The EA has today issued the following information, should you find yourself struggling to meet the technically competent manager attendance requirements for your site.
TCM attendance during COVID-19 restrictions:
- We understand that many operators will be concerned about how they can satisfy attendance requirements whilst sites are running on reduced staffing levels and staff may well be ill of self-isolating. We will be pragmatic in our approach.
- Firstly, TCM attendance hours are within the EA advice and guidance on Gov.uk and are an indication that site activities are being overseen by a technically competent manager.
- There is still a requirement to have a technically competent person as a requirement of the permit.
- There may be instances where the TCM is self-isolating and or sick and cannot attend the site. In this case the operators should already, by way of their EMS and operations training be able and capable of operating the plant or site safely.
- To that effect the operators should review their training and capability structure. They should ensure roles and responsibilities and accident plans are in place and reviewed to make sure they are fit for purpose.
- Ensure that remote systems are operational. Alarms systems are fully working, where they are required.
- There should be a responsive duty roster to respond to incidents.
- Where the site cannot be safely monitored then the operator must notify us.
- Operators should record if their nominated TCM(s) are self-isolating in the site diary.
Difficulties in taking Continuing Competence tests
- Although neither the EA, or WAMITAB are currently aware of any restrictions at Pearson Vue test centres, this is a fast evolving situation. In view of this and until the Governments advice on social distancing is relaxed, we will not regard the failure to complete a continuing competence assessment that becomes due after 16 March as being a failure to comply with the scheme. If this applies to you or your TCM, please contact both the EA and WAMITAB as soon as possible to let us know.