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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.