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AP 27 - Environment

Introduction

Construction has the potential to significantly damage the environment in a number of ways including ill-conceived development; environmentally inefficient or damaging designs; irresponsible procurement; high energy usage which contributes to high levels of carbon dioxide (greenhouse) emissions.

The Company recognises that the enhancement of the environment lies at the core of its activities and meets the needs of the clients in environmentally sensitive ways. This necessarily includes the minimisation of adverse environmental impacts arising from our activities.  Our environmental commitment is of importance if the company is to remain respected and ultimately profitable.  Substantial progress in environmental management has already been made and is recognised across the whole of the Company.

Wastewater treatment

For any item of plant, and concrete delivery lorries where a ‘No washout’ policy cannot be achieved, the concrete wash off water must be prevented from entering the ground or finding its way into nearby watercourses. Concrete lorries must wash into their drums and wash off their discharge chutes into a leak proof container which will store and contain the alkaline water. At set intervals and before the container is full, the wastewater PH level needs to be measured using a PH test kit. If the PH level of the water remains above PH7, then a PH neutraliser needs to be added to the wastewater and the PH level re-tested. Following the manufacturers guidance on dosing amounts. Once the above is completed and the PH level is 7, the wastewater can either be discharged or pumped to sewer (subject to discharge consent) or released to ground providing the water does not run beyond the site boundary. Any remaining cured concrete/aggregate solids can be broken up and removed from site or recycled.

Concrete column skips

To clean off a concrete column skip the skip is to be located on the column skip stand and a drip catch tray positioned underneath. The skip is washed off and the remaining water in the drip tray is to be tested and treated following the PH neutraliser procedure detailed above.

Concrete pump

To clean Coinford static concrete pumps, detailed procedure can be found in the Placement of Concrete method statement, this process must be strictly followed.

Policy

The Company aims to conduct its business in a manner, which as far as practicable will minimise adverse effects on the environment.  The Company will maintain an awareness of all legislation, regulations and codes of practice on environmental matters and take all reasonable actions to ensure compliance.

While construction is in progress, the Company will take reasonable precautions against environmental damage, disruption or nuisance on or adjoining its sites. Furthermore, we will at all times endeavour to keep their sites clean and tidy, and to avoid pollution of the air, ground or water by noise, fumes, dust, discharges or the disposal of construction materials.

The Company will, wherever viable and consistent with its clients’ needs and expectations, use materials and products from sustainable sources and that are re-usable or can be re-cycled.  Management initiatives play a major role in environmental progress and change.  The Construction Directors are empowered to make decisions for effective environmental management.

1. Responsibilities

The Operations Director is responsible for ensuring implementation of this procedure.  The Project Management Team is responsible for monitoring compliance with this procedure.

Good Neighbours

The Company strives to keep neighbours fully informed of the local site works.  This is achieved by a range of measures including written correspondence, meetings and house to house visits.  The Company minimises nuisance such as dust, deposits, odours, noise and vibration resulting from site activities by complying with all local and national regulatory requirements. Project Management Teams are directed to join the Considerate Contractors Scheme wherever possible.

The Company encourages communication with all interested parties including the clients, the general public, regulatory authorities and environmental groups.  The Company engages in active liaison with local schools, local and County Councils, local businesses, tenants and residents groups both directly and through the local media.  Detailed guidance on local liaison and consultation is provided to all Project Management Teams.

2. Environmental Noise

The effects of construction site noise can affect the local environment by causing a nuisance to those who live or work in the vicinity.  Complaints to the local Environmental Health Office (EHO) are always investigated and may result in legal action or enforcement notice being issued on a particular site.  This can be disruptive to the construction site and costly to the company.  The following guidelines should always be applied:

  • As early as possible prior to commencement of site work, the potential problems of environmental noise should be addressed;

  • Early contact with local residents and the EHO is useful to discuss the intentions with a view to making a Control of Pollution Act (COPA) Section 61 prior consent application and give contact numbers in the event of any complaints to try to avoid enforcement action.  If the local authority runs a considerate contractor scheme an application should be made to join;

  • Where a (COPA) Section 61 prior consent application is made the requirements should be communicated to all contractors;

  • Best practicable means of reducing noise should be used;

  • In the event of a (COPA) Section 60 notice being served, usually restricting hours of noisy working, actual noise levels or both, under no circumstances must the requirements of the notice be contravened.  The Construction Director and Health and Safety Department must be notified immediately and all contractors on site must be formally notified of the contents of the notice.

