WEEE Support Grants and Loans Package

To help stabilise the WEEE industry, the Compliance Fee Advisory Panel has agreed to offer operators financial support. £5.6 million is now available through the WEEE Support Grants and Loans Package. Approved Authorised Treatment Facilities (AATFs) can apply for a grant or loan sum based on WEEE tonnage treated in the 2019 compliance period.

The economic damage COVID-19 has caused the waste electrical and electronic equipment (WEEE) sector has been significant. Once the Household Waste Recycling Centres closed and the WEEE collections diminished, the upstream WEEE supply chain dried up. Compounding the pressure, reuse and other downstream supply chain solutions have also shrunk. These factors have left the WEEE sector with no choice but to take drastic action. Many AATFs have chosen to temporarily cease trading and furlough their staff.

To help stabilise the industry, the WEEE Fund 2019 Compliance Fee Advisory Panel is set to offer financial support under a ‘WEEE Support Grants and Loans Package’ programme. Trade associations, authorities and industry leaders – including the AATF Forum and Defra – make up the WEEE Fund panel.

Comprised of grants and loans, Wiser Environment understands that the funding will total £5.6 million. The WEEE AATF charity sector will be eligible for £600,000 in grant subsidies. Whereas, the wider AATF sector will have access to £5 million in interest-free loans. For an AATF to be eligible for the loan, it would need to have issued treatment evidence in 2019. An application needs to be made before the end of May 2020. Successful applicants will be funded 50% of their allocation shortly following approval. The remaining 50% will be released three months from the date of the initial payment.

Analogous to the Government’s ‘Coronavirus Business Interruption Loan Scheme‘, the process for applying for the support is relatively simple. Contact details will be provided once the scheme is finalised. The Wiser Environment team is here to help support WEEE operators; working together to gather the required information and apply for the support package. For more information contact Wiser Environment or call on 01480 462232.

Reopening HWRCs during COVID-19

Since movement restrictions have been in place, many HWRCs have been closed. Consequently, this has had an adverse effect on the public and the environment with fly-tipping incidents increasing. Wiser Environment understands that several operators and industry bodies are keen to push forward with the reopening of HWRCs. To prevent causing harm, HWRCs will seek to open in an orderly and structured manner.

On the 23rd of March, the Prime Minister addressed the nation on COVID-19. In this statement, the PM instructed that the general public must stay at home and avoid public gatherings. This COVID-19 action plan had a direct effect on Household Waste Recycling Centres (HWRCs). The following day after the PM’s statement, many HWRCs closed; issuing updates to their local communities encouraging them to stay home and hold on to their waste. An unforeseen consequence of this action was a spike in fly-tipping incidents. Richmondshire District Council expressed that they experienced a three-fold increase in fly-tipped waste since the closure of their HWRCs.

Acknowledging the fly-tipping issue, the Department for Environment, Food and Rural Affairs (Defra) determined that HWRCs should reopen. Documented in their ‘Guidance on prioritising waste collection services during coronavirus‘ report, Defra insists that “Local authorities must provide places for residents to deposit their household waste at all reasonable times”. The Waste Industry Safety and Health (WISH) Forum supports Defra’s claim as well. In their ‘COVID-19 and Waste Management Activities’ document, the Forum argues that the closure of HWRCs “may result in adverse responses from members of the public and others”.

The plan to reopen HWRCs

Wiser Environment has been in communication with several HWRC operators across the country. Many agree with the perspective of Defra and WISH. These operators are keen to maintain safety and reopen in an orderly and structured manner.

To achieve this goal, Wiser understands that sites are planning to reopen their HWRCs in a phased approach. This will help mitigate complications arising from staff shortages. Also, both rural and urban sites will gradually reopen; spreading the demand and limiting travel time for householders. Furthermore, a one-in, one-out system will be established to avoid overwhelming the site and create social distancing difficulties.

To help promote social distancing, sites will provide a ‘no assistance, no contact’ service alongside enforcing a 2-meter separation rule. Additionally, Wiser expects that public demand for HWRC services will be high. This could cause queuing on public roads. In response to this risk, HWRCs have the option to call upon the Police to help with traffic management.

Wiser Environment is ready and available to help support the process of reopening HWRCs during the COVID-19 movement restrictions. In cooperation with sites, Wiser can review permit compliance and update management systems; establishing the organised approached needed to reopen safely. For more information contact Wiser Environment or call on 01480 462232.

Earth Day: Enabling clean energy through innovation

The 50th anniversary of Earth Day comes at a challenging time for everyone. Whilst COVID-19 is causing disruption to the event, Wiser Environment celebrates the key developments in the waste industry. The way we manage our waste has been transformed over the past 50 years, with the introduction of great new technologies to move waste away from landfill disposal. There is much work to do and many further technologies are in various stages of development. Nevertheless, the waste industry should be proud that these innovations help reduce environmental harm.

