COTC & WAMITAB Cover

What is COTC cover?

COTC cover is the provision of a qualified Technically Competent Manager (TCM) to oversee a permitted waste site on your behalf, satisfying the technical competence condition of your environmental permit. It is used when a site has no permanent TCM, or during absence, recruitment or training.

COTC cover, WAMITAB cover, TCM cover: what is the difference?

As a service, none. Ask four operators what they need and you will get four names for the same thing: a qualified person named on the permit, attending the site for the hours the permit requires.

The four terms are not interchangeable, though. They refer to a certificate, a role, and two awarding bodies.

One distinction is more than wording. Government policy recognises two operator competence schemes: the CIWM (WAMITAB) scheme, and the ESA / EU Skills scheme. If your permit specifies a scheme, the person named has to be current under that scheme, not merely qualified under the other one. Worth checking before you assume a certificate covers you. Our holders are qualified under CIWM (WAMITAB).

When operators call us

• The named technically competent manager has resigned, retired or been signed off
• An Environment Agency inspection has flagged that the permit names someone who has left
• A new permit application needs a competent person named before it can proceed
• Someone is working towards their Level 4 and the site needs cover in the meantime
• A permit has been caught by the SR2022 and POPs changes and the competence requirement has moved

What technical competence actually requires

Under the Environmental Permitting (England and Wales) Regulations 2016, a permitted waste facility has to be managed by someone who is technically competent. In practice that means a named manager who holds a Certificate of Technical Competence and belongs to a government-approved competence scheme. There are two approved schemes: the CIWM (WAMITAB) scheme, formerly the Waste Industry Training and Advisory Board, and the ESA and EU Skills scheme. The Level 4 qualification is matched to the risk tier of the site and the waste types the permit authorises, running through low, medium and high risk operator competence.

What you get

Cover that stands up to inspection.

Named on the permit. A qualified holder formally named as your technically competent manager, not an informal arrangement that falls over when the regulator asks.

Attendance in writing. Hours agreed against the 20% minimum and your operating pattern, with records kept so the arrangement is evidenced.

Matched to your risk tier. Low, medium or high risk operator competence, matched to the waste types your permit actually authorises.

We cover waste transfer stations, skip hire, recycling centres, treatment plants, landfill, hazardous, non-hazardous, inert, clinical, and SR2022 / POPs sites.

Which competence level does your site need? See the risk tier table.

Prefer to qualify one of your own team instead of bringing in cover? See our COTC and WAMITAB training guide.

How much the manager has to attend

Being named is not enough on its own. The manager has to attend the site, and the amount is set by the permit rather than by preference. For standard rules permits and older fixed-charge permits, the baseline is at least 20% of operating hours in the first six months. Bespoke permits use a points-based system that runs from 5% to 55% of operating time each week, scored on the complexity, location and emissions of the site, and no permit requires more than 48 hours a week. After the first six months the figure can move up or down with the site’s compliance record. Whatever your figure is, the attendance has to be evidenced if the regulator asks, so we agree the pattern in writing at the start rather than leave it to memory.

What drives the cost

There is no fixed price for COTC cover because every permit is different. The cost is driven by five things, and we need to see yours to pin them down.

Attendance hours. Standard rules permits set a baseline of 20% of operating hours in the first six months. Bespoke permits use a points-based system from 5% to 55% a week, capped at 48 hours. More hours means more cost.

Competence level. A low risk site needs a different qualification from a high risk hazardous treatment facility. Higher risk tiers carry a higher cost because fewer holders are qualified at that level.

Site location. Cover involves physical attendance. A site in a major conurbation with good transport links costs less to service than a remote rural permit.

Duration of engagement. Short-term cover while you recruit or train a replacement is priced differently from an ongoing arrangement. If you already know the timeline, tell us when you send the permit.

Cover or qualify? If you have someone on site who could hold the qualification themselves, training them may work out cheaper than ongoing cover. We can advise on both routes and help you decide.

What happens if the site has no valid manager

The Environment Agency treats a site without a valid technically competent manager as non-compliant with its permit conditions. That can lead to enforcement action, compliance notices, and in serious cases suspension of the permit. The most common way this happens is not a missing manager but a manager whose Continuing Competence has lapsed without anyone noticing.

The two approved competence schemes

Government policy recognises two operator competence schemes for permitted waste facilities in England and Wales. Most permits sit under one or the other, and the person named on your permit has to be current under the scheme that applies to it.

The CIWM (WAMITAB) scheme is run by the Chartered Institution of Wastes Management, formerly branded WAMITAB. This is the scheme the large majority of English and Welsh permits are written against. Qualifications are the CIWM Level 4 Operator Competence units, and competence is maintained through a two-yearly Continuing Competence assessment.

The ESA / EU Skills scheme is run through the Environmental Services Association and EU Skills. A smaller number of permits, particularly those held by ESA member companies, specify this scheme. The qualification pathway and renewal cycle differ from the CIWM route, and a certificate under one scheme does not automatically satisfy a permit that names the other.

If your permit does not explicitly name a scheme, the CIWM (WAMITAB) route is the standard assumption. If it does name one, check that your named person is qualified and current under that specific scheme before assuming the cover is in place. All our holders are qualified under the CIWM (WAMITAB) scheme and maintain current Continuing Competence status.

How to check your named person is still valid

Two things have to be true at once: the person is named on the current version of your permit, and their Continuing Competence is in date. If either condition fails, the site is non-compliant regardless of the qualification certificate on the wall.

The CIWM (WAMITAB) Level 4 Operator Competence qualification, once achieved, does not have an expiry date. What has to be kept current is the person’s Continuing Competence status. Every technically competent person in England and Wales must pass a Continuing Competence assessment every two years. The clock runs from the date on the Primary Qualification Certificate, or from the most recent Continuing Competence Certificate, whichever is later.

Nobody sends a reminder. The certificate does not change colour. The manager keeps turning up. The only thing that changes is a date, and unless someone is tracking it, the first time it surfaces is often during an inspection.

To check: find the permit, find the name, then find that person’s most recent Continuing Competence Certificate and check the date falls inside two years. If either condition fails, the site needs to act now rather than at the next audit.

When we provide cover, keeping the Continuing Competence assessment date in view is part of the arrangement, not an afterthought. If you are not certain your named person is still current, send us the permit and we will confirm whether the competence cover still fits it.