A recent change to the continuing competence regime appears to have been made without any formal announcement. We first came across the change in an Environmental permit applciation to Natural Resouces Wales when the clients Continuing Competence Certificate for Hazardous Waste Treatment was rejected for a non-hazardous treatment permit application.
The officer referred to the WAMITAB.CIWM scheme website which now includes the note;
“Note: it is no longer the case that a certification for hazardous activities will be accepted for non-hazardous activities. TCMs responsible for sites that accept hazardous and non-hazardous waste will need both of the appropriate hazardous and non-hazardous certifications, as stated on the C/WM/WAMITAB website, under Risk Tier Tables.”
“If you are using a hazardous waste qualification (e.g. HROC6) as evidence of technical competence to cover a non-hazardous waste activity (e.g. non-hazardous transfer with treatment}, you need to take the hazardous waste continuing competence test (e.g. TMH) to maintain the original award and the corresponding non-hazardous waste continuing competence test (e.g. TMNH).”
Its not clear when this change was made and certainly the industry does not seem to have been notified in advance.
This means that if your original qualification was for hazardous waste, but your site also accepts non-hazardous waste then you will be required to site both the hazardous and non-hazardous continuing competence tests to be a qualified TCM for the on site. for our staff, who provide CoTC cover on a range of sites this has meant us having to sit two or three tests as the current test only allows you to select up to three site types in the site specific part of the test.
This means that a good number of operators having completed the relevant hazardous continuing competence qualification will also need the non-hazardous qualification if their site accepts non-hazardous waste. It may also result in some managers sitting two tests as the maximum number of specific tests available at Pearson Vue for each test sitting is three.
Our staff now hold continuing competence in Hazardous and Non-Hazardous Treatment and Transfer, Clinical Waste, ELV and Metal Recycling, so if you’re put in a position where you are told that your qualification is no longer valid we can help out whilst you book a new test.