Since 1970, the Earth Day event has stood up for environmental protection and climate action. 2020’s Earth Day theme is to highlight action on climate change; promoting the switch to green power. To support this event, Wiser Environment is celebrating its progress to establish clean power technologies at waste sites in the UK.

Wiser Environment works with many clients across the waste and resource industry. Wiser’s primary goal is to always help businesses grow and prosper through responsible operations. As an example, Wiser is collaborating with a closed non-hazardous landfill operator and overhauling the landfill into a clean energy plant. Echoing the Earth Day enthusiasm for change, Wiser and the operator have seized the opportunity to go above and beyond.

Clean energy

Instead of sticking with a traditional means of returning a non-hazardous landfill to land for beneficial use, the decision was made to innovate. Specifically, Wiser Environment and the client aims to create a platform for economic and ecological growth through carbon-neutral energy solutions. Such innovations include a solar-battery hybrid system that stretches over 4 hectares; an anaerobic digestion plant that converts food waste into energy; and ground source heat pumps that will maintain the site’s treatment plant temperature.

Wiser Environment has also helped businesses establish biomass boilers and reduce waste being sent to landfill. For example, Wiser supported a coffee recycler in gaining an Installation Permit for their advanced biofuel demonstration facility in Cambridgeshire. The application process required comprehensive pre-application and post-application liaison with the Environment Agency. Nevertheless, the challenge was worth the effort; this facility the first of its kind worldwide.

The installation of innovative and sustainable technologies at waste sites are examples of the climate action Wiser Environment is taking. Climate action does not always have to be a resource drain. Alternatively, climate action can become a platform for an integrated waste recovery solution that benefits the community.

Take part in Earth Day 2020

Wiser Environment encourages everyone to celebrate Earth Day 2020 and stand up for the planet. The event is set to be held across many digital platforms on the 22nd of April. Visit the Earth Day Network for discussions and presentations. Of particular note, the Lincolnshire Chamber of Commerce is hosting a selection of presentations on sustainability policies and how to increase eco-friendliness.

Management system remote auditing during COVID-19

The COVID-19 crisis has brought immense challenges; forcing businesses to adapt quickly. This is also true for those operating within the certification industry. In response, UKAS has empowered assessment bodies to use technology that enables management system remote auditing. Wiser Environment has recently successfully run a remote ISO certification audit with BSI on behalf of a client and feels that this method of assessment will become more common – not just during the lockdown period. Companies need to prepare for change.

A number of certified organisations have been questioning how the COVID-19 pandemic will affect their management systems. For many companies, maintaining certification is business-critical. This is especially true for those who are currently non-operational due to COVID-19. These businesses will want to be immediately back up and running when the pandemic is over. They will require the credibility certification bestows.

In acknowledgement of these issues, the Institute of Environmental Management and Assessment (IEMA) and the UK Accreditation Service (UKAS) are collaborating on a webinar series. The ‘Adapting to COVID19’ webinar series addresses the challenges the certification industry faces. The Wiser Environment integrated management system (IMS) experts sit in on these webinars and distil the information for clients.

UK Accreditation Service’s approach

During the webinar hosted on the 15th of April, UKAS expressed that existing guidance will help inform their approach. This existing guidance is from the International Accreditation Forum (IAF). The guidance document referenced was ‘IAK Informative Document for Management of Extraordinary Events or Circumstances Affecting Abs, CABs and Certified Organisations’ (IAF ID3:2011). Whilst the IAF’s report was published prior to the COVID-19 pandemic, it does offer suitable guidelines for handling such events. Furthermore, the IAF are frequently updating their COVID-19 FAQs.

From a UK perspective, UKAS are set to publish their own technical policy statement: ‘UKAS Policy on Accreditation and Conformity Assessment During the Coronavirus Outbreak’ (TPS 73). As of writing, the TPS 73 is currently in draft for consultation.

The UKAS Strategic Development Director, Jeff Ruddle, proposes that the aim of the guidance is to outline the appropriate course of action for conformity assessment bodies (CABs). Ruddle suggests that a level of remote assessment is achievable in all scenarios. Adding that UKAS are working closely with their CABs in order to maintain consistency. However, Ruddle does postulate that it is inevitable that each CAB will approach this pandemic slightly differently. This is because of external market and industry factors.

UKAS also made a provision to extend certificates requiring recertification audits during the pandemic. The decision for recertification must be made within 3-months of the lifting of the COVID-19 travel restrictions. However, Ruddle warns that if the timeframe exceeds 12-months then the certificate should be suspended and a new initial audit will be required.

