The requirement for correcting CAR non-compliances will be given a due date which must be met to prevent enforcement action being taken so it is important to act quickly.

Compliance Assessment Report Breach Corrections

Compliance assessment report breach corrections

If you have recently had an EPR Compliance Assessment Report (CAR) which has recorded breaches of your Environmental permit we are able to help.

GPT have a wealth of knowledge in correcting non-compliances raised in CAR reports to safeguard against a criminal prosecution and/or suspension or revocation of your permit.  The requirement for correcting these non-compliances will be given a due date which must be met to prevent enforcement action being taken so it is important to act quickly.

The below are extracts from the Compliance Assessment Summary with examples of how we can help.

B1. Engineering for prevention & control of pollution – infrastructure.

We offer a vast range of services related to design, repair, replacement and installation of infrastructure to control pollution such as interceptors, secondary containment, tertiary containment and spill control products.

In addition to the above services we also offer a Liquid Pollution Risk Assessment to establish any activities on site which pose a risk of polluting the environment and identify proportionate control measures to reduce your risk to a reasonable level. Ensuring you have adequate control measures for your risks on site will help to achieve legal compliance for permitted activities and reduce the likelihood of causing pollution.

B2. Closure & decommissioning – infrastructure.

We can offer industrial cleaning and decontamination and contaminated land services if you are closing down a site/activity.  We also offer contaminated land services related to the Industrial Emissions Directive for permitted activities.

B3. Site drainage engineering (clean & foul) – infrastructure.

We offer a range of drain services relating to foul, storm and combined systems including mapping surveys, CCTV surveys and drain repair.

B4. Containment of stored materials – infrastructure.

Primary Containment

We can test pressure test tanks and pipework to ensure they do not have any failure points and can undertake periodic visual inspections of tanks and storage containers e.g. IBCs.

Secondary Containment

We can undertake visual and hydrostatic testing of your bunds to ensure they are watertight.  We can also offer consultancy services to ensure they are compliant with relevant legislation e.g. CIRIA 736.  If bunds are found to be non-compliant we can design bund upgrades and repair and/or reline failed bunds.

Tertiary Containment

In addition to primary and secondary containment we can offer a range of solutions to ensure you have adequate tertiary containment in the form of drain closure valves etc.

C1. Staff competency/ training - General management

We offer ISAS accredited spill response training made bespoke to your site specific risks and procedures. We can also offer Train the Trainer courses.

C2. Management system & operating procedures - General management

We are able to work alongside your in house team to create Standard operating Procedures and help you to ensure your permitted activities are adequately covered in your Environmental Management System. We can also undertake EMS auditing inspecting your records to verify you are complying with the requirements of your EMS.

C3. Materials acceptance- General management

Although we can’t be responsible for accepting materials on your site we are able to write procedures to make the process as low risk as possible.  For example tanker deliveries pose a large environmental risk which is often overlooked.  We can write site specific tanker delivery procedures to ensure staff are taking the necessary precautions and can install infrastructure to reduce the risk such as drain closure valves which can be closed proactively before a delivery vehicle enters the delivery area.

C4. Storage handling, labelling, segregation- General management

We provide storage solutions of all shapes and sizes to allow you to safely store hazardous substances and segregate incompatible substances. In addition we can help with classifications of hazardous waste streams.

D2. Accident, emergency & incident planning - Incident management

We can assist in writing spill control and emergency incident procedures and provide training to ensure your staff are trained on how to implement them. We are also 24/7 UK spill accredited Emergency spill responders to assist in spill clean-up if you do have an incident.

E2. Land & Groundwater – Emissions

Emissions to ground and the groundwater have the potential to cause serious environmental damage, our contaminated land team can work with you to assess any remediate any ground or groundwater contamination. We can also undertake time series monitoring on onsite groundwater monitoring wells to highlight any changes in baseline conditions.

E3. Surface water – Emissions

We are able to ensure your surface water emissions are within compliance levels by installing and maintaining the adequate infrastructure e.g. interceptors up stream.  We can also undertake water sampling to confirm discharges are below the required levels for proof to regulators e.g. the Environment Agency. We can also install infrastructure such as MCERTS accredited flow meters and pH probes to continually monitor discharge.

4. Sewer – Emissions

We are able to ensure your foul water emissions are within permitted parameters by installing and maintaining the adequate infrastructure e.g. interceptors, DAF plants up stream of your compliance point.  We can also undertake periodic effluent sampling or install MCERTS accredited infrastructure to confirm discharges are within the parameters set out by the sewage undertakers.

G1. Monitoring of emissions & environment - Monitoring and records, maintenance and reporting

We can undertake periodic sampling to monitor effluent and surface water discharges. Alternately we can specify, supply, install and maintain infrastructure such as flow monitors, pH sensors and turbidity sensors to monitor your emissions.

