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More on Competence for Operators of Authorised Treatment Facilities

technical competence
The deadline is fast approaching and you need to make sure that those responsible for managing your site can prove their techcnically competence.
We recently received an email from Dr Lawrence Strong, Director General of WAMITAB expressing concern that our previous article about technical competence contained a number of inaccuracies about the scheme run jointly by WAMITAB and CIWM. He has forward the following article to explain further the scheme.


The introduction of the Environmental Permitting Regulations in 2007 in England and Wales changed the requirements for demonstrating and maintaining competence; an Operator Competence scheme (the ‘scheme’) was jointly developed by The Chartered Institution of Wastes Management (CIWM) and the Waste Management Industry Training and Advisory Board (WAMITAB) and became operational in December 2008; it is one of two schemes approved by Defra and the Welsh Assembly Government.

The scheme incorporates a flexible, risk-based approach to demonstrating competence where each person has a choice of qualifications and programmes depending on which risk tier they fall within. This builds on the concept of an individual’s competence which was the cornerstone of the previous Certificate of Technical Competence (CoTC) scheme and extends it further into low, medium and high risk waste management activities. The Environment Agency (EA), as the Regulator in England and Wales, will determine the risk tier as part of the Permit application process.

An important development was the introduction of a mechanism for maintaining competence over time, something CIWM/WAMITAB called ‘Continuing Competence’, which came into force on 1 March 2009. This involves taking a multiple-choice, computer based test at a local centre; the test comprises questions on legislation, health and safety, environmental protection and ELV operations. MVDA provided the ELV questions. Operators were initially given a 2-year period (up to 28 February 2011) to take their test.

How does this affect ATF‘s handling end-of-life-vehicles (ELV) which are classified by the EA as a ‘medium risk’ activity?

New ATF Operators

Any operator starting a new ELV facility will require an Environmental Permit from the Environment Agency; for a vehicle storage, de-pollution and dismantling facility this will typically be based on a Standard Rules permit (SR2008No20 and SR2011No3 apply). T he individual will be able to demonstrate his/her competence by achieving a 6-unit vocational qualification or a ‘vocationally related qualification’. These may be achieved within 12 months of the facility commencing operations providing a ‘low-tier’award is first obtained within 4 weeks of commencement.

Existing ATF Operators

At present, the Continuing Competence aspect of the scheme applies to existing holders of a CoTC achieved before 22 December 2008 and those individuals who have previously been ‘deemed competent’ or initially assessed by the EA. Many ELV operators have historically relied on ‘deemed’ competence or so called ‘grandfather rights’, however, these are no longer accepted by the EA and so these operators must pass the Continuing Competence test by the due deadline.

Help is at hand for Operators taking their ‘Continuing Competence’ Test

WAMITAB/CIWM provide considerable support on our web sites for individuals wishing to take the test; this is in the form of syllabuses, learning outcomes, information, advice and guidance and the Environmental Permit Operators Certificate (EPOC). This will allow individuals to undertake activities to obtain the necessary knowledge, skills etc in any way that is appropriate to their specific needs. This could include for example, an organisation's own in-house training or coaching programme, 3rd-party training courses or self learning e.g. via the internet. In other words gaining the required knowledge will be a self-managed process. This takes into account that everyone will have a different starting point, different learning preferences, different time and budget constraints etc.

Don’t Delay

ELV facility operators need to be aware of the approaching deadline for Continuing Competence which following discussions with Defra, WAG and the EA was extended to 29 February 2012. Lawrence Strong, WAMITAB Director General said “The extension was agreed as part of a pragmatic approach to competence which was adopted to deal with new sectors to ensure no one was disadvantaged. We have increased the number of test centres/seats available for the test but it is important that people book in good time to avoid a rush as the deadline approaches and the risk of being non-compliant.”

Further Information

The deadline is fast approaching and we have a 14 question test sample that you can try. There are also training seminars running this autumn which may be helpful to bring your knowledge up to the required standards. These have been jointly developed by MVDA, Astbury Wren and Aviva. A booking form can be downloaded at the bottom of or dummy test page.

Further information on all aspects of CIWM/WAMITAB Operator and Continuing Competence scheme can be obtained from www.wamitab.org.uk and www.ciwm.co.uk.

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