Peter Jinks

In 2022, India added end-of-life tyres to the list of wastes that are covered by extended producer responsibility (EPR) rules. Since then, manufacturers of tyres in India have been required to buy EPR certificates issued by permitted recyclers of waste tyres to reflect the ‘polluter pays’ principle.

‘Polluter pays’

EPR schemes oblige manufacturers to pay for some of the costs of managing and recycling their products at end of life. The idea is to minimise environmental harms and drive up the overall rate of recycling, while shifting the burden of dealing with waste from taxpayers and local authorities to those that produce it. E-waste, waste plastic and waste oil are all now subject to Indian EPR regulations.

Government recycling targets

Underpinning EPR schemes are government targets for recycling that waste generators must meet. Producers buy EPR certificates at a level that corresponds to a set percentage of the goods they manufacture. In 2022-23, Indian tyre manufacturers were required by government to buy EPR certificates corresponding to 35% of the tyres they produced, which rose to 70% in 2023-24, and 100% in 2024-25.

How Indian EPR works in theory

According to India’s Hazardous and Other Wastes Amendment Rules, 2022, tyre producers, importers of new and scrap tyres, recyclers, and re-treaders are obliged to register on the Central Pollution Control Board’s EPR portal. This is where producers and importers are supposed to buy EPR certificates from recyclers to meet their obligations, rather than directly managing and recycling their own waste.

Certificates are generated by recyclers based on the quantities of tyres they re-process, with each recycling method carrying weightage points that determine the number of credits awarded. Tyre manufacturers and importers are also meant to provide facilities for collecting worn tyres and direct them to licensed recyclers or waste processors, along with fulfilling various new reporting requirements.

Implementation challenges

Some Indian tyre producers have not been buying EPR certificates, however, either because certificates are not available, or because they see the system as flawed and are prepared to risk a fine. The practical challenges of implementing and enforcing EPR across India are acknowledged to be formidable in view of the country’s large informal recycling sector, and growing quantities of imported whole tyres. The UK exported 350,000 metric tonnes of whole scrap tyres to India in 2023, attracting criticism from the UK’s Tyre Recovery Association due to the environmental risks involved, and the underutilisation of tyre re-processing capacity in the UK.

Importers of scrap tyres

Officially, imported shipments of waste tyres are only allowed into India if they are bound for re-processing at permitted plants, not for pyrolysis. In India, pyrolysis is classified as a category orange industry (second only to category red), based on its air pollution potential from combustion and fugitive emissions.

However, the shortage of EPR certificates issued by these permitted recycling plants, and data gathered by bodies such as India’s Automomotive Tyre Manufacturers’ Association (ATMA), suggest that most imports of whole scrap tyres either end up being re-used on vehicles, risking passenger safety, or illegally fuelling batch pyrolysis plants.

Smaller tyre operators in England and Wales who store or process end-of-life waste tyres (ELTs) for recovery by baling, shredding, peeling, shaving or granulating do not need to obtain an environmental permit if they successfully apply for a T8 waste exemption from their regulator.

Who qualifies for a T8 exemption

In England and Wales, a T8 waste exemption allows an operator to handle up to 60 tonnes of truck tyres, or 40 tonnes of any other type of tyre, in any 7 day period for storage or treatment. Obtaining a T8 is free of charge and straightforward to obtain from the Environment Agency – and does not require a site inspection before it is issued. A registered waste exemption lasts for 3 years.

1,149 T8 exemptions were registered in England as of September 2022 according to a statement in the House of Commons issued by the Department of Environment, Food and Rural Affairs (Defra). Aside from recyclers, this number includes farmers who store tyres for use as silage clamps.

T8 exemption does not apply in Scotland

In Scotland, the T8 exemption was removed by the Scottish Environment Protection Agency (SEPA) in 2016 amid concerns about the unsafe storage of tyres in illegal sites. The new legislation required all waste operators who collect waste tyres and store them prior to treatment or recycling to apply for a waste management licence. Anyone found to be keeping or treating waste tyres without an appropriate licence faces a maximum penalty of £40,000 and/or six months in prison.