Preventing Pollution of Watercourses

It is an offence to allow a polluting substance (either deliberately or accidentally) to enter controlled water e.g. all watercourses, and there are several types of water pollutant, the main ones being;

  • Substances that deoxygenate the water;

  • Substances which block out light or impede flow e. g. silt or clay;

  • Toxic substances;

  • Substances that pollute by over enrichment e. g. fertilisers;

  • Substances which cause disease;

  • Heat which deoxygenates and changes the biology of a body of water;

  • Substances which detract from the visual amenity e. g. litter

The activities on site with the potential to pollute are:

  • Fuel storage: all stores of fuel must be kept in a secure/ventilated location to prevent vandalism, fuel storage must have a bund wall to prevent any escape of fuel leaking to the ground or a watercourse and it must be clearly labelled;

  • Concrete: placing of concrete especially near to watercourses and drains needs to be controlled, a designated wash out area is required on site;

  • Waste water: discharge of any effluent (other than domestic sewage) to a foul sewer requires the permission of the local sewage undertaker;

  • Vehicles must not be allowed to wash down on the road because it will cause silting up of the surface water drainage.

  • Dewatering excavations.

Most pollution incidents are avoidable.  Careful planning can reduce the risk of pollution.  Most of the measures needed to prevent pollution cost very little, especially if they are included at the planning stage of any scheme or project. In contrast, the costs of cleaning up a pollution incident can be very high.  There are also serious consequences of a prosecution for environmental offences.  Any work carried out in or near watercourses, must be regarded as high risk with significant potential to cause pollution.  Potential pollutants of concern include silt, cement, concrete, fuel, lubricating and shutter release oils, petrol, sewage, and other waste materials.

General Precautions

In planning and carrying out any work in or near rivers, streams, ditches and other watercourses, precautions must be taken to ensure their complete protection against pollution, silting and erosion.

Any work on or near foul sewers, (especially trunk sewers), underground oil/chemical pipelines or fluid filled electricity cables poses a major threat of pollution if damage occurs.  At least 7 day prior notification of an intention to work on these structures should be given to the Agency, enabling appropriate pollution prevention measures and emergency procedures to be agreed.

The use of industrial by-products at locations where drainage from the material could directly or indirectly enter surface or groundwater must be discussed with the Agency.  Such materials must be suitable for the purpose, well weathered and must not pose a leakage problem.

Silt

Silt causes lasting damage to river life such as fish, insects and plants and can also build up to cause flooding.  Water containing silt should never be pumped or allowed to flow directly into a river, stream or surface water drain.  Silty water can arise from dewatering excavation, exposed ground, stockpiles, plant and wheel washing, site roads and disturbance of the riverbed.  When possible, silty water should be disposed of to the foul sewer with the prior agreement of the sewerage undertaker.  Discharges to streams, watercourses or soakaways must have Agency approval, which should be obtained well in advance.  Suitable treatment will be required, such as the use of a lagoon, tank or grassed area to settle solids.  For fine silts, flocculants may be required to aid settlement, although these should be used with care because of their potential for pollution.

Pumping

Care should be taken with the discharge to watercourses of any pumped clean water from dewatering or over-pumping operations.  If it is carried out with a powerful pump and/or at a high rate, then the riverbed and bank could be disturbed and eroded, producing silty river water.  Therefore pumped discharges must be made using a pump of a suitable size for the situation and at a rate which will not cause riverbed disturbance.

Excavations

Where possible prevent water from entering excavations.  Use cut off ditches to prevent entry of surface water and well-point dewatering or cut-off walls for groundwater.  Use the corner of the excavation as a pump sump and avoid disturbing that corner. Do not allow personnel or plant to disturb water in the excavation.  For work in river channels, the use of coffer dams is recommended to keep river water out of the working area.

