This Operational Guidance (OG) alerts inspectors to the continued planned proactive inspection initiative within the waste and recycling industry during 2012/2013.
The purpose of the initiative is to deliver a program of FOD inspections in 2012/2013 to assess health and safety standards across all waste management and recycling facilities. The work will also:
Band 3 & 4 FOD inspectors should inspect those sites carrying out W&R activities identified locally as 'poor performers' or 'not recently visited'. The processes to be covered represent the full range of waste management and recycling activities.
Explore opportunities for joint working with other regulators, notably the Environment Agency (EA) or Scottish Environmental Protection Agency (SEPA).
HSE maintains a liaison with the multi-agency initiative on metal theft. If inspectors are made aware of instances of metal theft when visiting scrap or metal recycling premises this should be brought to the attention to the local Head of Operations for guidance.
Similarly, if DIOs are contacted by the Police about relevant matters, they should also refer to the local Head of Operations for guidance on a local response.
Where visits are made to organisations within the NLI initiative, the relevant lead inspector(s) should be kept informed of any significant outcomes.
Waste and recycling is a rapidly growing industry. Operations range from local authority and major contractor run sites to small to medium enterprises (SMEs) and sole traders. It is defined as a high risk industry based on its poor health and safety performance during recent years.
Waste and recycling has an overall employee accident rate around 4½ times greater than the Great Britain all industry average and a fatal accident rate around 17 times the average for all industries (based on 2010/2011 statistics.)
This poor performance is reflected in high levels of enforcement arising from previous inspection initiatives to scrap yards, skip hire premises and waste electrical and electronic equipment (WEEE) recycling sites over the last few years.
'Not recently visited' includes sites that have never been visited or were last visited over three years ago. Sites recently visited as part of more recent initiatives (e.g. WEEE sites as part of 2011/12 hotspots) should not be re-visited unless follow up action is required indicating they are a poor performer.
The inspections are not limited to any specific waste and recycling process/activity. As such, a wide range of relevant processes should be visited (e.g. composting, scrap yards, metal recycling, skip hire, material reclamation/recycling facilities etc.) as long as the activity falls into the following SIC 2007 codes:
Several additional indicators may be used to help identify 'poor performers' such as:
Priority targeting should be given to SMEs or micro SMEs (i.e. those employing less than 50 or 10) where known.
There is a potential for some of these visits to overlap with planned visits to organisations that are currently involved in the influencing local authorities and national lead inspector (NLI) interventions. Although not expressly excluded from the 'hotspot' initiative overlap should, if possible, be avoided. However, it is accepted that the relatively high proportion (and range) of waste and recycling activity that some organisations undertake means this may not be achievable in some regions.
Analysis of previous hotspot interventions (over the last 3 years) has highlighted that the most significant issues likely to be encountered will be mature subjects, such as:
As outlined under 'Action', opportunities should be taken to explore joint working with other regulators. For example, a specialist environmental crime task force has been set up to blitz illegal waste sites in England and Wales in the next two years
There is also a Metals Theft Taskforce led by British Transport Police.
The work will take place throughout 2012/13; timing is entirely flexible. Divisions may want to spread out the work over the year or prefer to bundle up visits in specific time frames (e.g. intensive inspection campaigns over a set period of time, which could cover all activities or focus on specific activities).
DIOs should be utilised to take a lead in targeting and identifying local 'poor performers' and sites not recently visited (i.e. last visited over three years ago). They can also liaise with other regulators as required.
It is anticipated that FOD Divisions Northern, Central and Southern will undertake approximately 40 inspections each (120 total).
A total of 60 days B3 Inspector contact time is anticipated (i.e. approx 1 staff year), based on 120 visits at 0.5 days contact time per visit. NB. This does not take into account any non-contact or follow up time, e.g. for enforcement.
Specialist inspector support is likely to be required, especially where enforcement and/or other follow up action are proposed.
FOD inspectors will use COIN in the normal way to record visits via inspection reports (case or service order) and IRFs.
FOD Divisions will provide quarterly narrative reports via the quarterly Dashboard reporting process. It is anticipated that these will include summary details of:
COIN details (case or service order) should be provided that will also allow the Sector further opportunity to analyse the effectiveness and impact of the initiative.
The Sector will make use of the dashboard reports, enforcement action (notices and prosecutions) and overall rating scores to assess the industry's performance.
Inspecting waste and recycling premises has potential to expose HSE staff to safety risks. In particular, there are significant risks on most sites due to vehicle movements. Inspectors must wear high visibility clothing and appropriate footwear at all times and should:
Agriculture, Waste and Recycling Sector, Waste Management and Recycling Team