Attendance hours: what your permit actually requires

Ask three operators how long their technically competent manager has to be on site and you will often get the same answer: twenty per cent. It is the figure everyone repeats, and for a lot of sites it is right. For plenty of others it is not, and getting it wrong is the kind of thing an Environment Agency officer notices.

Here is how the attendance requirement actually works.

The 20% figure is a baseline, not a universal rule

For standard rules permits, and for older fixed-charge permits issued before April 2018, the manager has to attend at least 20% of the site’s operating hours during the first six months. That is where the number comes from, and if you hold a standard rules permit it is a fair starting point.

Bespoke permits use a points system

Bespoke permits do not use a flat percentage. They use a points-based system that scores the site on its complexity, its location and its emissions. The total points translate into a required attendance figure that runs anywhere from 5% to 55% of operating time each week. A simple, low-risk operation sits near the bottom of that range. A complex site in a sensitive location sits near the top.

There is a ceiling on all of it: no permit requires the manager to attend for more than 48 hours in a week, however long the site runs.

The figure can move after six months

The first six months are treated as a settling-in period. After that, the required attendance can go up or down depending on how the site has performed on compliance. A good record can reduce the hours. A poor one can increase them.

Attendance has to be evidenced

Being named on the permit and turning up are not the same thing, and neither is enough on its own if you cannot show it. If the regulator asks, you need records that demonstrate the manager attended for the hours the permit requires. An arrangement kept in someone’s head is treated much the same as no arrangement at all.

This is why, when we provide COTC cover or WAMITAB cover, we read the permit first, work out the actual figure for that site, and agree the attendance pattern in writing before anyone is named on anything.

What to check on your own permit

• Is it a standard rules permit or a bespoke one? That decides which method applies.
• If bespoke, what attendance figure did the points assessment produce?
• Are you actually meeting that figure, and can you prove it?

If you are not sure what your permit requires, send it to us and we will tell you the figure rather than guess at it.