National Threat Assessment 2008. Organised Crime - Politie

a role, namely the fact that supervision and enforcement in relation to soil
remediation crime is insufficient. Inspections are rarely performed, the level
of professionalism of the inspections leaves a great deal to be desired,
communication with fellow supervisors or enforcers is limited and after a
remediation operation there is rarely a test to determine whether the findings
of the evaluation report are correct. The police’s environmental task is made
more difficult by the specific (environmental) knowledge required and the
complex environmental legislation. Another complicating factor is the extended
enforcement network in which the police are merely one of the links in the
chain. As a result, carrying out the environmental task requires more
collaboration with and information from other (enforcement) agencies than
other police tasks.
Due to the competition between companies, there is also a risk of other players
adjusting their standards when they see that offenders run only a low risk of
getting caught and if they are caught, they are given relatively mild penalties.
There are many opportunities for illegal trading in the soil remediation industry,
in all phases of the remediation process and for all the players involved. Cases
in which these opportunities are used mostly involve fraud and forgery of
documents. For example, maybe no or only selective testing (in the least
contaminated areas) is carried out on site; maybe survey reports trivialise the
pollution or use old test results; maybe a remediation operation is only
performed on paper; and maybe soil is mixed without permission. Players who
carry out the remediation often have specific opportunities at their disposal.
For example, a contractor on site A may have to remove contaminated soil,
whilst soil has to be deposited on site B. The number of opportunities increases
the more a player is active in various links in the chain or maintains contacts
with people who are active in other links in the chain.
114 National Threat Assessment 2008 – Organised crime