Management system remote auditing

With the additional support from UKAS, it is likely that CABs will still conduct surveillance auditing and renewal assessments. Wiser understands that all of these audits will proceed remotely; utilising the various digital conferencing platforms available. This stance will likely remain in place until at least the 31st of July.

During the remote audit, an added focus will be on the system records. These include internal audit reports, management review records and key performance monitoring data. This will enable businesses, where remote oversight of operational activities is restricted, to still be assessed.

The Wiser Environment IMS team recently completed their first remote audit. Representing a client, Wiser used the Webex conference platform to communicate with the CAB – BSI. The sharing of information between the client, Wiser and BSI was seamless. Resulting in a successful audit for the client.

The Wiser Environment Consultancy Director, Charles Thomas, reflects positively about the remote audit:

“The BSI audit was very thorough. The remote nature of the audit enabled BSI to undertake a more considered review of system documentation as process operations could not be reviewed. BSI worked with us to overcome any difficulties in achieving the audit plan, amending the scope of the audit and rescheduling operational activities until the next schedules surveillance audit due in 6 months time.”

Preparing for remote assessment

Wiser Environment recommends that businesses should prepare for their remote assessment. They should take some additional time to consider what resources, both human and technical, they have available.

On the day, the auditor may need access to electronic records. For this reason, the auditee should familiarise themselves with the functionality of their preferred digital conferencing platform (e.g. Microsoft Team, Skype and GoToMeeting).

Wiser Environment is ready and available to support businesses with their remote assessment. In preparation, Wiser can organise a remote internal audit of the IMS. This will provide confidence that the system’s documentation is of a suitable standard for assessment. For more information contact Wiser Environment or call on 01480 462232.

Safe return of Wiser consultant to Vietnam

Our top priority remains the safety of our employees, customers and partners. Adhering to government COVID-19 advice, the whole Wiser Environment team has been working remotely and practicing social distancing. For the majority of our team, working remotely means working from the comfort of the home. This has not been the case for one of our key Vietnam consultants – Ngan Tran.

In early 2020, Ngan travelled to the UK from Vietnam. Here, she was trained and mentored in our St Ives office by the UK team. This collaboration has enabled us to share best practice, open new channels of communication and become a more efficient team. Specifically, Ngan has done an amazing job in bringing our team up to speed with the environmental challenges faced in Vietnam.

Ngan’s first flight back home was due for the 28th  March. But, the impending lockdown in Vietnam and the UK meant a short notice change of plan to find a flight for the 23rd  March. Unfortunately, a change of travel and transfer rules whilst at the airport meant Ngan was not allowed to get a connecting flight to join up with a European based flight to Ho Chi Minh.

All other incoming passenger flights to Vietnam were subsequently cancelled to avoid overloading Vietnamese quarantine facilities. As a result, this meant that Ngan had to prolong her stay in the UK. We were, fortunately, able to extend the stay at the same accommodation for Ngan.

Ngan was able to work remotely within the UK for 3 weeks along with the rest of the team. Eventually, the Vietnamese Embassy was able to establish a repatriation flight for those stranded in the UK. On 14th  April, Ngan flew with Vietnam Airways on a direct flight to Hanoi. After touching down in Vietnam safely, Ngan was placed into a specific COVID-19 quarantine unit. This quarantine will last for 14 days. After which, the Vietnamese government will repatriate Ngan back to Ho Chi Minh City.

Ngan, and the rest of the team, will certainly remember her first visit to the United Kingdom!

Site status check during COVID-19 pandemic

Alongside the Environment Agency’s operational update, the local Environment Agency departments are performing a site status check. The check will request information on a site’s operational status and its business continuity plans. The Wiser Environment team is ready and available to help operators correspond with their regulators.

Site status check during COVID-19 pandemic

An example of a site status check form.

On the 3rd April, the Environment Agency (EA) published an Operational Update. This update outlines the Agency’s strategy to support the industry during the COVID-19 pandemic; expressing that they are aware that communities, businesses and the environment rely on their services.

Coinciding with the update, local EA teams have been contacting sites and performing a site check. Wiser Environment considers this to be a part of the EA’s process to risk assess sites that need support.

Operators can find a copy of the site check questionnaire here. This version is being distributed throughout several regions across the UK. Nevertheless, Wiser Environment recommends that sites doublecheck with their Local Officer.

Above all, the EA are seeking reassurances that sites have adequate control measures in place. The regulator will be looking for evidence of the site’s operational status and contingency planning. However, the onus is still with the operator to request implementation of alternative measures.