T8 exemption reform is delayed in England and Wales

Defra has declared its intention to follow Scotland’s lead and remove T8 exemptions across England, but this requires legislative changes whose timing is uncertain. Defra’s mandatory digital waste tracking (MDWT) service is due to launch in April 2025, replacing a range of paper-based processes and waste reporting requirements with a UK-wide digital database, although few believe the deadline will be met. If and when MDWT is introduced, waste transfer notes, waste consignment notes and T8 exemptions are all likely to be phased out over time in favour of a digital system.

Waste handling in Northern Ireland

In Northern Ireland all activities involving the treatment, keeping or disposal of waste must be authorised by the Northern Ireland Environment Agency (NIEA). Some activities involving waste materials are exempt from licensing if they meet the requirements detailed in Regulation 17 of the Waste Management Licensing Regulations (Northern Ireland) 2003.

Controversy about the T8 waste exemption

T8 exemptions were introduced to eliminate the burden of red tape from a limited number of waste activities that were considered low risk. However, permitted recyclers of waste tyres have anonymously complained to the tyre and rubber recycling trade journal that some operators are taking advantage of the exemption. This, it is argued, amounts to a ‘two tier playing field’ whereby operators with T8 exemptions are spared the time and expense of applying for an environmental permit, or complying with its requirements, which includes paying fees and investing in site infrastructure.

Scrap tyre exports to India

The Tyre Recovery Association has raised concerns that the T8 exemption is encouraging the export of baled end-of-life tyres to overseas destinations such as India that have lower environmental standards, rather than encouraging operators to process tyres in the UK, which is currently the more costly disposal option. Transforming tyres into higher value secondary raw materials such as chip, shred or granules makes them suitable for use as aggregate in civil engineering, for example. They can also be put to ‘beneficial use’ in high quality tyre-derived fuel (TDF). By contrast, less efficient and often poorly regulated batch pyrolysis plants that are common in low and middle income countries tend to use whole tyres.

Anyone involved in the movement of household, commercial or industrial waste in the UK will have to check their new reporting requirements when mandatory digital waste tracking (MDWT) comes into force in April 2025.

According to government indications, the new UK-wide digital tracking service will require operators to input more data, more often, compared to hard copy waste transfer notes, which is how most reporting of non-hazardous waste movements work currently. Until the industry completes the process of digitalisation, which could take years, the two systems may end up running in parallel, raising the burden of compliance for businesses in the sector.

Digitalisation is coming, like it or not

While details of MDWT are yet to be made public, and many cast doubt on the 2025 launch date so soon after a general election, the government has been clear that digitalisation is inevitable for the waste sector. In October 2023 the Department for Environment Food and Rural Affairs (Defra) made an official response to a MDWT consultation where it set out a clearer picture of what the new digital service would look like, and how it would compare to the paper-based system that it is meant to replace.

Existing legal requirements will stay

Defra indicated that existing legal requirements for record-keeping of waste movements within the UK will remain. The key information that goes on hard copy waste transfer notes will need to be entered onto the new database. Depending on the type of movement or transfer being undertaken, this information includes the date and time of the movement or transfer; details of the waste producer, consignor, or originator; details of the waste carrier; and details of the waste that include the description, relevant coding, chemical composition, and containment.

Hard copy documents won’t disappear

Much like waste transfer notes, hard copy Annex VII documents will still need to accompany loads of non-hazardous waste that are being exported. The same information will most likely need to be uploaded onto the digital database as well.

More data input will be needed, faster

The new database is certain to have additional data requirements. In its summary introduction to MDWT, the government indicated these would include a unique identifier for all waste movements; details of who classified the waste; waste destination details; Standard Industrial Classification (SIC) Code; details about rejected or quarantined loads; waste treatment details including the end fate of the waste; identification of Persistent Organic Pollutants (POPs) in waste; details of end of waste products or materials produced from waste, and where these go next.

Administrative burden for business

In its response to consultations, the government set out some general rules for the new service, namely that records will need to be kept on the movement of ‘all types of household, commercial and industrial waste whether it is classified as hazardous or non-hazardous waste’. In terms of administrative burden, the industry will be expected to enter data ‘in a much timelier way than it is now and at a more granular level’. Many traders and brokers will therefore face a choice between committing more staff hours to data entry and compliance, or investing in digitalisation and automation.

Household waste exception

A guiding principle of MDWT is that tracking will begin from the place where the waste is produced. One exception regards the movement of household waste when it is collected from domestic premises by third parties. In response to consultations, Defra clarified that digital waste tracking obligations will not apply to local authorities or their contractors. Tracking records for this waste will begin when it is taken into a waste receiving site.

