Do you ever feel that you’re in danger of falling into a hole over soils management? If so, you’re not alone! The Regulation of ‘waste’ is designed to reduce risks of environmental damage and tax evasion, but it can put barriers in the way of the effective and sustainable re-use of soils.
There are legal holes (or traps) if you miss something important, which can quite quickly eat up cash that could be saved or even generated from re-using excess soils.
Drawing on years of consultancy experience, H Fraser Consulting has developed a series of blogs to guide professionals in using the CL:AIRE Definition of Waste Code of Practice (DoWCoP). These blogs provide practical insights on enabling the reuse of excavated materials on-site or transferring them between sites while ensuring compliance.
Complicated it is…
This blog series is authored by Associate Director Joe Gomme, a Qualified Person under the CL:AIRE DoWCoP. Joe will highlight common pitfalls in managing excess materials from excavation and groundworks, offering practical solutions to help you stay compliant and avoid costly mistakes. Here’s what you can expect:
- Blog 1 – Introduction
- Blog 2 – The questions to ask
- Blog 3 – Using the CL:AIRE DoWCoP
Before going any further, our appreciation goes to Chris Berryman and the team at Stantec who put together the CIRIA guidance on sustainable soils management[1], which we’ve found invaluable in bringing together the detail of this complicated area.
Regulation for re-use of surplus soils is governed by several different mechanisms. Which one(s) may be valid for your site depends on various factors including:
- Amount of materials
- Whether materials are “contaminated” or “clean, naturally occurring” soils
- Where the intended re-use will take place
- Whether planning permission exists for placement of materials
The principles of sustainability and the government’s Waste Hierarchy favour re-using soils wherever possible. But controls on inappropriate disposal limit the freedom to do this and sometimes put barriers in the way of sensible solutions.
In practice this can result in confusion and the misapplication of rules. The outcome can be soils re-used in ways that either endanger the environment or fall foul of regulations, or both.
It is important to apply the rules correctly – companies or individuals not having the correct or properly administered paperwork will be deemed to have illegally deposited waste. Details will be given to HMRC (opening potential landfill tax liabilities) in addition to any other enforcement action taken by the waste regulator.
Joe’s next blog will look at the different mechanisms that companies and individuals can use to manage excess soils on site.
So how do you avoid the pitfalls? See next our blog to find out more or contact our team of soil consultants to discuss your soil management project – email info@hfraserconsulting.co.uk or call Joe on 01743 352797.
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[1] https://www.ciria.org/CIRIA/CIRIA/Item_Detail.aspx?iProductcode=C809&Category=BOOK
