Testing times for technical competence
Modern waste management now requires a more a flexible approach when it comes to measuring technical competence. Claire Poole looks at how the industry is addressing this key area
More legislation and stricter compliance requirements, the proliferation of treatment technologies, and the industry's worrying health and safety record all point to the need for a new approach. Equally important is the professional image of the industry, particularly given the higher profile that waste enjoys today. The recent consultation by Defra, part of its wider environmental permitting programme (EPP) review, considered two schemes - a joint proposal from ESA and EU Skills and a joint proposal from CIWM and Wamitab.
While taking quite different approaches, the two proposals are fairly complementary. Now that the consultation has been concluded, final amendments to reflect the consultation responses will be put to Defra in the next few weeks. Whatever the outcome, the end result will be that operators will be required to be compliant with the approved scheme(s), so it is important that the industry takes the time to respond on this important issue.
The joint CIWM/Wamitab scheme aims to provide a relatively simple competence framework that meets the needs of an increasingly complex industry. It encompasses three key changes to the current technical competence framework that will address priority issues raised by Defra concerning proportionality, flexibility and continuing competence.
Assess the risk and cater for it
Firstly, the scheme acknowledges and caters for different risk levels to reflect the range of waste treatment technologies in use now or in development. Where the previous full NVQ was essentially a 'one size fits all' approach, the suggested scheme proposes three risk levels and makes an initial attempt to populate the categories. That said, CIWM has emphasised the need for consultation with the industry before the risk matrix is finalised. At present, the proposal suggests:
- low risk - encompassing inert waste storage, transfer and treatment operations and green waste composting
- medium risk - covering non-hazardous transfer and treatment operations, biological treatment other than green waste composting, and potentially civic amenity sites and contaminated land operation
- high risk - all previously PPC regulated waste operations including landfill and most hazardous waste transfer, treatment and disposal activities.
Uptake opportunities increased
As well as catering for different learning preferences, this system also encourages quicker and wider uptake of technical competence by opening up more opportunities. Candidates taking the VRQ, for example, don't have to be observed on-site to get the qualification. This means that personnel can be trained prior to a facility becoming operational and professionals looking to transfer into waste management from other industries can get trained before they make the move.
Importantly for an industry that is working hard to 'professionalise' its image, it also gives people a more flexible way of getting the qualifications they need to move up the waste management career ladder in the future. An important factor in the design of the scheme is that it should not have a disproportionate impact on industry. Therefore the original 100% attendance times proposed have been changed to reflect Environment Agency guidance. In addition, anyone who is 'deemed competent' at present or has been assessed by the EA will not have to gain a new qualification.
However, in a sector that is changing so fast, maintaining professionalism is very important and so one of the key elements in the CIWM/Wamitab scheme is 'continuing competence'. Applicable to all technically competent persons, the proposal is for a two year competency period. During this time, candidates must update themselves and demonstrate their knowledge about subjects specified in a syllabus set every two years by a cross-industry working party.
Candidates can choose how they update their knowledge - for example through in-house or external courses or workplace coaching - but they must complete the learning and be tested successfully on it within the two-year timeframe. Although the details of how the testing will be carried out have not been finalised, there are likely to be around 60 test centres across the UK and further discussion is now taking place about the choice of test format, including online delivery.
Claire Poole is education & training manager at CIWM