SR2022 and POPs: what the standard rules changes mean for your competence

Two sets of changes have quietly reshaped a lot of waste permits in recent years: the SR2022 consolidation of the standard rules permit sets, and the rules on waste containing persistent organic pollutants, known as POPs. If your permit was caught by either, it is worth checking that your technical competence still lines up with what the permit now authorises.

What the SR2022 changes did

The Environment Agency periodically reviews and consolidates its standard rules permits. The SR2022 round updated and merged several rule sets, which means some operators are now working under a permit that reads differently from the one they originally applied for, even though the site on the ground has not changed. When the permit wording moves, the competence expected of the named manager can move with it.

The Environment Agency sets out which technical competence qualifications map to the consolidated standard rules permits in its regulatory position statement RPS 326. If you hold a standard rules permit, that is the document that tells you which qualification the named person needs.

What POPs changed

Persistent organic pollutants are chemicals that do not break down easily and accumulate in the environment. The clearest example operators deal with is waste upholstered domestic seating, such as sofas and armchairs, which commonly contains POPs in its foam and fabric. This waste has to be kept separate from other waste, must not be landfilled, and has to go for incineration.

For a lot of transfer stations and household waste sites, that changed how the waste is stored, segregated and moved on, and in some cases it changed what the permit authorises the site to do. A change to the authorised activities can change the competence tier the site sits in.

Why this matters for competence cover

The risk tier of a site, and therefore the qualification the named manager needs, is set by the waste types the permit authorises and what the site does with them. When a consolidation or a POPs change alters either of those, a manager who was correctly qualified for the old permit may not be the right match for the new one.

This is one of the more common reasons operators come to us for COTC cover or WAMITAB cover: the permit moved, and the competence arrangement did not move with it.

What to check

• Has your permit been reissued or consolidated under SR2022?
• Does the current permit still describe the activities you actually carry out?
• Do you handle POPs waste such as upholstered seating, and is it being segregated correctly?
• Does your named manager’s qualification still match the tier the current permit sits in?

If any of those give you pause, send us the current permit and we will confirm whether your competence cover still fits it.