WFAA Seminar 19 th October 2016 Manchester Chamber of Commerce The Role Facility Auditing Plays in Assuring Ongoing Waste Compliance Alan Potter, Director Beyond Waste CENv, FCIWM, UKELA, IEMA (qualified auditor)
Beyond Waste • Specialist Environmental Consultancy • Founded in 2003 building on 30 years+ experience of waste compliance advice • Providing Compliance Support to: – Waste Producers – Waste Management Companies – Government • Permitting, auditing, enforcement matters, appeals and expert witness.
Why bother about Ongoing Compliance?
Risks • Prosecutions for – Documentation Irregularities – Non Compliance with producer regs – Unlicensed Operations & Permit Breaches – Pollution Incidents • Civil sanctions – Fixed Penalty Notices – Enforcement Undertakings • Reputational Risks – External (PR) – Personal
Risks Starbucks fined £160,000 for leaving rubbish on street opposite the Ritz Hotel Westminster City Council have confirmed that the prosecution was made under Environmental Protection Act S 34 – Duty of care etc. as respects waste. This imposes a number of duties on anyone who imports, produces, carries, keeps, treats or disposes of controlled waste including preventing the escape of the waste from his control.
Ongoing Compliance Issues
WEEE, batteries, packaging etc Duty of Care Waste Hierarchy • Secure storage • Pass to authorised person TEEP • DtC documentation Producing Landfill Pre Treatment Hazardous waste consignment Exemptions Transporting Storing/Treating Registration Permitting as waste carrier Low Risk Positions ABP compliance
Facility Auditing
What to Audit for. • Waste Production Sites – Assess the state of compliance with current waste related legislation. • Waste management facilities to confirm: – Compliance with permit (s) – no gross non- compliances – No formal enforcement action inc H&S notices & – Claimed landfill diversion rates are actually being achieved.
How to Audit • Waste Production Sites: If a multi site estate visit sample of sites across a range of company functions. How to decide which ones? • Visit waste management facilities – Desktop review of web sources – do homework – Site visit – drop in or give notice to an operator? – Be prepared to visit other receiving sites • Produce healthcheck report with prioritised actions
Clipboard Wielding Auditors.. • Audits conducted by IEMA accredited auditors accompanied by own staff.
The Facility Audit It is only a snapshot so how can you be sure that: 1. the site visit was representative of current performance (or even at its worst ie highest compliance risk); and 2. If no problems found will this continue until next audit?
Cant be everywhere all the time…
Things can go wrong rapidly…
SEVERE EXPOSURE!!
Going Beyond the Spot Check Facility Audit…
Action Required o Establish robust compliance monitoring systems. o Establish risk based programme of checks that will pick up all sites. o Establish support systems to build internal capacity with ongoing training, education and information. o Engage contractor support too
Assuring Ongoing Compliance
Example Monitoring System Q Target check type Looking for what a 'pass' looks like example 1 Clear identification of Visual of selection of bins what should be in the bin staff understanding of how cardboard is not present in receptacle contents around site plus verbal system operates substantial quantities in verification residual waste bin 2 Contents of bin Visual of selection of bins what is actually in the bin no contrary material is no glass bottles in food correspond to labels around site plus verbal present that might waste bin verification compromise designated management route 3 Instruction to third party Verbal check backup by Are cleaners and other materials handled by third good segregation of contractors that may be paperwork - work instruction contractors aware of system in parties placed in correct materials in external bins involved in managing operation bins waste 4 Awareness of at risk Visual plus verbal check Presence of liquid containers any risky materials isolated waste oil in bunded area receptor on specific site over drains or bins near from possible pathway to where surface water boundary that may result in 'at risk' receptor drainage; bins near odour or litter release. boundary kept closed to prevent windblow or 5 Awareness and Verbal check with random what to do in exceptional knowledge of what to do what to do with a broken understanding staff circumstance 'if in doubt refer matter to glass bottles of pasta MML sauce - does it go in food waste bin? Glass recycling bin or residual waste bin? What if bulk breakage? 6 Paperwork Visual of Paperwork Presence of duty of care Complete and up-to- date All forms present, signed transfer note that is up-to- register with all forms and correctly completed date, signed, covers all waste present, signed and types and includes waste correctly completed hierarchy statement Hazardous waste consignment note register ABP consignment note Register
Devising A Programme • Desk based risk assessment initially based on EA site compliance score • Sample of waste management facilities ‘critical to contract’ – The management of a particular stream of waste relies substantially or exclusively; or – A particular location relies e.g. if relatively remote: or – To which client waste represents a substantial input; or – Operated by third parties that have no direct buy-in to fulfilling the client needs as not directly procured
Example Programme
Getting Contractors Help Clearly (and consistently) coloured and labelled receptacles Feedback on material non-compliances. Provide up-to-date correct documentation eg DoC. Feedback on site performance. Take shared responsibility to resolve issues. Train/educate site staff about ‘Dos’ and ‘don’ts’.
How Can I Be Alerted to Changes in the Compliance Status of my Suppliers between audits?
Introducing DUTIE…
Features Integrates the public registers from the four nations into a single stop online ‘shop’ ie equal data access. + Integrates the registers with Companies House financial performance data ie early warning of instability. + Rationalises company search results by reference to Companies House saving time on searches = Comprehensive & Time Saving Waste Compliance Checking & Monitoring Tool
Conclusion…
Facility Auditing & Compliance Assurance • Facility auditing is important as it establishes a baseline BUT • it is only a part of compliance assurance AND • no substitute for establishing ongoing mechanisms needed.
Ongoing Compliance Assurance Contractor Internal Support Capacity Ongoing Monitoring & Alerts Spot check Producer Site Facility Auditing Audit
Feeling More Comfortable & less exposed…
WFAA Seminar 19 th October 2016 Manchester Chamber of Commerce THANK YOU FOR YOUR ATTENTION Alan Potter, Director Beyond Waste CENv, FCIWM, UKELA, IEMA (qualified auditor) Tel: 01342 825300 alan@beyond-waste.com
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