RSK Geosciences services - Waste and resources logo

RSK continually prepares materials management plans and verification reports for clients in wide-ranging industrial sectors

CL:AIRE materials management plans

Under the Waste Framework Directive, naturally occurring soil is not considered waste if reused on the site of origin for the purposes of development. In accordance with the definition provided in the Waste Framework Directive, materials are considered waste only if “they are discarded, intended to be discarded or required to be discarded by the holder”. Thus, soil that is not of clean and natural origin, i.e., made ground (whether contaminated or not), and other materials, such as recycled aggregate, do not become waste until the aforementioned criteria are met.

Historically, the reuse of waste materials on construction sites in the UK has been carried out under an environmental permit, waste exemption or some other mechanism (such as a Quality Protocol or Regulatory Position Statement). The Definition of Waste: Development Industry Code of Practice (DoW CoP) (CL:AIRE, 2011) was developed in consultation with the Environment Agency and the development industry to enable the reuse of materials under certain scenarios and subject to demonstrating that specific criteria are met. Version 2 of the DoW CoP was released in 2018, and the third version is expected to be issued soon. The current scenarios covered by the CoP comprise the reuse of non-natural material on the same site at which it was generated and the transfer and reuse of natural material between two construction sites. The CoP requires the preparation of a materials management plan (MMP), which aims to confirm that four specific factors will be met. This plan needs to be reviewed by a Qualified Person (QP), who will then issue a declaration form to the Environment Agency. As the project progresses, data must be collated, and on completion a verification report must be produced that shows the MMP was followed and describes any changes.

RSK Geosciences services - waste and materials

We routinely prepare and issue MMPs and verification reports for many clients

We support clients including housebuilders, groundworkers, consulting engineers, principal contractors and local government, for scenarios ranging from anywhere between the simple transfer of topsoil between construction sites to on-site reuse of more than 100,000 m³ of material excavated during large earthworks projects. RSK also has a number of registered QPs across the UK who can submit declarations for MMPs authored by other regions, as well as directly assisting with producing declarations for MMPs written by external parties.

CL:AIRE MMPs apply in England and Wales only. We also have experience of providing similar services in accordance with the equivalent in Scotland, the Scottish Environment Protection Agency Land Remediation and Waste guidelines.

Waste management licensing/WM3 hazardous waste assessments

The UK’s Technical Guidance WM3 on the classification and assessment of waste provides guidance to assist waste producers, waste managers and regulators to accurately classify waste so that options for recycling and/or disposal of waste in compliance with waste regulations can be established. Waste classification and assessment include the selection of appropriate List of Waste codes (formerly EWC codes) and, where applicable, describing a waste’s hazardous properties and hazardous chemical components following assessment, which often is determined by chemical testing carried out in accordance with a waste sampling plan.

RSK has developed a waste soil characterisation assessment tool (HASWASTE), which follows the guidance within Technical Guidance WM3, that can be used to assess chemical data to determine if waste samples potentially exhibit hazardous or non-hazardous properties based on their chemical composition. RSK’s team of waste specialists is able to undertake waste classification and assessment on a wide variety of waste types, in addition to waste soil, including water, trommel fines, timber and filter cakes. RSK is able to offer specialist technical advice, expertise and guidance to assist its clients in classifying and assessing waste in accordance with WM3 guidance and remain compliant with waste regulations.

RSK’s waste and resources team has helped multiple clients in the utilities sector with their participation in phases 1 and 2 of the Street Works UK (SWUK) waste sampling trial, which is aimed at developing an industry-led protocol to replace the Environment Agency’s regulatory position statement (RPS) 211, ‘Excavated waste from utilities installation and repair’, once this guidance is fully withdrawn. The team has provided a wide range of specialist services and technical support for its clients throughout all parts of the process:

  • Waste classification and assessment of 1200 samples
  • Preparation of over 900 site-specific waste classification and assessment reports
  • Delivery of excavation waste sampling training to clients’ operatives, including both classroom sessions and practical demonstrations
  • Development of short bespoke waste sampling protocols for clients’ operatives to use a quick reference guide when sampling in the field
  • Laboratory chemical testing services using our in-house UKAS and MCERT accredited laboratory, Envirolab, which tests for an extensive range of chemicals, including organic and inorganic substances
  • Excavation waste inspection and description of all samples to ensure that all samples submitted by our clients for assessment meet the legal requirement to accurately describe waste as part of waste classification and assessment
  • Development of a bespoke WM3-compliant waste assessment and classification report template for the SWUK sampling trial presenting the key information required by the SWUK Steering Group as part of its overall appraisal of the sampling trial data

The team will continue to support its clients throughout phase 3 of the SWUK sampling trial, which commenced in January 2024.

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RSK Geosciences is part of the RSK group of companies

The RSK group is a leading integrated environmental, engineering and technical services business offering bespoke end-to-end solutions to a variety of sectors. Headquartered in the UK but with an established presence throughout Europe, Africa, the Middle East, Asia and Australia, RSK helps organisations around the world achieve their business aspirations in a sustainable and efficient manner.