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Dismantling industry gets heard by the Environment Agency

Environment & Business launched
We would no longer be able to operate our yards if those who police our industry weren't made aware of the harm they can cause.
The Environment Agency recently held an event attended by over 300 Environment Agency staff and interested parties to launch their new Environment & Business (EB) structure. This new structure is designed to streamline the agency’s roles in site based regulation of waste (which incudes dismantling) and has been driven by the demands on all public offices to reduce cost and increase efficiency. Under the new regime, which came into force on April 1st, most waste activities will be regulated by the Illegal’s and Waste Team with the regulation of waste sites covered by the Site-Based Regulation Team.

The reasons for the Environment Agency’s event was to make sure that their staff were clear about the new role of EB and to understand the new ways of working within the regime.

Apart from changes to who will be responsible for policing our sites, the event did hold another matter of significance for the dismantler. The Motor Vehicle Dismantlers Association's (MVDA) Secretary, Duncan Wemyss was invited to make a presentation to the audience. Why is this significant? Simply because they obviously value the opinion of the MVDA and the concerns the association raises. This can only be good news to have an organisation expressing the views and opinions of the dismantler.

Anyone who isn’t directly involved with the MVDA can easily be unaware of the time and effort that’s put in to make sure that rules are workable and will not cripple your business. It is because of this behind the scenes success that we are all still operating and have not been decimated by ill thought out implementation of legislation. So what did the MVDA's Secretary tell the audience of EA officers? He was asked to give an overview of the issues facing our sector, explain some of the highs and lows of past experience and his wish list for what he would like to see from the Environment and Business Directorate in the future.

Duncan Wemyss explained to the audience, “There are some 1500 permitted elv ATF’s in England and Wales and an average size of these employ some 5 persons. The industry handles approximately 2 million elv’s per annum. Over the last 20 years the industry has been subject to a considerable amount of new regulation. This includes Environmental Protection Act 1990, Waste Management Licensing, Hazardous Waste Regulation and the greatest major change to the industry in 2003 “The End of Life Vehicles Regulations”. Duncan Wemyss made it quite clear that our industry has been bombarded with regulation and that although many regulations were now well established, they still required an understanding by the regulators of “how they impact on the operator”. Duncan went on, “The companies wish to operate within a clear statement of their regulated responsibilities but in a manner which allows them to be financially successful and therefore to continue to employ staff and return a profit. It is vital that the EA continues to have dialogue and work in partnership with the industry to allow this to happen whilst still ensuring environmental protection”.

As for the highs and lows, he preferred to focus on the highs saying, “The most important of which is the EA’s approach to working in partnership with industry. A greater willingness to understand the problems we face and to seek mutually beneficial answers to these problems. An example of the partnership working has been the agreement reached between us on an environmentally acceptable method of handling used vehicle oil filters – moving them from a hazardous waste to a recyclable non-hazardous item via an approved depollution process. This is achieved at a low cost to the operator and recovers a major percentage of the oil filter and its contents”.

“Additionally, the Agency’s acceptance of our proposal to remove the charge for Hazardous Waste consignment notes for movements of undepolluted end of life vehicles. This financial relief has assisted the industry whilst still retaining the environment audit trail by the completion of the consignment notes – This was a win-win solution achieved through partnership working. This was an example for business to demonstrate a practical solution to a problem without compromising environmental protection and for the Environment Agency to consider and reach a successful conclusion”.

MVDA Secretary, Duncan Wemyss
MVDA Secretary, Duncan Wemyss left the EA officers in doubt as to what he wants
When it came to his wish list, then number one was that we had sector specific personnel, “officers knowledgeable in our particular sector” he said. Secondly, he went for consistency. “Much has changed in the regulation world over 25 years i.e. COPA licence, waste management licence, environmental permits etc. In many cases these have automatically changed into the new name without a full review of the new demands” Mr Wemyss explained. “To create a more consistent approach I would request that the Agency sets out with the industry a clear understanding of what a current standard rules permit requires. This includes the type of management system required – The EA’s very practical and user friendly “toolkit” could be ideal for SME operators. Once agreed I would wish for the EA to review all current permits which fall within the standard rules volumes and allow the operator a reasonable timescale to implement any changes (say 6 months). Once in-place and the EA and operator share the same understanding of the requirements then this should support a more uniform national approach to the regulations”.

Better communication was Duncan’s third wish, saying, “I believe that the EA needs to improve its communication channels with those it regulates”. “The presumption that operators have time to regularly view the EA Website (if you can even get into it) is not what happens. How do operators find out about changes to regulations affecting their permits and operations – why can’t the EA send an email to the operator to alert them to changes? You know what the site is permitted for, so why not set up a computer programme to cover this demand – most operators have emails. Alternatively agree with the operator to text them – all have mobile phones. When dealing with operators explain to them the reason for any request – not “it is the law, and use language that the operators understand when discussing matters”.

Duncan’s final wish was enforcement. He said, “The industry is indebted to the EA for mounting a national campaign and continues to seek out the illegal operators. These people have had a commercially free ride for many years and undermine the stability of the sector. The agency must continue to seek out and take action against these illegals. They must be stopped. It is hard work and a visit to a welcoming legal operator is often a natural choice rather than seeking out the illegal. Make the hard choice – go for the illegal and support the complaint”.

Duncan Wemyss' speech was well received by the audience and it demonstrates the benefits when our industry’s voice is heard. The MVDA is well represented in all areas affecting the well being of the dismantling industry but it is only with constant effort as a group that the MVDA can protect our individual futures. If you are not a member and feel it is important that we protect our industry, then why not join the MVDA. For around £500 per annum you get a great deal of protection!

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