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Workplan 2014-15: Civic amenity site (CAS) inspection

Summary

This introduces a targeted proactive inspection initiative to assess health and safety standards across civic amenity sites, also known as Household Waste and Recycling Centres (HWRCs). Inspection will take place between 1 April 2014 and 31 March 2015.

Introduction

CASs are a key part of the waste management chain.  They are fixed location facilities where members of the public (and, to a lesser extent, trade customers) can bring a range of waste and recyclables. They are usually operated directly by local authorities (LAs) or on their behalf by private contractors and there is a history of serious and fatal accidents.

This work programme is a follow up to the recently concluded three year inspection initiative (2010 to 2013) with LAs who procure and manage municipal waste and recycling services. It aims to:

Action

DIOs should lead in identifying and prioritising candidates for visits, liaising with other regulators as required, particularly, local EA, NRW or SEPA offices (see the ‘Targeting’ sub-section of ‘Organisation’ and Appendix 1 for scope, information sources and criteria):

B3 and B4 inspectors should:

Background

Waste management and recycling is a rapidly growing industry,considered high risk based on its relative health and safety performance. The overall employee accident rate is around 4.5 times greater than the Great Britain all industries average and the fatal accident rate is around 9 times the average for all industries (see www.hse.gov.uk/statistics/industry/waste-recycling/waste-recycling.pdf).

CASs can expose both workers and members of the public to health and safety risks and there is a history of serious and fatal accidents. See Waste 26 ‘Managing health and safety in civic amenity sites’ and HSE’s Waste Management and Recycling webpage’.

Organisation

Targeting

There are approximately 407 LAs in GB and each LA is likely to have multiple CASs.  Each FOD Division (SANE, Central and Southern) should aim to undertake at least 75 inspections (225 total).

CAS identification

For identifying CASs the following sources are recommended:

Give priority to the following:

Where practical, strike a balance between visiting those run in-house by LAs and those run by private contractor (eg if 90% of CASs in a division are run by LAs then the majority of planned visits should be to LA run sites).

Inspection focus

Focus on the following issues during inspections:

See Waste 26 ‘Managing health and safety in civic amenity sites’ and the HSE Waste Management and Recycling webpage for more details.

Timing

Inspections should be carried out any time between 1 April 2014 and 31 March 2015. The timing is entirely flexible: divisions may spread the work over the year or bundle up visits into specific time frames (eg, intensive inspection campaigns over a set period of time).

Resources

Each FOD Division (SANE, Central and Southern) should aim to undertake at least 75 inspections (225 total). In theory, the overall initiative amounts to less than one inspection per LA area (there are 407 LAs).

112.5 days total contact time has been allocated for this work, based on 225 visits at 0.5 days contact time per visit. NB: this does not take into account any follow up time for enforcement, etc.

Divisions may negotiate with each other to split the work based on staff ratios and other work priorities.

It is expected that FOD the inspections will be carried out by B3 inspectors. However, more experienced B4s may also be deemed suitably competent.

Specialist inspector support may be required, especially where follow up action and enforcement action is proposed.

Recording and reporting

COIN

COIN narrative reports should contain the keyword CAS14 and should provide a summary of the findings under the following headings:

If significant failings are found at sites that are contracted out, the role of the LA as client should be followed up (e.g. procurement and management of the service and in particular monitoring arrangements).
Inspectors should report back to NLIs if the CAS is run by one of the NLI companies listed in SIM 03/2012/10 at http://intranet/operational/sims/manuf/3_12_10.htm and there are significant issues found.

Inspectors are also encouraged to share with the Waste and Recycling Sector Team any issues of particular note (eg particular instances of good and extremely poor performance, with photographs, copies of letter/notices, etc.)

Dashboard

FOD Divisions should also provide quarterly narrative reports via the Dashboard reporting process.  Include summary details of:

Feedback

The Waste and Recycling Sector Team will use the COIN reports, dashboard reports, enforcement action data (notices and prosecutions) and overall rating scores to produce a summary report in the first quarter of 2015/2016.

Findings will be communicated to inspectors via internal briefings (eg FOD news) and the industry via press articles, web pages and through the Waste Industry Safety and Health (WISH) forum.

Health and safety

Inspecting CASs has potential to expose HSE staff to health and safety risks. Inspectors should refer to HSE’s guidance for visiting staff at http://intranet/yourhealthsafety/visiting-staff/index.htm.

In particular, there are risks at CASs due to vehicle movements. Inspectors must wear high visibility clothing and appropriate footwear at all times and should:

Further reference

HSE’s waste and recycling website. Selected sub-sites include:

Inspection Topic Packs. The following may prove useful:

Contacts

Agriculture, Waste and Recycling Sector, Waste Management and Recycling Team

Appendix 1: Agency information sources

The EA provides a public database of all permitted waste sites nationally in England and Wales (on behalf of NRW) which can be used as a starting point. These can be searched to show all sites with Environmental Permits (Waste Operations) by postcode or by LA. The listings provide a site code which indicates the type of site including CASs. See:

In Scotland, SEPA do provide some historical data online, but this would need to be checked for currency. See:

A request for data from their up to date registers can be made directly via three offices (at Aberdeen, Dingwall and Holytown) in person, by email, in writing or by phone. See:

Updated 2015-06-15