Exposed Ground and Stockpiles

Minimise the amount of exposed ground and soil stockpiles.  Seeding or covering stockpiles and constructing silt fences from suitable geo-textile may be useful in reducing silt levels in run-off water.

Site Roads and River Crossings

Site roads and approaches to river crossing must be regularly brushed and scraped and kept free from dust and mud deposits.  The inclusion of small dams in roadside ditches may assist silt retention, especially on steep slopes.  If a river is to be frequently crossed, a permanent bridge or pipe crossing should be constructed.  This would make fording of the river and the consequent disturbance of the bed, unnecessary.

Bank Restoration

Where possible, bank restoration should be carried out by vehicles operating from the bank rather than the river.

Concrete and Cement

Concrete and cement are very alkaline and corrosive and can have a highly polluting impact on watercourses.  It is essential to ensure that the use of wet concrete and cement in or close to any watercourse is carefully controlled so as to minimise the risk of any material entering the water, particularly from shuttered structures or the washing of equipment.  The use of quick setting mixes may be appropriate.

For long term projects involving on-site concrete production, careful initial sitting of concrete mixing facilities is vital.  A settlement and re-circulation system for water re-use should be considered.  This will minimise the risk of pollution and reduce water usage.  Washing-out and cleaning of concrete batching plant or ready-mix lorries should be carried out in a contained area as far from the watercourses as practical.

Wastewater treatment

For any item of plant, and concrete delivery lorries where a ‘No washout’ policy cannot be achieved, the concrete wash off water must be prevented from entering the ground or finding its way into nearby watercourses. Concrete lorries must wash into their drums and wash off their discharge chutes into a leak proof container which will store and contain the alkaline water. At set intervals and before the container is full, the wastewater PH level needs to be measured using a PH test kit. If the PH level of the water remains above PH7, then a PH neutraliser needs to be added to the wastewater and the PH level re-tested. Following the manufacturers guidance on dosing amounts. Once the above is completed and the PH level is 7, the wastewater can either be discharged or pumped to sewer (subject to discharge consent) or released to ground providing the water does not run beyond the site boundary. Any remaining cured concrete/aggregate solids can be broken up and removed from site or recycled.

Concrete column skips

To clean off a concrete column skip the skip is to be located on the column skip stand and a drip catch tray positioned underneath. The skip is washed off and the remaining water in the drip tray is to be tested and treated following the PH neutraliser procedure detailed above.

Concrete pump

To clean Coinford static concrete pumps, detailed procedure can be found in the Placement of Concrete method statement, this process must be strictly followed.

Oils and Chemicals

  • Storage - Fuel, oil and chemical storage must be sited on an impervious base within a bund and secured.  The base and bund walls must be impermeable to the material stored and of adequate capacity.  Leaking or empty drums must be removed from the site immediately and disposed of via a registered waste disposal contractor.

  • Security - All valves and trigger guns should be protected from vandalism and unauthorised interference and should be turned off and securely locked when not in use.  Any tanks or drums should be stored in a secure container or compound, which should be kept locked when not in use.  Bowsers should be stored within site security compounds.

  • Refuelling - The risk of spilling fuel is at its greatest during refuelling of plant.  Where possible, refuel mobile plant in a designated area, preferably on an impermeable surface well away from any drains or watercourses.  Keep a spill kit available and use a bunded bowser. Never leave a vehicle unattended during refuelling or jam open a delivery valve.  Check hoses and valves regularly for signs of wear, and ensure that they are turned off and securely locked when not in use.  Diesel pumps and similar equipment should be placed on drip-trays to collect minor spillage or leaks.  These should be checked regularly and any accumulated oil removed for appropriate disposal.

  • Bio-degradable Oils - When working in or near rivers, the use of biodegradable chainsaw chain bar lubricant and biodegradable hydraulic oil in plant is recommended.  The Environment Agency has adopted a policy to do so for its own operations along those working on its Sites.

  • Herbicide Use - The use of herbicides in or near rivers requires the written approval of the Agency.  If approval is given, the user is responsible for ensuring that the interests of other river users are not adversely affected.

