Certificate of Technical Competency

You have been in the auto recycling business since you finished school, your children have been brought up in the business and their children are of an age where they want to finish school and come and join you, and the Environment Agency are now asking you to take a test to prove your competent to operate a recycling yard.

You are probably thinking what do they know about running a salvage yard that I don’t?

Well, the bad news is that Technical Competency is here to stay; the good news is that it is not too difficult once you know how the testing procedure works and have received a little bit of training.

There are three elements to the test, the generic module and then two activity specific modules that most End of Life Vehicle sites should be taking.
The Generic module looks at three areas:
• The Law – this includes Waste Carriers, Environmental Permitting, Hazardous Waste Controls and so on.
• Health and Safety – Equipment, Manual Handling, People on Site etc.
• Environmental Protection – for example - Drainage, Bunding, Liquid Containment, spillages, etc.
This part of the test is 20 questions with multi-choice answers.

The activity specific modules focus directly into such areas as End of Life Vehicles, Metal Recycling, Waste transfer Station and so-on, and these are 6 questions for each, again with multiple choice answers.

It is best to work with professionals in this area to determine the exact modules required and the training needed to pass the Technical Competency tests, both UK motor salvage federations are offering training to their members, so their web sites would be a good place to start, www.mvda.org.uk and www.bvsf.org.uk , you could also work with your local Environment Agency office to determine what is required, as the modules detailed above are only suitable for members of staff with considerable experience of running auto recycling operations, and newer staff may be required to complete more intensive training and development before being technically competent.

If you are based outside of England and Wales then there is currently no requirement for you to hold this qualification, so you can watch with interest as your colleagues work through these tests, however if you are based in England and Wales you cannot ignore the requirements, without a Certificate of Technical Competence the Environment Agency could revoke your Waste Management Licence or Environmental Permit with major consequences on your business.

Certificate of Technical Competency

Auto recycling yard managers in England and Wales have less then 12 months to obtain their Certificate of Technical Competence. Failure to do this could result in businesses being closed down following revocation of waste management licences.

The original deadline of Feb 2011 was extended by 12 months so that all necessary staff could get through the qualification, and to date it is believed that only 10% of all Technically Competent Managers have taken the test, leaving almost 10,000 tests still to be taken in the remaining 10 months.

All End of Life Vehicle or Metal Recycling facilities must have the following ‘Operator Competence’ in place:
Free from environmental convictions
Financially viable
Have technical Competence in place

Operator Competence must remain in place for the life of the facility – this includes ongoing testing with the first deadline of Feb 2012 and ongoing re-testing every 2 years.
Additionally the Technically Competent Manager must be on site 20-25% of EVERY week, so if they go on holiday, they need to be replaced for the time they are away.

There are a number of avenues for obtaining initial competence, and the choice taken can be as follows:
You have already been deemed to be competent by the Environment Agency – you take the on-line general module and up to three specific modules relating to your chosen area of business.
Work through a training agency towards a number of NVQ’s
Take a VRQ – an intensive training course that is equivalent to 6 NVQ’s
Obtain the ESA ‘Corporate Competence’ qualification

One of the best sources of information is the WAMITAB (Waste Management Industry Training and Advisory Board) web site – www.wamitab.org.uk

Technically Competent Management

England and Wales based metal recycling and ELV sites are affected by changes in statutory requirements that dictate management standards.
All licensed or permitted waste management facilities must have Technically Competent Management (TCM) on site.
Managers are required to hold the following qualifications:
For low risk Metal Recycling Facilities, 4 appropriate NVQ’s or completing an Environmental Permit Operators Certificate (EPOC) at an approved training centre.
For medium risk ELV sites, 6 appropriate NVQ units or completing a Vocationally Related Qualification (VRQ) course at an approved training centre followed by a work related project.

Following successful qualification all TCM’s must keep their knowledge updated and will have to show continuing professional competence. All current TCM’s must pass a new competency test before the end of Feb 2011 – note, this includes anyone deemed to be competent under ‘grandfather rights’ – and all TCM’s will be reassessed bi-annually.
You can find more details through the Chartered Institution of Wastes Management at www.ciwm.co.uk/pm/17, or through local training centres/colleges.

The Environment Agency have told me that the TCM needs to be present on site for 20-25% of the week, so one self-employed TCM could work with 4 or 5 yards.

My opinion:
This could be seen as more attacks on the ELV industry, with additional cost in an increasingly tough economic environment, but the regulations did come into force in April 2008 so there has already been two years to complete this. These qualifications mean another step up in professionalism for this industry and show that we are serious about protecting the environment, the health and safety of our workers, and give environmental agencies more opportunities to root out and control illegal operations that bring the car salvage industry into disrepute.