Depending on the complexities of a site and the number of management system(s) in place, operators are required to ensure the management system(s) they operate at their site is/are fit for purpose and compliant with the regulatory regime they operate under. As an example, a large proportion of waste sites are operated under a standard rules or bespoke environmental permit which, under Condition 1.1 General Management (of the permit), require operators to manage and operate the specified activities in accordance with a written management system. Failure to do so can result in a breach of the permit and consequences for this can vary dependent on the outcome of the fault. When one management system, e.g. for a permit, is operated in conjunction with management systems for other regulatory regimes such as:
- Health and Safety;
- The PAS110 or PAS100 Standard (dependent on if you are a composter or Anaerobic Digestion operator); and/or,
- ABPR Regulations – if you collect and treat animal by-products (ABPs).
This presents a significant administrative and operational challenge to ensure full compliance with all regulatory regimes. Due to the scale of management system requirements there is the potential for operators to miss certain aspects (operational/monitoring/recording) of these systems so they fall foul of breaches/non-compliances when regulatory representatives conduct site visits/audits of the site.
WRM offer a service which enables us to assist with this situation ensuring any issues are identified so they can be addressed by the operator. When contacted by an operator and commissioned to perform a compliance assessment, WRM perform the following actions:
- Documentation Search – WRM commence by attending site to conduct a search of documentation related to the management system(s) specified within the scope of the works.
- Document Review & Audit Development –WRM then commence with a review of the existing permission and consent documents such as the environmental permit, APHA approval letter and H&S documentation. This review focuses upon identifying any site-specific conditions or considerations that have been stipulated.
- Site Based Audit and Meetings – Upon completion of the review, WRM then visit site again to review all site-based documentation that supports, and discharges conditions set within consents and permissions.
- Follow-up & Report – Following completion of the audit, WRM produce a short report which summarises the compliance position and makes recommendations on any short term or immediate improvement actions, along with longer-term recommendations for ongoing compliance management.
Our team has experience of working at strategic and operational levels, as well as on procurement and investment due diligence projects, and this ensures that the outcomes from consultancy advice work reflect the objectives and aspirations of our customers in a pragmatic and deliverable focussed manner.
If you are a site operator and feel your site would benefit from a compliance assessment, please contact Tom Broderick (Senior Environmental Consultant) via the details below.