changes.
Sites have been categorised into high, medium and low risk activities, with this affecting the competency options available to you. The final categories are yet to be approved by Defra, but we have a far idea of what will be going where.
High risk sites
These will still require a full NVQ, although the COTC requirement has been dropped. Example activities are generally those involving hazardous waste and also non-hazardous landfill sites.
Medium risk sites
These are where the changes will start to have a big impact as you will only need to complete 6 units of the NVQ, or a 6 unit VRQ (see below). Example activities are non-hazardous transfer sites, contaminated land remediation sites, inert landfills, some WEEE and ELV sites.
Low risk sites
These will only need to complete 4 units of the NVQ, or a two-day EPOC (Environmental Permit Operator’s Certificate) that is being developed by CIWM. Example activities are in house storage of waste and WEEE ATF (storage only).
Continuing Competence
This is a new requirement for you to demonstrate that you remain up-to-date with changes to legislation and operational issues. This will be a two yearly requirement and will affect ALL competent persons, even those who already have their COTCs and also those who are relying upon deemed competence.
For those managers who achieved their competence before 6 April 2008, they will have to demonstrate their Continuing Competence by April 2010, whilst those certificated after April 2008 will have until 2012 as they have already demonstrated their Competence within that initial 2 year period.
To demonstrate your ongoing competence you will need to complete a test administered through CIWM/WAMITAB.
What if I already have a COTC?
If you already have an appropriate COTC then this will still be valid as an initial award, although Continuing Competence will apply.
What do I need to do if I have any questions?
As you can see there is quite a lot to take in, particularly for those of you operating sites that might fall into the medium, or low risk categories. The system is still in it’s early stages and there is going to be some confusion whilst it beds in and the finer detail becomes clearer.
Give me a call on 01204 658691 or email nigel@theskip.net if you have any questions and I will do my best to point you in the right direction.
Nigel Mair is a WAMITAB assessor and verifier and runs the North West Regional Assessment Centre, delivering WAMITAB qualifications and other H&S, waste and environmental training.