G3. Maintenance records - Monitoring and records, maintenance and reporting

We offer maintenance of various environmental infrastructure such as interceptors, interceptor alarms, bunds, tertiary containment devices.  Following maintenance being conducted we will provide you with a maintenance report, providing 3rd party validation that proper maintenance has been conducted.

Environmental Permitting Regulations CAR FAQs

What is the Compliance Classification Scheme?

The Compliance Classification Scheme (CCS) is used to standardise assessment and rate the severity of any non-conformances.  They will be rated as C1, C2, C3 or C4 breaches of your permit depending on the severity of the breach and the reasonably foreseeable environmental damage as a result of the breach. C1 breaches are the most severe and C4 the least.  Operators will be awarded a compliance rating for each site that reflects an operator’s performance over the course of a year. Less compliant sites will pay a surcharge on their annual charge, while operators with perfect compliance records can receive a discount.

How will we be assessed/inspected?

The Environment agency can undertake desk based assessments e.g. ensuring you are submitting your required paperwork or can undertake site inspections.  Inspections are usually planned, but can be performed unannounced. Environment Agency staff will look around your site and ask questions about what you’re doing. They may ask to see documents or talk to your staff.  The EA may also take water samples of your groundwater or your permitted water discharge to check any discharges are within compliance levels.

Why would I be Inspected?

Waste operations, installations, complex flood risk activities and complex water discharges and groundwater activities, will definitely be assessed or inspected.

It is also likely you will be inspected if you discharge to surface waters or groundwater in a sensitive or vulnerable area, such as a groundwater SPZ (source protection zone).

Other reasons you may be assessed or inspected include:

·         If there has been a pollution incident at your site, or in your area

·         If there has been a flood incident at your site (for flood risk activities)

·         If someone has made a complaint about your activity

What is a Compliance Assessment Report?

If Environment Agency staff carry out an assessment, inspection or attend an incident, they will complete a Compliance Assessment Report (CAR) and give you a copy.

The CAR will record anything you’re doing that does not comply with your permit and state what you have to do to correct this, giving timeframes of when this must be completed by. A blank example of a CAR can be downloaded HERE as can a completed example HERE  (the completed example has been downloaded from the .gov website and is as such in the public domain but has been anonymised out of courtesy to the business).


The Environment Agency may take action if they suspect you’ve broken the law, or if they think you are going to break it imminently. Their actions might include:

·         giving you advice

·         changing your permit conditions

·         serving you with an enforcement notice/remediation notice, which will state what you have to do to fix problems and set a due date for this

·         serving you with a suspension notice if there’s a risk you might cause pollution - this means you have to stop carrying out your activities

·         prosecuting you


The Environment Agency can carry out work to address a problem and recover the costs from you if:

·         your activity has caused serious pollution

·         your activity is creating a risk of serious pollution

·         you’ve deposited waste illegally and not removed it when told to

·         you’ve caused polluting substances to get into a watercourse or the substances are in a place where they are likely to get into a watercourse - or you’ve knowingly allowed this to happen

·         you have carried out any unauthorised works or caused harm to flood risk, land drainage or the environment (for flood risk activities)

How many people fail EPR Compliance Assessment Reports (CAR)?

If you have been found to have a breach under the Compliance Classification Scheme CCS you are not alone. The Environment Agency work tirelessly to protect the Environment by ensuring permits are being adhered to.  In 2018 the EA found over 14,000 breaches.  Luckily most of these were minor with only 13 being C1 breaches, however it is extremely important to fix any breaches as soon as they are discovered.  The EA will provide timelines for fixing any breaches in section 2 of your CAR.

What if I disagree with a decision?

If you disagree with the EA’s decision in your CAR you have 28 days to challenge the decision. You can challenge the non-compliance scores and comments through the provision of additional information or evidence.

Need advice for services and products? Call us now 01656 741 799

Geo Pollution Technologies (UK) LTD - company number - 04689357


GPT head office is based in South Wales and covers all areas of South Wales, West Wales and Mid Wales including Cardiff, Swansea, Bridgend, Newport, Port Talbot, Powys, Llanelli, Neath, Pembrokeshire and Aberystwyth.

We also cover the South West of England from our premesis in Exeter including Cornwall, Devon, Taunton, Redruth, Truro, St Austell, Falmouth, New quay, Torquay, Paignton, Bristol, Plymouth, Bath, Gloucester and Somerset, .

We also operate across the midlands, London, Birmingham, Leicester, Northampton, Derby, Stoke, Nottingham, Coventry, Liverpool, Worcester, Southampton, Swindon, Manchester, Sheffield, Slough, Heathrow, Leatherhead and Surrey.