COTC Cover

COTC/WAMITAB Cover

Environmental Permitting Regulations 2007. From the 1st of April 2019 all sites must provide the details and dates of births of the nominated COTC holder on the Quarterly Waste Return to the Environment Agency.

COTC cover is an essential way for waste management and recycling facilities to meet their legal obligation to have a Technically Competent Manager (TCM) on-site for at least 20% of their operating hours.

A TCM must hold a Certificate of Technical Competence (COTC) and the failure to have a TCM on-site for the minimum period is an offence punishable by unlimited fines and, in the event of a serious environmental incident, possible jail time.

Your TCM should have completed relevant COTC training, for example the jointly developed technical competence scheme by the Chartered Institution of Wastes Management (CIWM) and the Waste Management Industry Training and Advisory Board (WAMITAB).

This gives them a good understanding of the issues surrounding waste management, including specific types of waste like clinical and hazardous waste, as well as aspects of recycling such as processing recyclable scrap waste.

COTC Cover, Roger on site.

Who Needs COTC Cover?

Permitted waste management facilities and waste processing sites should have a permanent TCM or suitable COTC cover, including:

  • Anaerobic Digestion Facilities
  • Composting Sites (including composting in vessel)
  • Household Waste Recycling Centres
  • Landfill Sites
  • Material Recycling Facilities
  • Covid-19 testing Centers
  • NHS Hospitals
  • Clinical Waste Transfer Stations
  • NHS Nightingale Hospitals
  • Clinical Waste Companies

COTC cover can give you the skills you need while you appoint a permanent TCM, while your TCM undergoes training or renews their accreditation, in the event of prolonged sickness absence, or general interim COTC cover for any period when you are left without a TCM.

COTC Cover is an Ongoing Commitment

You must always have a designated TCM, who should be on-site for at least 20% of your operating hours. The Environment Agency usually will not consider new permit applications without a named TCM.

A TCM must also undergo regular assessments in order for their COTC to remain valid – under the CIWM/WAMITAB scheme this is required at least once every two years.

The only exception is if you apply for a new permit for a waste management facility that is not a landfill site, you may be given a period of grace to appoint a TCM. However, you should still meet the minimum requirements outlined by a suitable COTC scheme.

COTC Cover for Specific Types of Waste

The TCM’s role is to audit the premises, identify any concerns about compliance, and inform the site operator so action can be taken to operate within the terms of your permit and any relevant environmental regulations.

In some cases, there can be specific demands associated with certain types of waste, which a competent TCM should take into account.

Clinical Waste

You may face additional obligations to avoid dispersing bioaerosols, biological material and dangerous implements like needles, especially if you operate close to a residential area.

Commercial Waste

There are extra rules governing the disposal of commercial waste. As a waste site operator, you must ensure you follow these rules and only process acceptable forms of commercial waste.

Hazardous Waste

Hazardous waste includes a wide variety of different solids and fluids that could contaminate land, harm plants and wildlife, or cause a risk of harm to humans. There may be specific regulations for the processing and safe disposal of different types of hazardous waste.

Scrap Metal

Recyclable scrap metal can fall under a different type of waste regulation. Rather than minimising contamination or physical harm, these regulations aim to maximise the proportion of waste that is reused, recycled or used to generate energy.

If your waste processing facility handles any of the above types of waste, or other specific waste streams not listed here, make sure you have specialist COTC cover in place with a Technically Competent Manager who understands the unique issues you face.

Clinical/Medical Waste
Commercial waste
Hazardous Waste, gas canisters
Scrap waste, heap of scrap metal

Frequently asked questions

What is COTC cover and why do I need it?

COTC  stands for Certificate of Technical Competence and shows that you have a Technically Competent Manager (TCM) on-site at your waste management facility. If you are left without a TCM for any reason, COTC cover gives you access to a freelance TCM so that you can continue to meet your legal obligations to process waste and recycling.

Who needs CoTC cover?

If you operate without a permanent TCM for any length of time, you might need COTC cover to avoid breaching the regulations. COTC cover can be used for prolonged sickness absences, if you have trouble finding a permanent TCM, if you just bought a waste management business and have no certified TCM, and other similar reasons.

How often does the TCM have to be on-site for?

A TCM should be on-site for at least 20% of your operating hours, or longer. This is the case for both standard rules permits, as well as Tier 2 permits for waste operations. The TCM should hold a Certificate of Technical Competence (COTC) and ensure your site operates within the requirements of your permit.

Is it against the law not to have a TCM on a waste and recycling site?

Yes. A TCM is a legal requirement under the Environmental Permitting (England and Wales) Regulations. You will also need to have a TCM in place when you make a new permit application, before the Environment Agency will grant your permit.

Can I be prosecuted for not having COTC Cover when operating a waste and recycling site?

Yes. Failure to have a TCM on-site for at least the minimum 20% of your operating hours is an offence. You can be prosecuted and could face an unlimited fine. If a serious environmental incident occurs on your premises and you do not have a TCM, you could be sent to prison.

What We Do

Recycling Training Services provide WAMITAB-qualified TCM cover for landfill sites, non-hazardous waste facilities, clinical treatment facilities and more.

We cover the whole of the UK and provide daily reports, as well as being on-hand to answer any questions you have about waste operations on your premises, as you would expect from any experienced TCM.

You can call us on 07710 200 333, email us at info@recyclingtrainingservices.co.uk or follow us on all the main social media platforms for regular news and updates about our services.