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Are Regulators Getting Tougher with Trade Effluent?
We have noticed in the last 12 months a marked increase in the number of clients who have been having problems with their trade effluent consents, with the regulators (your local water company) starting to increase the amount of enforcement work they are undertaking. Clients from across the country have been experiencing these difficulties so it would seem that this is an industry wide trend rather than an increase in enforcement by a particular water company.
As team leader in this area I therefore pulled the team together to see if we could come up with some answers as to what was driving this increase in work, and more importantly, how this might help us focus on the technical side of what the regulators are finding fault with.
As a result of this analysis we have found that our clients issues can be split into 3 categories:
- The client did not have a trade effluent consent and the regulator has caught them discharging. In these sorts of cases we start off by assessing the nature and composition of their trade effluent and details of their sites drainage, so they can apply for a trade effluent consent (or we can assist them with their application and negotiations). It’s not clear if regulators are “catching” more people because of more investigations of the sewer network, or if this is a drive to find more income streams, but in most cases the regulator is happy once the permit or consent is in place and they are getting an income from their charges.
- Client knows they are breaching their existing consented limits. This issue can either be proactive (the client is aware of the breach, but the regulator is not) or reactive (the regulator has informed the client of a breach) and the client needs help with the negotiations to prevent enforcement and to ensure that they remain within their consented limits in the future. Again, it is likely that this may be driven due to the water companies reviewing their compliance samples in more detail now.
- Clients needing a new consent due to a change of premises address, due diligence on a private sale of a business or increase in manufacturing which requires a proactive approach to consent negotiations to ensure that they won’t breach their consented volume or concentrations limits. Most such moves require more than one type of permit and we are finding that when a company submits a planning application or Environment Agency waste permit then the need for a Trade Effluent Consent is now being looked at.
If you think you may need help with your trade effluent consent because you have one of the above issues, then please get in touch via email@example.com or read more about our service below.