Wiser Environment suspects that the majority of sites will need to provide the following information:

  • Any staffing and TCM attendance issues.
  • Contingency and emergency planning.
  • Updates to the integrated management system.
  • Evidence of supply chain risk management.
  • The volume of waste stockpiled on site.
  • Fire prevention and security measures if the site is non-operational and the stock remains on site.
  • Confirmation that the site is still able to submit waste returns and preserve records.

Wiser Environment has extensive waste and resource management experience; providing independent advice to the waste industry for many years. Wiser can help support sites gather the required information and respond to the EA. For more information contact Wiser Environment or call on 01480 462232.

RPS C2: Exceeding waste storage limits due to COVID-19

To help businesses cope with COVID-19 disruptions, the Environment Agency has published a temporary regulatory position statement. This statement authorises sites who are restricted by COVID-19 to exceed their waste storage limits. For assistance in confirming arrangements, talk to Wiser Environment.

Coming off the back of the Environment Agency’s (EA) Operational Update, the EA has taken further steps to support the waste and resource industry.  Understanding the challenges waste sites are dealing with, the EA has published regulatory position statement C2 (RPS). This RPS allows waste sites to exceed their waste storage limits if they are unable to remove the waste due to COVID-19.

Sites will need to demonstrate to the EA that they have taken all reasonable steps to maintain compliance. This includes evidence of business continuity and contingency planning. In other words, the EA needs to see that the site is taking all the appropriate measures to minimise disruption and protect the environment.

RPS C2 conditions

Sites that choose to use the RPS C2 must comply with the following conditions:

  • Comply with all the other requirements of their environmental permit.
  • If there is a risk to human health or the environment, then to cease accepting waste on to the site.
  • Operators must maintain security and prevent unauthorised access.
  • Organise waste by storage age and operate under a clear and recorded “First-In, First-Out” principle.
  • Any waste that exceeds the permit’s storage limit must be removed within 3 months.
  • Conduct a documented review and update of the site’s management system and fire prevention plan.
  • The statement’s termination date is the 30th of September 2020.

Wiser Environment welcomes the EA’s pragmatic approach outlined in RPS C2. Where strict environmental and human health controls can be maintained, the relaxation of regulatory requirements may be appropriate to help businesses overcome short term supply chain pressures.

The Wiser Environment team is available to help operators, whose energies and focus may be elsewhere. For more information or assistance please contact Wiser Environment or call us on 01480 462232.

Obtaining a Local Area Agreement

Obtaining a Local Area Agreement can be the solution to help waste sites maintain compliance during unprecedented circumstances. At a local level and on a case-by-case basis, an agreement is made between the operator and the regulator. Wiser Environment has experience in negotiating these agreements on behalf of the waste operator; considering them to be a viable means of implementing alternative measures to limit the impact to the environment.

In the current climate, waste operators are under pressure from all angles. Sites are closing, maintaining technical competence is increasingly difficult and there are delays to requests and permit applications, to name but a few. In order to continue protecting the environment and avoid breaching breach their permit conditions, waste operators need support.

The permitting team at Wiser Environment has identified a potential solution to this growing pressure. With the help of Wiser, businesses where compliance is proving difficult should contact the Environment Agency (EA) and request to agree temporary alternative measures. This process is referred to as a Local Area Agreement (LAA) and is held between the permitted site and its Local Officer (sometimes referred to as a Site Responsible Officer). The LAA can authorise the site to operate outside of particular permit conditions, provided this is justified and approved. The following are potential examples of LAAs:

  • Reduced frequency of waste return submissions. 
  • Relaxation of monitoring requirements. 
  • Extensions to waste storage time-limits. 
  • Increasing the quantity of waste allowed on the site.
  • Changes to waste storage locations.
  • Storing waste outside of the permit boundary.

However, these alternative measures do come with restrictions. For example, there may be time constraints or a demand for additional reporting. These restrictions are in place to mitigate the potential risk to the environment.

Obtaining a Local Area Agreement

When working towards achieving an LAA, the Wiser permitting team will identify and clearly define where the operator needs regulatory support. This is an important step as it is likely that the LAA have a limited scope. After clearly defining the problem, Wiser and the operator will work together to create an alternative measure solution and embed actions to mitigate risk. The final step is to submit the LAA proposal in full to the EA and request their response.

The key part of this advice is to act transparently and proactively. From the EA’s point of view, they have to consider the potential risks and the limitations caused by these unusual circumstances. If the operator can demonstrate that they have taken into account and planned for all reasonable factors, then the EA are more likely to acknowledge the proposal.

Wiser has first-hand experience in implementing workable LAAs. Furthermore, the permitting team are ready and available to liaise with the EA on the operator’s behalf. For more information about how waste operators can protect their businesses through LAAs, contact Wiser Environment or call on 01480 462232.