Some old compliance tasks will go

The good news is that some old paper-based compliance processes are likely to be retired. These include quarterly permitted or licensed site returns; hazardous waste returns (England and Wales); waste summary returns (Northern Ireland); complex exemption returns that may be required by SEPA (Scotland); and local authority waste collection and treatment information. Animal by-products are not considered to be within the scope of MDWT as they are not considered ‘controlled waste’.

No more pre-shipment submission of Annex VII in Scotland and NI

In Scotland and Northern Ireland, waste tracking service requirements will probably replace pre-shipment submissions of Annex VII forms to the respective regulators, SEPA and NIEA.  Pre-notification of hazardous or special waste consignment notes is also likely to become redundant.

How to enter data into the digital tracking service

Manual data entry will be possible with MDWT, either by means of an app or an online form. Uploading data from spreadsheets should also be enabled for reporting purposes, along with barcodes or QR codes. In time, exchanging live data by means of modern API technology is likely to further improve efficiency and transparency in line with the objectives of MDWT. For many traders of secondary raw materials, this further step towards digitalisation of the waste sector will be the spur to adopting modern commodity trading and risk management software.

When non-hazardous waste changes hands, a legal document called a waste transfer note (WTN) is needed to record the waste type, the waste quantity, and the parties involved in its transfer. Also known as duty of care certificates, WTNs are meant to track the movement of waste along the so-called chain of custody to provide accountability, and encourage responsible waste management.

Moving hazardous waste, as opposed to non-hazardous waste, has its own rules which include the compilation of a hazardous waste consignment note.

What goes on a waste transfer note?

Anyone transferring waste needs to include on the WTN a description of the waste and any processes it has been through; how the waste is contained or packaged; and the quantity of waste. They also need to record the place and date of transfer, the name and address of both parties, as well as details of the permit, licence or exemption of the person receiving the waste.

If the party handing over the waste has a waste management licence or is a registered carrier of controlled waste, they should put down their licence or registration number. A WTN also requires the relevant European Waste Catalogue (EWC) code for the waste, the Standard Industry Code (SIC) of the waste holder, and the name of their unitary authority or council.

Additional requirement for Northern Ireland

In Northern Ireland, a statement must accompany the WTN indicating that the waste hierarchy has been applied in line with regulation 17 of the Waste Regulations (Northern Ireland) 2011.

Risks of non-compliance

As a general rule, WTNs need to contain enough information for the waste to be handled safely, and either recovered or disposed of legally in line with the Environmental Protection Act 1990 (EPA). This act sets out the duty of care obligations for anyone handling certain kinds of waste, which requires them to take all reasonable steps to keep it safe. Prosecution is a risk if waste is mismanaged as a result of missing information on a waste transfer note. WTNs should be stored for two years to ensure compliance, allowing for for audits, inspections, and resolution of disputes.

When will waste transfer notes be phased out?

The existing paper-based system of waste transfer notes is due to be accompanied by Mandatory Digital Waste Tracking (MDWT) in April 2025. From that point, waste producers, intermediaries, brokers, carriers, and facilities that receive the waste will need to feed their data into a unified, UK-wide digital database, although there are a number of exceptions and details are still lacking. While some of the current reporting requirements will almost certainly be retired, hard copy WTNs are unlikely to disappear any time soon.

Until the new rules relating to MDWT come into force, existing regulations apply and the UK government website provides a WTN template which can be downloaded as a pdf.

Administrative burden is set to rise

The additional reporting requirements and heightened levels of regulatory scrutiny that MDWT will introduce are sure to put more pressure on back-office staff in the sector. As a result, many waste traders will have little alternative but to adopt modern recycling software or scrap trading software as a means of automating their reporting and compliance processes.

UK businesses that export packaging waste need to register with the national packaging waste database (NPWD) to gain accreditation. This enables them to generate the packaging waste export recovery notes (PERNs) that waste producers can then buy to fulfil their recycling obligations.

Qualifying as a reprocessor or exporter

To become an accredited reprocessor or exporter, businesses must have a UK presence with a UK address for receiving business communications. They need to be actively receiving, treating and recycling UK sourced packaging waste, or exporting it to be recycled overseas. When packaging waste is recycled into a new product or material, it should require no further processing, meeting end of waste status.