  • Emergencies - If it is unavoidable that oil and chemicals have to be used within close proximity of a stream, river or any other watercourse, then it is recommended that a suitable spill kit or absorbent materials are held in the vicinity and that an appropriate temporary bund is put in place.  In the event of any spillage, the spilt material should be contained using absorbents such as sand, soil or commercially available booms or pads.

The law requires that when pollution of controlled water occurs it is notified immediately to the Environment Agency the Construction Director must be consulted prior to this notification.

Mobile Crushing and Screening Equipment

Demolition contractors often use this type of equipment on site.  This equipment is to be used only if the Project Management Team has copies of the local authority authorisation to use the equipment, notice given to the local authority of the location where it is to be used and any special operating conditions given in the authorisation.

The Project Management Team must check that the contractor is working in accordance with the conditions of the authorisation.

Wildlife

Wild Animals

The Wildlife and Countryside Act is the principle mechanism for the legislative protection of wildlife (including aquatic mammals and insects) in Great Britain. There are 105 species such as bats, dormice, greater crested newts, red squirrels otters etc that are protected from:

  • Disturbance including nest/burrow/roost etc;

  • Injury;

  • Intentional destruction including destruction of any structure or place which the animal uses for shelter;

  • Intentional obstruction to the access to any structure or place which the animal uses for shelter; and

  • Sale.

The Act is regularly amended to ensure that protection is afforded to the most vulnerable species of animals and plants.  Permission can be obtained to remove or relocate in some circumstances and licences are obtained through the appropriate wildlife authority.

Wild Birds

Most birds, their nests and eggs are protected by law and it is an offence with certain exceptions to intentionally kill, injure or take any wild bird, destroy etc their nests or eggs have in ones possession any wild bird dead or alive or part of, or egg or part of which is in contravention of the Protection of Birds Act (POBA) or intentionally or recklessly disturb any wild bird listed in Schedule 1 of the POBA.

It may be possible to obtain a licence to remove pest species (as detailed on the RSPB website)

Wild Plants

All wild plants (including Aquatic plants) are protected by the law and it is therefore an offence with certain exceptions to intentionally pick wild flowers, uproot a wild plant(s) or destroy a wild plant.  A person shall not be found guilty if the offence was committed with the knowledge and permission of the landowner or local authority.

Additionally the Act deals with the unlawful spreading of certain non-native species such as Giant Hogweed and Japanese Knotweed.

Protection of Trees

Trees including shrubs and hedges may be protected by legislation. Even where no specific legislation exists it may be necessary to obtain a felling licence if the volume of timber exceeds a specified amount. Site clearance, even for a small site may require a felling licence which is obtainable from the Forestry Commission.

The use of the following measures will help to ensure that trees are not killed and that their lives are not shortened;

  • Fence the area in which the trees roots lie;

  • Do not raise or lower ground levels in the area where tree roots lie;

  • Store tools and chemicals outside the tree root area;

  • Do not fix cables, signs etc to any part of a tree;

  • Keep trenches outside root area;

  • Keep plant and machinery outside root area and away from overhanging branches;

  • Do not light fires near any part of a tree;

  • Do not use weed killer near any part of a tree. ​​​​​​​

Waste Management

Waste Management practices are designed to reduce costs through effective management of company resources, thereby reducing unnecessary by-products.  The way in which we manage our waste also has a critical part to play in moving towards sustainable development, in terms of both reducing our demands on scarce resources, and of minimising the environmental impact of its treatment or disposal.

​​​​​​​It is the understanding gained through detailed assessment throughout the life of a Project/Site that enables reduction, recovery and recycling of waste.  Put simply, managing waste effectively reduces the amount of profit thrown away.

Objectives

Enable The Company to meet Environment Agency and EU targets for waste minimisation;

  • Reducing construction costs;

  • Reducing demand for primary materials;

  • Reducing construction waste;

  • Reducing Project / site duration;

  • Positive encouragement of a sustainable development;

  • Reduce the environmental impact of new Projects / sites;

  • Increase the re-use of waste and recycled materials.

