CL:AIRE recently had to apply both its Qualified Persons (QP) and Project Team Disciplinary procedures.
A project was flagged advertising a Receiver site clearly intending to apply a gate / disposal fee, via the whistle-blow service. When challenged it was clear that liaison with the EA / NRW had not been carried out to allow this as per the guidance note on the QP Declaration and FAQ (Why were extra questions added to the Declaration in October 2016 e.g. applications for recovery permits & contractual arrangements?).
Following both the QP and Project team disciplinary procedures, CL:AIRE carried out an Investigation Panel process requesting information from all parties to clarify the situation.
The QP confirmed that they had not explicitly asked the project team as to whether a fee would be applied. The project team indicated that an incorrect email template normally used for sites with disposal permits had been used in error. They also confirmed that no money had been charged to-date.
Discussions were held between all parties to go through the key points reiterating the FAQ.
Warning letters were issued to both the QP and Project Team, these will remain on record at CL:AIRE and will be recognised in the event of future use of the procedures.
If a project using the DoW CoP intends to or needs to charge some form of unit rate charge e.g. a gate or disposal fee - they should make contact with the local EA / NRW waste team as early as possible and arrange a formal, paid for, review of the proposals. Only once this is done should the QP be in a position to tick all the boxes in Q16 of the Declaration.