How to register as an exporter or reprocessor

The first step to register as a UK reprocessor or exporter of packaging waste is to obtain a unique NPWD username and password from the relevant environmental regulator. England’s regulator is the Environment Agency, Scotland’s is SEPA, Northern Ireland’s is the NIEA, and that of Wales is NRW. The second step is to apply for accreditation on the NPWD site using the password and username provided by the regulator.

Reprocessors must submit an application for each of their sites, which are accredited separately, although an accreditation can cover multiple materials. Exporters can make a single application regardless of the number of their overseas reprocessing sites. These overseas sites can be added and paid for after accreditation has been issued. Accreditation in itself does not authorise the business to export waste. For this, the business must follow international waste shipment requirements.

Packaging waste producers

UK producers of packaging waste with a turnover of over £2m who handled 50 tonnes of packaging materials or packaging in the previous calendar year also need to register on the NPWD website, to pay for some of the costs of recovering and recycling their waste. Alternatively, packaging producer compliance schemes (PCSs) can register on behalf of their members.

How to register as an obligated packaging producer

A business or organisation that produces or uses packaging, or sells packaged goods, is likely to be classified as an obligated packaging producer. They must register by 7 April every year, meet their recycling obligations, and obtain evidence of compliance. They should also submit a certificate of compliance (CoC) by 31 January the following year.

Obligated producers need to submit packaging data (such as packaging activities and tonnage) on the NPWD site along with their business details and contact information. The NPWD automatically calculates the producer’s obligation based on the submitted data, which the producer then needs to review. If the producer’s main activity is selling packaged goods, they need to upload supporting information about how customers are notified about recycling matters, such as return and collection systems. Lastly, there is a packaging producer charge which needs to be paid offline.

Templates of form 6 for download and form 9 for download enable exporters of waste to compile information that Indian Customs must check before allowing certain waste shipments into the country. An article on form 6 and form 9 transboundary movement documents provides more information on how to conform with India’s hazardous waste management rules. In total there are 12 hazardous waste forms that importers, exporters and recyclers can use to obtain authorisations and file reports with the relevant State Pollution Control Board.

Because waste paper is classified as hazardous waste by India, shipments of this secondary raw material also need a pre-shipment inspection certificate, a certificate of chemical analysis report, a certificate of origin and an Annex VII document.

Chemical Analysis Report (CAR)

A certificate of chemical analysis report (CAR) certificate is needed by Indian Customs to certify that the waste material has been tested by a recognised inspection authority who has found it to fit internationally acceptable parameters for safety, quality and contamination. The CAR captures details of the exporter, importer and waste originator. The container numbers, quantity of bales, weight in metric tonnes, and HS codes of the waste paper are also needed, along with a declaration that the information on the certificate is true and correct.

Pre-Shipment Inspection Certificate (PSIC)

Another document that contains almost identical information to the CAR is the pre-shipment inspection certificate (PSIC). The PSIC certifies to Indian Customs that the shipment’s safety, quality and contamination levels have been found to meet required standards by the recognised inspection authority, this time by means of inspection rather than chemical analysis.

Certificate of Origin (COO)

A certificate of origin (COO) is also required to obtain Indian Customs clearance for shipments of certain secondary raw materials. The COO serves to confirm the commodity’s country of origin, or ‘nationality’. The country of origin is determined by what parts or ingredients are in the commodity, and where they came from. Depending on the goods being shipped, and any trade agreements that may apply, rules of origin can be complex. In the UK, a local Chamber of Commerce can issue or certify a certificate of origin if that is required by the destination country or customer.

Annex VII

The Annex VII document is a UK and EU requirement for exports of what it classifies as non-hazardous green list waste. Exporters need to compile this hard copy document and ensure that it accompanies the shipment overseas. When the waste arrives at its destination, the importer and the recovery facility (if they are different) sign and complete relevant sections in the Annex VII form, which needs to be kept for 3 years as a record. Exporters must also create a written contract with the importer in which the exporter undertakes to take back the waste or recover it somehow if the shipment cannot be completed as planned, or is found to be against the law. Lastly, the exporter needs to confirm that the waste will be treated in an environmentally sound way at its destination. 

Exporters of green list non-hazardous waste need to complete an Annex VII form which is available as an Annex VII pdf download.

