Project background

The Environment Agency (EA) regulatory position statement (RPS) 211, ‘Excavated waste from utilities installation and repair’, allows utility companies that are members of Street Works UK (SWUK) (or contractors working on their behalf) to classify certain excavation waste streams arising from unplanned utilities installation and repair as non-hazardous without the need for laboratory testing and classification in line with the EA’s WM3 Technical Guidance document. However, in 2018, the EA indicated its intention to withdraw RPS 211, which would necessitate that all utility excavation wastes be classified and assessed in accordance with WM3 unless a replacement protocol was developed by industry, and this was agreed to by the EA.

Given the potential significant impact the withdrawal of RPS 211 would have on the utilities sector, between 2019 and 2022, SWUK coordinated its members’ participation in a phased industry-wide sampling and testing study of approximately 3000 samples of excavation waste that would otherwise potentially be disposed of as non-hazardous waste under RPS 211. The results of the study have been used to develop a risk-based approach as the proposed replacement protocol to RPS 211. In spring 2023, the sampling trial entered an implementation period focused on ‘fine-tuning’ the risk-based approach that will ultimately be presented to the EA for approval. SWUK indicated this final phase may last up to 18 months, with further sampling, testing and assessment to be carried out as part of this phase of work to demonstrate the efficacy of the new protocol.

RSK has supported many of its clients in the utilities sector with their participation in the first two phases of the sampling and testing trial, resulting in the chemical testing and waste classification of 1200 samples of excavation waste by its consultants and analytical testing laboratory. The services it has provided to its clients include (but are not limited to) the following.

Excavation waste sampling training

Technical staff in RSK’s waste team have delivered waste sampling training to its clients in the utilities sector at a range of locations across the UK. The training generally takes a full day to complete and comprises two sessions: an initial classroom session to provide information on the background and theory that underpins sampling of excavation waste followed by a practical sampling demonstration at a ‘live’ site.

Development of waste sampling protocols

RSK’s technical team has developed excavated waste sampling protocols bespoke to its clients’ requirements that collate the key information covered in the excavated waste sampling training for use as a reference guide by clients’ staff when sampling in the field.

Laboratory chemical testing services

RSK’s in-house environmental testing laboratory, Envirolab, undertook chemical analysis on approximately 1200 samples of excavated waste submitted as part of both phases of the SWUK RPS 211 sampling study. Envirolab has the capability to complete an extensive range of chemical testing for organic and inorganic substances on a wide variety of sample matrices, including soils, asphalt, water and leachate. Envirolab is able to expedite its analytical testing service to meet the specific needs of clients for projects when faster turnarounds are required. Envirolab is UKAS and MCERTS accredited and adheres to rigorous quality control and assurance processes to ensure the integrity of the analytical results it reports. In addition, Envirolab offers a complimentary in-house courier service and provision of sampling containers and consumables.

Excavation waste inspection and description

It is a legal requirement for waste to be accurately described during waste classification and assessment. As part of the SWUK sampling trial, RSK’s technical staff visited the in-house laboratory at Envirolab to inspect the samples of excavation waste submitted by client operatives so that a detailed waste description for each sample could be recorded, thus ensuring that waste classification and assessment of the sample were compliant with waste regulations.

Waste assessment and classification reporting

The technical team developed a bespoke waste classification and assessment report template for the SWUK sampling trial, which presented all the key information considered in support of the assessment of excavation waste samples in general accordance with the EA’s Technical Guidance WM3, ‘Waste Classification – Guidance on the classification and assessment of waste’. Our technical team produced approximately 900 standalone waste assessment reports detailing the waste classification and assessment of approximately 1200 samples of excavated waste. In addition, RSK has its own waste soils assessment tool (HASWASTE, developed by Envirolab and maintained by RSK), which follows the guidance within Technical Guidance WM3. The analytical results for every soil sample classified and assessed by RSK as part of the SWUK sampling trial was carried out using this tool.