Definitions

The following definitions are provided in the Environmental Protection Act:

  • Waste:  'Any substance or object discarded or intended / required to be discarded; Items with no further use';

  • Controlled Waste:  'All waste produced from industrial, construction, commercial and domestic premises', therefore all waste produced on The Company sites and offices is Controlled Waste

  • Special Waste:  Is ‘Controlled Waste’ with hazardous properties which cause the greatest environmental damage or danger to life‘.  A simple way to identify these materials is by hazard symbols or those with safety data sheets.  Typical Special Wastes are:

    • Asbestos;

    • Acids and Alkalis;

    • Diesel;

    • Industrial solvents;

    • Oils and Oily sludge’s;

    • Pesticides;

    • Fly ash;

    • Wood preservatives;

    • Paints & Varnishes;

    • Batteries
      ​​​​​​​

The Hazardous Waste Regulations 2009 have reclassified some 200 Controlled Wastes as Special Waste including some construction and demolition wastes and contaminated soils, plasterboard (also includes fluorescent tubes, PC monitors and hard drives, batteries, scrap cars, TVs, radios, mobile phones and electronic equipment).

Special Wastes must be stored safely in secure, labelled containers.  They should never be stored in the same containers as other Controlled Wastes and should never be mixed with other Controlled or Special Wastes.​​​​​​​

Waste Hierarchy

The Company supports the approach outlined in the waste management hierarchy, which prioritises elimination of waste over minimisation, re-use, recycling, recovery, treatment and disposal.

Planning & Design

In order for a waste management scheme to be effective it is important to minimise waste arisings at all stages of a project from design through demolition, construction and future maintenance.  The following should be considered at the planning and design stage;

  • Undertake a demolition audit of relevant buildings and select demolition techniques for maximum re-use / recycling of materials;

  • Identify the key waste products likely to arise during demolition and construction phases and implement waste reduction plans for these products (key products include plasterboard, insulation, timber, concrete, packaging etc);

  • Establish a Company or site benchmark against which to measure;

  • Consider the incorporation of recycled and reclaimed materials (especially if arising on site) e.g. recycling demolition waste to help with cut & fill areas or concrete aggregate;

  • Agree on site re-use and recycling as part of the construction process;

  • Alternative construction methods e.g. pre-cut plasterboard, off site manufactured bathroom pods, cladding panels, balconies, staircases;

  • Partner with a waste management contractor to maximize recycling and reduce disposal costs.​​​​​​​

Procurement

The following shall be applied on all The Company projects;

  • Contractually oblige sub-contractors to co-operate in waste minimisation as part of their tender;

  • Ensure that all suppliers of materials provide returnable or recyclable packaging and enquire about possible take back of product off cuts or insulation products such as Rockwool;

  • Ensure materials are delivered on a ‘Just In Time’ basis and do not over order;

Waste Minimisation

Waste minimisation means reducing the amount and environmental impact of waste generated, which can be achieved by reducing the quantity of materials used (and therefore potential for wastage) or by reusing existing materials.

Methods of minimising waste on site:

  • Develop waste minimisation initiatives e.g. nominate a site manager / contractor with the responsibility for overseeing waste management and;

  • Develop a waste management plan for each Project;

  • Improve delivery e.g. JIT and do not order excess;

  • Store and handle materials safely and correctly on site, minimise material movement to avoid breakages;

  • Keep deliveries packaged/undercover/secure until ready to use;

  • Segregation of different waste streams;

  • Reduction – waste is not produced e.g. timber/plasterboard is the right size and doesn’t need to be cut;

  • Re-use – waste finds another use on site e.g. timber off-cuts used as noggins, pallets for storage;

  • Recycling – waste is processed to make something else e.g. bricks crushed for use as hardcore;

  • Conduct regular waste inspections / audits ;

Segregation & Recycling

Segregation of waste should be encouraged to identify materials which can be re-used or recycled, and to reduce cross-contamination of waste streams.  The latter often results in costly disposal which would otherwise be unnecessary.  Segregation also allows for analysis of waste produced, from which opportunities for further minimisation can be developed.  This could include:

  • Timber;

  • Hardcore (concrete, sand, rubble, masonry and bricks);

  • Uncontaminated soils & rocks;

  • Cardboard;

  • Paper;

  • Site Metals;

  • Drinks Cans; and

  • Special Waste Streams.

