Response 447235423

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About You

What is your name?

Name
David Bremner

Are you responding as an individual or an organisation?

Please select one item
(Required)
Ticked Individual
Organisation

Part 2: Policy Overview

1. Do you agree with the benefits set out here?

Please select one item
Ticked Yes
No

2. Are there any other comments you would like to make on Part 2?

Are there any other comments you would like to make on Part 2?§
It should be clearer that authorisation holders can keep their existing authorisations etc and do not have to adopt the new IAF, and there is no time constraint for an undertaking to move to the IAF

3. How could SEPA better support the uptake of new technologies?

How could SEPA better support the uptake of new technologies?
Publish more of them on their website

Part 3: Key features of the new framework for authorisation holders.

4. Do you agree that the framework should include a set of universal outcomes?

Please select one item
Ticked Yes
No

5. If so, are the outcomes proposed the right ones?

Please select one item
Ticked Yes
No
Comments:
yes, but is should be made clear if these will be detailed in authorisation, permits etc or whether terms such as BPM or BAT will continue to be used.

6. Do you see any opportunities within your sector for industry- led guidance to be produced to support this approach and how could it support you to deliver better?

Please select one item
Ticked Yes
No
Comments:
As above

7. Do you understand the descriptions of the regulated activities in Annex 2?

Please select one item
Ticked Yes
No

8. Do you agree that these are the right factors for SEPA to consider?

Please select one item
Ticked Yes
No
Comments:
These seem sensible, but further guidance should produced once these are adopted

9. Do you agree that SEPA should consult on the guidance setting out the likely tier of authorisation for particular activities?

Please select one item
Ticked Yes
No

10. Do you agree that standard rules will deliver the benefits we have set out?

Please select one item
Ticked Yes
No

12. Do you agree that SEPA and Scottish Ministers should have the ability to make GBRs?

Please select one item
Ticked Yes
No
Comments:
This will make life easier for undetakings and SEPA, so long as the undertaking follows the GBRs

13. Do you agree that all regulated activities should have an authorised person responsible for overall compliance and that this person should be named in a permit and registration?

Please select one item
Ticked Yes
No
If not why not?
But consider changing the term from authorised person to authorised organisation (for example) as it be more than one person within the organisation who is responsible

14. Do you think it is proportionate to require the person in control to be the person that notifies an activity in the notification tier?

Please select one item
Yes
Ticked No
Comments:
Might be more than one person

15. Do you agree that SEPA should include more than one person as the authorised person where appropriate?

Please select one item
Ticked Yes
No
Comments:
See above

17. Question 17 – Do you think the core requirements set out here will deliver the right approach to FPP for the integrated authorisation framework?

Please select one item
Ticked Yes
No

18. Do you think that the criteria set out above will achieve the stated purpose of the FPP test?

Please select one item
Ticked Yes
No

19. Do you agree with the proposed application processes?

Please select one item
Ticked Yes
No
Comments:
The time periods for the regulator to reply seems proportionate

20. Do you agree with the proposal to have a statutory determination period of four months for the majority of permit applications?

Please select one item
Ticked Yes
No
If not, what do you think the determination period should be?
As above

25. Do you agree with the proposals for surrender?

Please select one item
Ticked Yes
No

26. Do you agree with the proposed approach to enforcement notices set out above?

Please select one item
Ticked Yes
No
Comments:
Seems a reasonable proposal

Part 7: Radioactive Substances

39. Do you agree that it is appropriate to have controls on radioactively contaminated materials whilst they remain on the premises where they were contaminated?

Please select one item
Ticked Yes
No

40. Do you foresee any practical implications of the proposal to have controls on radioactively contaminated materials whilst they remain on the premises where they were contaminated?

Do you foresee any practical implications of the proposal to have controls on radioactively contaminated materials whilst they remain on the premises where they were contaminated?
No this seems a reasonable approach and it is what the undertaking should expect to have to do. Although not directly related to this question the following is in the consultation document: 7.2.4 The current legislation that we propose replacing with the integrated authorisation framework is: • The Radioactive Substances Act 1993 (RSA 1993); • The Radioactive Substances (Basic Safety Standards) (Scotland) Direction 2000 (BSSD); • The High-activity Sealed Sources and Orphan Sources Regulations 2005 (HASS Regs); • The HASS (Scotland) Directions 2005; and • The Radioactive Substances Exemption (Scotland) Order 2011. The above suggests for example that RSA93 will be replaced with the IAF, please confirm that RSA93 will still exist or not

43. Do you agree that we should continue to exclude the public from the scope of the radioactive substances regulatory regime?

Please select one item
Ticked Yes
No

44. Do you agree with the proposed radioactive substances regulated activities?

Please select one item
Ticked Yes
No

45. Do you agree with the proposals for applying the new regulatory regime to nuclear licensed sites?

Please select one item
Ticked Yes
No

46. Do you foresee any problems with removing the requirement to display certificates?

Do you foresee any problems with removing the requirement to display certificates?
No, this will remove an additional burden on undertakings

47. Do you agree that SEPA should have the power to impose conditions in an authorisation requiring the permit holder to carry out operations off their site?

Please select one item
Yes
Ticked No
If not, why not?
Need more clarity on what this might mean