The Role Facility Auditing Plays in Assuring Ongoing Waste - - PowerPoint PPT Presentation

The Role Facility Auditing Plays in Assuring Ongoing Waste Compliance

Alan Potter, Director Beyond Waste CENv, FCIWM, UKELA, IEMA (qualified auditor) WFAA Seminar 19th October 2016 Manchester Chamber of Commerce

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

Waste Hierarchy

Producing Storing/Treating Transporting

Duty of Care

• Secure storage
• Pass to authorised person
• DtC documentation

Hazardous waste consignment Registration as waste carrier Exemptions Permitting Low Risk Positions WEEE, batteries, packaging etc ABP compliance Landfill Pre Treatment TEEP

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

• wn 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

• Establish robust compliance monitoring systems.
• Establish risk based programme of checks that

will pick up all sites.

• Establish support systems to build internal

capacity with ongoing training, education and information.

• Engage contractor support too

Assuring Ongoing Compliance

Q Target check type Looking for what a 'pass' looks like example 1 Clear identification of receptacle contents Visual of selection of bins around site plus verbal verification what should be in the bin staff understanding of how system operates cardboard is not present in substantial quantities in residual waste bin 2 Contents of bin correspond to labels Visual of selection of bins around site plus verbal verification what is actually in the bin no contrary material is present that might compromise designated management route no glass bottles in food waste bin 3 Instruction to third party contractors that may be involved in managing waste Verbal check backup by paperwork - work instruction Are cleaners and other contractors aware of system in

• peration

materials handled by third parties placed in correct bins good segregation of materials in external bins 4 Awareness of at risk receptor on specific site Visual plus verbal check Presence of liquid containers

• ver drains or bins near

boundary that may result in

• dour or litter release.

any risky materials isolated from possible pathway to 'at risk' receptor waste oil in bunded area where surface water drainage; bins near boundary kept closed to prevent windblow or 5 Awareness and understanding Verbal check with random staff what to do in exceptional circumstance knowledge of what to do 'if in doubt refer matter to MML what to do with a broken glass bottles of pasta 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 transfer note that is up-to- date, signed, covers all waste types and includes waste hierarchy statement Hazardous waste consignment note register ABP consignment note Register Complete and up-to- date register with all forms present, signed and correctly completed All forms present, signed and correctly completed

Example Monitoring System

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.

Internal Capacity

Contractor Support Producer Site Audit

Spot check Facility Auditing

Ongoing Monitoring & Alerts

Ongoing Compliance Assurance

Feeling More Comfortable & less exposed…

Alan Potter, Director Beyond Waste CENv, FCIWM, UKELA, IEMA (qualified auditor)

Tel: 01342 825300 alan@beyond-waste.com

WFAA Seminar 19th October 2016 Manchester Chamber of Commerce

THANK YOU FOR YOUR ATTENTION