     

Other disposal and treatment methods, such as composting and incineration with energy recovery, have a vital role in the waste management hierarchy but generally are not suitable for The Company operations.

Waste Collection & Disposal Contractors

Waste Collection / Disposal / Management Contractors must be registered carriers or brokers under the Environmental Protection Act.  Before placing an order with a carrier of waste (this includes subcontractors such as demolition contractors) checks should be carried out to ensure that the carrier is registered (obtain a copy of the carriers annual licence or check with the Environment Agency).  Segregation of waste on site will ensure controlled waste and special waste is not mixed resulting in increased costs of disposal.

Removal of Waste from site

Controlled waste

The most common way of removal is by builder’s skip, usually hired from a contractor.  Before allowing anyone to remove ‘controlled waste’ from site the following documentation must be checked, copied and retained on site. The following requirements apply:

  • The person or company carrying the waste offsite must be registered with the local Environment Agency and be able to produce a copy of the registration certificate;

  • Confirmation that the waste is being transferred to an authorised person, landfill site or transfer station and be able to provide a copy of the waste management licence;

  • Details of the waste material have been passed onto the carrier via a Waste Transfer Note with a covering order.
    ​​​​​​​

Due to the long term and repetitive nature of controlled waste removal from a construction site, a single waste transfer note is usually filed with the waste carrier when the order is placed and is valid for 12 months.  As the producer of the waste it is still our responsibility to ensure that the waste is transferred only to the licensed landfill or transfer station detailed above.

This is evidenced by retaining on site copies of the load waste transfer notes (skip tickets) completed by the driver, signed by a representative of The Company before leaving site and countersigned by the landfill site / transfer station manager on receipt of the load.  The transfer notes must be kept on site, or archived in the Regional office, for two years.

Removal of Special Waste can only be carried out by specialist contractors whose waste carrier’s certificate clearly states that they are permitted to carry Special Wastes.

Any contractor who carries Special Waste which is to be disposed of at a licensed landfill site or incinerator must complete five copies of a consignment note which is a pre-printed form available from the local Environment Agency Office, the Environment Agency will make a charge on receipt of the Consignment Note.  The Environment Agency must be pre-notified of the transfer of waste at least 3 days prior to the transfer of the special waste.

Consignment notes must be kept on the site, or archived in the head office, for three years.  The Landfill Directive 2004 reduced the number of landfill site licensed to accept special waste from 240 to 12 in July 2004.  All special wastes leaving our site after this date has to be pre-treated prior to removal.

Minimum standards to be adopted on all Company sites

In accordance with best practice, all The Company projects where we undertake the role of Principal Contractor, will adopt a waste management system encompassing a controlled waste recycling scheme. It is hoped that these systems will be both cost effective and progressively more sustainable in environmental terms.

Setting up a Controlled Waste Management System and Recycling Scheme for all future Projects:

  • All future projects will be audited at design stage to assess the potential for waste prevention, reduction, re-use and recycling;

  • Waste management will be planned at the earliest stage of the project design (e.g. where to site mini skips, skips and roll on roll offs where applicable and at which stages of construction they will be required);

  • Waste reduction and re-use schemes will be set up and documented;

  • Waste recycling schemes will be set up and documented.  This will be achieved by waste segregation on sites;

  • As a minimum timber and hardcore (concrete, sand, rubble, masonry and bricks) will be recycled whenever possible on all sites;

  • Separate storage containers (generally skips) for the three different waste streams will be provided and clearly labelled as ‘Timber Only’, ‘Hardcore Only’ and ‘Mixed Waste’;

  • Site personnel and contractors will be informed of the requirements of the waste management system and recycling scheme at pre-tender stage, site induction stage and will receive regular briefings (tool box talks) throughout the duration of the project;

  • Waste should be segregated into the correct containers as soon as it is produced, it should not be stored in an incorrect basis on a ‘short term basis;

  • The inclusion of a Penalty Charge System to deal with any sub-contractor who is not complying with the Waste Management System and Recycling Scheme.  Sub-contractors should be informed of the charging system at pre-tender stage and site induction stage;

