A temporary regulatory position statement to support the management of high-activity sealed radioactive sources during the COVID-19 public health emergency has been developed for Scotland.
Where compliance with a SEPA Permit or other regulatory requirement is not possible for an individual site(s), a type of activity or for a sector, we may temporarily take a regulatory position that any failure to comply with those requirements will not be treated as a non-compliance for compliance assessment or enforcement purposes. This will be where that non-compliance is unavoidable and solely as a direct result of the impact of EU Exit or COVID-19 and will not lead to significant environmental harm.
We are only likely to consider taking a temporary regulatory position if the person contacts us at an early stage to advise us of a non-compliance or potential non-compliance, and we are satisfied that:
If we take a temporary regulatory position we expect the person to:
SEPA expects people to have business continuity arrangements in place to ensure compliance with their SEPA permit or other environmental regulatory requirements during EU Exit and COVID-19. We are clear we expect everyone we regulate to continue to comply with Scotland’s environmental laws.
Where compliance with a SEPA Permit or other regulatory requirement is not possible for an individual site(s), a type of activity or for a sector, we may temporarily take a regulatory position that any failure to comply with those requirements will not be treated as a non-compliance for compliance assessment or enforcement purposes. This will be where that non-compliance is unavoidable and solely as a direct result of the impact of EU Exit or COVID-19 and will not lead to significant environmental harm.
This temporary regulatory position statement applies to authorisations under the Environmental Authorisations (Scotland) Regulations 2018 and registrations under the Radioactive Substances Act 1993 for the management of high-activity sealed radioactive sources.
This temporary regulatory position statement only applies in Scotland and where non-compliance is unavoidable and a direct result of emergency resulting from COVID-19 outbreak.
Let us know as soon as possible if you think that you may not be able to comply with the conditions of your authorisation or registration.
You should advise both your site inspector, using normal routes, and email us using our online contact form, with the circumstances and any alternative arrangements that you are putting in place in accordance with EASR standard condition A9.