The Annex VII is a hard copy paper document that accompanies the waste shipment all the way to its overseas destination, at which point the importer and the recovery facility (if they are different) need to sign and complete the relevant sections. Copies of the Annex VII then need to be retained by the exporter for three years.

What information goes on an Annex 7?

The Annex VII needs to record who has arranged the waste shipment, who is transporting it, and where it is being taken. It also describes what the waste is, along with the relevant identification codes, which can be found in the consolidated waste list. These codes indicate the rules that govern the transportation of each type of waste. Differing rules between the exporting country, the destination country and transit countries can require extra paperwork and various other forms of compliance.

For example, waste paper is considered non-hazardous in the UK, whereas Indian Customs consider it to be hazardous waste, requiring a pre-shipment inspection certificate, form 6 and form 9 transboundary movement documents, a certificate of chemical analysis report, and a certificate of origin. Italy on the other hand doesn’t classify waste paper as waste at all.

Pre-shipment submissions for Scotland and Northern Ireland

For exporters in Scotland, information contained in Annex VII forms has to be submitted to the Scottish Environment Protection Agency (SEPA) before the shipment sets off. A similar pre-shipment submission requirement exists in Northern Ireland, whose regulator is the NIEA. This requirement does not apply in England and Wales.

Green list rules require a written contract

In addition to completing and signing the Annex VII, exporters of green list waste need to ensure that the waste is properly sorted in a way that conforms with Article 18 controls, and will be accepted by the destination country, which might have different rules. Exporters must create a written contract with the importer in which the exporter undertakes to take the waste back or recover it in some other way if the shipment cannot be completed as planned, or is found to be illegal. The exporter also needs to confirm that the waste will be treated in an environmentally sound way at its destination.

The official document that verifies the accuracy of a weighing scale for vehicles and their loads is called a weighbridge calibration certificate (WCC). It certifies that the weighbridge meets acceptable industry standards for accuracy, and records the latest calibration test results to prove it. 

What goes on a calibration certificate?

Aside from calibration test results, a valid WCC details the equipment used to test the weighbridge, the individual who performed the tests, where and when it happened, and which methodologies and procedures were followed. The WCC includes details such as the serial number and type of weighing device, its capacity, accuracy class, and the scale interval with which it was tested. A qualified technician authenticates the certificate with a signature. In a lab setting, it can be validated by an organisation accredited by the United Kingdom Certification Service (UKAS).

Why is a calibration certification needed?

A calibration certificate is not a legal requirement for weighbridges. However, when used for trade purposes, a weighbridge is required to have a unique, valid WCC ready for inspection. A ‘trade approved’ weighbridge, as it is known, indicates that the weighbridge can be operated for trade purposes in accordance with the Weights and Measures Act 1985. In the UK, trading standards officers monitor loading sites to check that trade approved equipment is within specification and correctly marked. Whether trade approved or not, most weighbridges need to be recalibrated on an annual basis to guarantee accuracy, and identify potential issues such as hysteresis.

Operator certification

Whoever operates a weighbridge that people pay to use needs to hold a certificate of competence and adhere to its conditions. The conditions of competence include weighing on demand and fairly; providing statements of weight, usually in the form of a weighbridge ticket; and retaining two years worth of weighing information as a record, including dates, times, names, addresses, vehicle identifications (usually the number plate), and load types. Failure to comply can incur a fine of up to £5,000 and 6 months imprisonment.

3 types of calibration certificate

Weighbridge calibration certificates fall into three categories. ‘In-service’ certificates are used to verify that an existing scale complies with industry standards. ‘As new’ certificates are issued when a newly purchased or manufactured weighing device is tested and found to be accurate within its specified accuracy class. ‘Calibration confirmed’ certificates usually apply to a previously calibrated scale whose accuracy levels have been returned to acceptable levels following repairs or maintenance work.

How do I get a weighbridge calibration certificate?

In the UK, local councils can provide a verification, testing and calibration service in exchange for a fee. Tests are carried out by an Inspector of Weights and Measures from the local trading standards office. When buying a weighbridge, or at the point of initial verification, a declaration of conformity can also be issued by either a trading standards officer (TSO), an approved verification officer (AVO), or the manufacturer.

Any business that is expanding its digital footprint needs corporate password management to keep its data safe. Without a password manager, interacting with multiple accounts and platforms such as CRM, e-commerce and cloud storage rapidly becomes cumbersome and vulnerable to hacking, especially as staff numbers grow.

