The Environment Agency (EA) have provided the following guidance:

TCM attendance during COVID-19 restrictions

  • We understand that many operators will be concerned about how they can satisfy attendance requirements whilst sites are running on reduced staffing levels and staff may well be ill or self-isolating. We will be pragmatic in our approach.
  • There is still a requirement to have a technically competent person as a requirement of the permit.
  • The TCM attendance hours are within the guidance on GOV.UK and they are an indication that site activities are in being overseen by a technically competent manager.
  • Where the TCM is self-isolating or sick and cannot attend the site. The operator should be able and capable of operating the plant or site safely through both their EMS and operations training.

Operators should:

  • Review their training and capability structure to ensure roles, responsibilities and accident plans are in place and reviewed to ensure that they are fit for purpose.
  • Ensure that remote systems are operational. Alarms systems where required, are fully operational.
  • Have a responsive duty roster to respond to incidents.
  • Notify us where the site cannot be safely monitored.
  • Record if their nominated TCM(s) are self-isolating in the site diary.

Difficulties in taking Continuing Competence tests

Pearson VUE test centres are now open but not operating at full capacity due to the requirement to comply with social distancing guidelines. The EA will not regard the failure to complete and pass any of the assessments in the circumstances listed below as being a failure to comply with the CIWM/WAMITAB Operator Competence scheme until 30 September 2020; where:

  • under a new permit, an operator is required to gain an Environmental Permit Operators Certificate (EPOC) or 4 specified units of a primary qualification within 4 weeks of permitted activities commencing
  • under a new permit, an operator benefitting from the period of grace provisions cannot be assessed for their primary qualification within 12 months of their permitted activities commencing,
  • a continuing competence assessment becomes due after 16 March 2020.

If any of these scenarios apply at your site then you should contact your local environment compliance officer as soon as possible.