waste disposal commissioner
The external commissioning of a disposal specialist representative is not irreconcilable
The persons responsible for the management and supervision are qualified persons who are in charge of the management, supervision and control as well as compliance with the regulations and official regulations applicable to the operation in the context of waste management activities.
This group of persons has significant in-house control and instruction rights and obligations. If a waste management company has several locations, then at least one person responsible for the management and supervision as well as his / her representation must be named for each individual location.
However, one person may be responsible for several sites if the technical management, supervision and control of the waste management activities and the observance of the applicable regulations are ensured. This possibility also applies if several waste disposal companies are part of a company (representative regulation and leave, illness representation in multi-site organizations). However, it must be ensured throughout that the person responsible can actually perform the management and supervision functions.
An external commission is currently not clearly regulated.
The currently available draft version of the currently under revision LAGA-notification 36 (Vollzugshilfe Entsorgungsfachbetriebe) contains the following passage to § 2 Abs. 2 EfbV:
"The responsible person must instruct, supervise and supervise the certified waste management activities.(Page 29 LAGA release 36 sentence 2)
The necessary personnel equipment requires at least that the persons responsible for the management of the enterprise are employees of the specialist waste management company.
An assignment therefore presupposes that a delegated person will be given the decision-making and participation powers necessary for the performance of the management tasks. This can not be represented by external agents.
QHSE Compliance Division Europe