What is a password manager?

A business password manager enables passwords to be tracked, stored, shared, protected and managed by permitted users in a way that is simple but secure. Passwords are stored in a cloud-based digital vault that can only be accessed via a master password, which keeps passwords inaccessible to unauthorised users even when a device is compromised. Documents, identity cards and secure socket shell (SSH) keys can also be kept safe in the vault. A password manager enables users to generate strong, unique passwords for their individual accounts – and reset them without needing to call up support.

Password policy enforcement

Sensible security policies such as minimum password length (which reduces the risk of brute-force attacks) and the use of multi-factor authentication (MFA) are far better enforced with a corporate password manager, and easy to customise around the requirements of different sites. Secure management of passwords tends to become the weakest link once MFA has been implemented.

Role-Based Access Control (RBAC)

A growing awareness of internal threats has made the traditional perimeter-guarding approach to security obsolete. These days system access is limited in line with an individual’s job, ensuring that system exposure can be controlled if a user is compromised. Role-based access control (RBAC), as it is called, is easily implemented with a corporate password manager, enabling anomalous user activity to be monitored and checked.

Ease of secure access

A password manager offers the user on-demand access to all their passwords, ensuring they never get locked out of crucial accounts. Single sign-on (SSO) allows users to log in to multiple accounts using a single set of credentials. For businesses with multiple team members, password managers allow secure password sharing (without revealing the actual password), ensuring that everyone has access to the accounts they need without compromising security. Management of access and permissions becomes easier too across larger teams.

Audits and updates

No system is immune from threats which are constantly evolving. It makes sense therefore to conduct regular audits and reviews so that old accounts are deleted, new ones are added, and passwords are regularly reset. A password manager can be programmed to send out regular reminders and ensure that new passwords are sufficiently robust. Staff also need to be trained to use the password manager effectively and follow best practice.

The Environmental Protection Agency (EPA) is the Republic of Ireland’s environmental regulator. It is tasked with protecting and improving the environment for the people of Ireland. This involves implementing and enforcing environmental legislation, and advocating to meet Ireland’s environmental commitments. Its work includes authorising and monitoring industrial activities that might impact the environment or human health.

Industrial and waste activities

The EPA’s Office of Environmental Enforcement (OEE) ensures that large industrial and waste activities are carried out in accordance with operators’ licences. To this end, it promotes and monitors compliance, provides guidance and support, carries out inspections and sampling, and takes enforcement actions when needed. The agency also tracks emissions and reviews complaints about off-site impacts from neighbours and the local community. 

The EDEN portal is the EPA’s online gateway for licensing, monitoring, reporting and digital map data.  

EPA powers

Operators can be instructed by the EPA to take action when they are found to be non-compliant with their licence obligations. If the problem is complex or not addressed in a timely manner to the EPA’s satisfaction, this can escalate to a compliance investigation. Operators can then be directed to take specific corrective and preventative actions, and provide supporting evidence that the required work has been completed.

Some licensed sites find themselves placed on a list of National Priority Sites (NPS). This list is used to target enforcement on the poorest performing sites and drive improvements. Serious failings can lead to legal enforcement measures. These include prosecution of the licensee, the issue of a statutory notice, and ultimately the suspension or revocation of a licence. 

NPS scores

The EPA has a scoring system that measures the environmental performance of individual licensed sites. The NPS Score, as it is called, combines various metrics arising from compliance investigations, incidents, non-compliance, and complaints. A similar performance score approach is taken to water monitoring by the EPA.

EPA and water

The EPA has wide-ranging responsibilities for protecting the environment and human health. It publishes a remedial action list of sites where Uisce Éireann (formerly Irish Water), the state-owned water utility company, needs to take corrective action to ensure the safety and security of drinking water supplies. The EPA’s annual reports on urban waste water treatment identify key areas where improvements are needed to prevent water pollution, eliminate discharges of raw sewage, meet EU treatment standards, and protect bathing waters and freshwater pearl mussels. 

EPA organisation

The EPA operates independently under the Department of the Environment, Climate and Communications. It is led by an advisory committee headed by a director general, and is divided into five offices. Aside from the EPA’s core functions of compliance, enforcement, data analysis and advocacy, there is also an office of radiation protection and environmental monitoring to protect the public from the effects of harmful ionizing radiation.