What should be included in a construction waste management plan in the UK?

The Site Waste Management Plans Regulations of 2008 were repealed in 2013, as part of the Government’s efforts to reduce the amount of red tape surrounding construction projects.

Put simply: this change meant that clients and principal contractors didn’t need to produce a plan, prior to starting a project.

Great news. Without needing a plan, you can skip ahead and just get on with your build — it’s a no brainer, right? Well, not quite.

While it’s no longer a legal obligation, engaging with a waste management expert to create a plan will still save you time, effort, money and legal worries. And those working in the industry know that identifying potential problems, before they occur, plays a huge role in the success or failure of a project.

So, now you know why a construction waste management plan still carries worth, what do you need to know about writing one?

Plan early and avoid risks

The current UK planning framework requires developers to produce Human and Environmental Risk Assessments. But, these reports often don’t consider the waste that will be generated from construction — or how to best deal with it.

Even when this has been considered, construction waste (and its implications) is often considered far too late in the process. Ideally, these decisions should be made well in advance of groundwork sub-contractors being appointed, and the plan should form part of the tender process.

This kind of forward-thinking avoids two common issues:

1. Not recognising waste soils as a resource

To properly consider waste as a resource, rather than a liability, the project needs to be designed with waste in mind.

Many are unaware of the fact that the excavation and reuse of soils, even contaminated ones, could be permitted as long as the appropriate risks assessments and compliance measures have been carried out. It’s important to note that this process can take a long time to arrange — planning ahead, therefore, avoids unexpected delays and unforeseen expenses, and a waste management expert can help you every step of the way.

2. Not understanding waste classification

It’s not uncommon for soils to be dealt with incorrectly. This is because the chemical data sourced from the initial site investigations is usually insufficient. With insufficient data, classifying the waste soils accurately is impossible, due to the nature and frequency of the testing.

Accurate waste classification is a legal requirement. Despite this, poor planning and ill-informed decisions by the waste producers and their supply chain (often stressed by their own time pressures) results in this legal requirement being overlooked.

For commercial reasons, waste producers will often “make-do” with insufficient information and use this to make assumptions (with little evidence) about waste classification and segregation of contaminated hot-spots. All in all, this increases the risk of misclassification, harm to the environment and regulatory prosecution — something that’s easily avoided, with a thorough plan.

Consider the environmental impact (and the responsibility you have)

While a construction waste management plan is no longer a legislative must-have, complying with Duty of Care responsibilities and Waste Hierarchy guidance is still essential.

The Waste Hierarchy defines the order in which producers should consider dealing with their waste. Prevention and re-use of waste are at the top of the list, with disposal being the final, least preferred option.

Duty of Care legislation forms part of the Environmental Protection Act of 1990 and, amongst other requirements, it specifies the producer must:

• Prevent unauthorised or harmful deposit, treatment or disposal of waste
• and provide an accurate description of the waste when it’s transferred to another person.

Failure to adhere to these rules can result in fines, conviction and — at worst — imprisonment.

What’s more, poor project management of the waste (generated by construction activity) means:

• The site team won’t be able to prevent or re-use soils (directly affecting the Duty of Care legislation mentioned above).
• There’ll be less time to accurately test, classify and segregate different waste classifications.
• There’ll be negative compliance and commercial implications.

Don’t go it alone — seek expert advice

Partnering with a waste management expert, as early as possible, is critical to not only a project’s legal obligations but to its success.

Even though a lot of environmental consultancies won’t include waste management as part of their project tender (usually to keep costs down), we know that addressing it early on can help prevent future problems occurring.

Avoiding it can have detrimental commercial implications for the project, as the prevention, re-use and correct removal of waste should save money, not incur expenses.

We know it can be tricky managing a busy project, especially with so many different things to juggle. But, remember, you don’t have to do it alone. We’re here to help with all your waste management questions should you have any.

About the author

Alex Collman

Waste management expert | Identifying cost savings on construction waste soil management and removal