  • The waste management system and recycling scheme should be checked and enforced on a daily basis by Site Management;

  • Recyclable Waste will only be removed by a registered carrier, in accordance with a waste transfer note and disposed of at a licensed transfer station for sorting and recycling.  Mixed waste will only be disposed of at a licensed landfill;

  • Records will be kept on the site, or archived in the office, for a minimum period of 2 years.​​​​​​​

Additional Measures for Larger Projects

In addition to the above points the larger projects might consider the following:

  • Waste Recycling Schemes similar to that mentioned above could be also be set up and documented for the following materials:

    • Uncontaminated soils & rocks;

    • Cardboard;

    • Paper;

    • Site Metals; and

    • Drinks Cans

  • The inclusion of a Penalty Charge System to deal with any sub-contractor who is not complying with the Waste Management System.  This would be managed by the externally appointed Control Manager;

  • Waste Performance figures could be produced and discussed for the site and as a comparison with other sites throughout the area / Industry.

Contaminated Land

Introduction

It is becoming increasingly necessary to redevelop land that has become contaminated by residues from previous industrial processes.  The Government has a strategy to build new homes on Brownfield sites and/or contaminated land and this procedure addresses the hazards associated with working on contaminated sites and aspects which need to be considered prior to work commencing.

The long term future use of the contaminated sites or how the contamination will be treated is not addressed.  These matters will be decided by The Company under the guidance of the Local Authority and will form part of a remediation contract.

It should be remembered that some contaminates have immediate effect on those who are exposed even for a short time, Land and Technical Department staff and trespassers, especially children, are likely to be affected as well as construction operatives.  Other contaminants have medium or long term effects even from very small exposure especially if they persist over long periods of time.  These may present a risk to eventual residents or users of buildings such as houses, schools, industrial or commercial premises.

​​​​​​​This procedure applies to all Company developments and is to assist in identifying if the site is contaminated and also the method of work to be undertaken when contamination is confirmed.​​​​​​​

Initial Appraisal

The Client or Developer, will have undertaken an appraisal of the development and ensured that the following points are covered prior to purchase:

  • Review any existing recent surveys and soils reports; confirm if site is ‘Greenfield’ or ‘Brownfield’.  The use of earlier fill materials may indicate earlier contamination.  Establish if appropriate chemical testing has been carried out on samples of the fill to check for contamination;

  • Ensure that a desktop study has been carried out or is part of the site investigation reports/surveys that confirms the previous occupation of the land, and the possibility of contamination.  The location of process equipment, waste storage areas, buried tanks etc. from previous occupation may be highlighted on maps or plans and identified as ‘hot spots’ or potential locations of buried structures;

  • Visit the site and look for evidence of any previous occupation, look for redundant structures or suspicious heaps, fly tipping etc. Check for the existence of mining or similar subterranean activities in the area these can point to the possibility of shafts on site, previous spoil tipping and underground methane;

  • Where concerns are raised and no previous investigation exists a desktop study and appropriate surveys e.g. environmental, soil and groundwater sampling and analysis must be carried out. Surveys should also enable the location of boreholes or trial pits and the determination of the types of samples to be taken for testing to be intelligently planned;

  • The location of new works, drainage and trenching must be reviewed taking into consideration any existing retained contamination. The possibility of relocation of such work to avoid disturbance of the contaminated ground must be considered;

  • If suspicious substances, drums and containers, underground structures, soil discoloration or unpleasant smells, are uncovered during construction, all works must stop and the area made safe. The H&S Advisor must be informed immediately and further sampling and analysis must be undertaken;

  • Efforts must be made to avoid contaminating the ground during the construction activities. Such potential contaminants could consist of hazardous demolition materials, unauthorised combustion, contaminated fill, diesel fuels and oils from construction equipment, hazardous construction chemicals, pile drilling mud, waste materials.  All must be handled in accordance with the appropriate regulations.

  • Any accidental contamination must be reported to the H&S Advisor and dealt with by a Specialist Contractor to an agreed method statement;

  • Biological hazards such as Weil’s disease, where connections have to be made to live sewers, psittacosis, also pathogens such as tetanus, hepatitis B and more rarely anthrax or smallpox etc should be considered.

Assessment of Risk

Written risk assessments of the potential risk to health and precautions required to protect workers and the public should be undertaken by an occupational hygienist, chemist or a bacteriologist.  This must be an ongoing process based on the information available and the state of the ground uncovered and they should be able to recommend an overall method of protection

The following points should be considered:

  • Detailed information is required on the nature, extent and level of contamination;

  • The level of risk and precautions necessary will depend on the likely exposure of the worker i.e. the precautions to be taken by a lorry driver remaining in his cab will be different from those of a fully exposed ground worker.  In localised areas of contamination consideration should be given to extra protective measures such as protective clothing and equipment;

  • The Project Management Team must ensure that contractors have carried out a realistic written assessment and that the specified control measures are provided and used;

  • The risk assessment should address the potential path associated with the contamination. Such as through skin absorption, skin penetration, ingestion, inhalation, asphyxiation/ gassing, fire/ explosion.  Substances which can be absorbed through the skin such as phenols and coal tars will require special consideration;

  • Risks to operatives will be enhanced industry conditions.  Many heavy metals if contained in the dust will present a significant risk of inhalation;

  • Very high or very low pH values for water samples should be viewed with concern.  Typical acid or alkali burns can be experienced on skin coming in contact with such conditions.

Precautions and Control Measures

  • The following precautions and control measures must be adhered to;

  • The contaminated areas should be clearly fenced off and suitable warning signs posted;

  • Access to and from dirty areas should be via a hygiene facility for personnel and via a gated wheel wash facility for vehicles;

  • A two metre minimum height security fence should be provided to the perimeter of the site;

  • The hygiene unit should provide appropriate washing facilities and facilities for storage of ordinary clothing and contaminated working clothing in separate areas.  Operatives must ensure they wash thoroughly at the end of each work period and they leave non-working clothing in the storage facilities provided;

  • Eating and smoking must only be allowed in designated areas of the site e. g. canteen;

  • Cabs of vehicles used on site should be provided with positive pressure or should be vacuumed at the end of each day to remove any contaminated dust;

  • The wheel wash facility should include a high pressure hose.  Where public road travel is required washing should include the under body and wheel arches;

  • Protective clothing such as safety boots, hand protection, eye protection, head protection, high visibility and protective overalls must be worn appropriate to the written risk assessment.  Contaminated clothing should be placed in double skin plastic bags and sealed before disposal or laundering.  Where there is a potential risk through inhalation, respiratory protective equipment should be provided;

  • Special attention should be given to confined space working and should be prohibited where practical. In addition to the normal measures such as providing support or battering the sides of excavations, it may be appropriate to line the sides of trenches etc. with polythene sheeting or similar, to reduce possible contact with contaminated soils. Where it is necessary to enter confined spaces procedures should be developed to enable the operation to be carried out safely.  A standard pattern for such procedures would be as follows;

    • Testing for oxygen deficiency, explosive gases, toxic gases such as carbon dioxide and hydrogen sulphide, or other gases indicated by site tests;

    • Ventilating the area as necessary;

    • Entry to the area on harness and line with full time supervision present;

    • Emergency rescue procedure should anybody be overcome, breathing apparatus for trained rescue personnel should be available.

  • Operations such as those involving excavators etc. may produce considerable quantities of dust particularly during hot dry periods.  These can be blown around the site and to neighbouring residential areas thus causing a potential risk to workers and members of the public.  Precautions such as water sprays to dampen down the dust should be considered;

  • Covered skips should be used for the removal of contaminated materials from site.  Drivers should be discouraged from covering the skips unless properly clothed.  Detailed waste movement records should be maintained and agreed with the Environment Agency prior to collection;

  • Health surveillance and first aid measures consistent with the risks involved should be provided.  Even the slightest scratch must be thoroughly cleaned by the First Aider and covered with a waterproof dressing and any health disorders such as headaches or stomach ache etc must be reported to the First Aider;

  • All workers/visitors to the site should receive appropriate information, instruction, and training.