UKCG Environmental Training Standard

The UKCG Environmental Training Standard  was published in July 2015, and recognises the leadership role that UK Contractors Group member companies play in driving best practice within the construction sector. It sets down the minimum training expected for individuals to undertake their roles on member’s sites to be able to demonstrate their competency through formal environmental training, including the CITB SEATS course.

This document sets down the standard of environmental training applicable to those who manage, supervise or undertake construction related activities as follows:

Site Managers (including those employed by supply chains):

  1. CITB SEATS+ Course (SEATS plus additional management modules); or
  2. A comparable external course approved by the UKCG Environmental Training Task Group; or
  3. An internally developed course that can demonstrate training outcomes comparable to 1 and 2 above.

The training must last a minimum of TWO DAYS, include a form of assessment, and a completion certificate. Refresher training must be carried out at intervals not exceeding five years.

Site Supervisors (including those employed by supply chains)

  1.  CITB SEATS Course; or
  2. A comparable external course approved by the UKCG Environmental Training Task Group; or
  3. An internally developed course that can demonstrate training outcomes comparable to 1 and 2 above.

The training must last a minimum of ONE DAY, include a form of assessment, and a completion certificate. Refresher training must be carried out at intervals not exceeding five years.

Site Operatives (including those employed by supply chains)

A relevant competency scheme card including the CITB Health Safety & Environment Test where required, and renewed as necessary.

Note – in July 2015, the UKCG and NSCC (National Specialist Contractor’s Council) merged to form Build UK. A list of the members of the new body can be found here

Thoughts on a flat-packed wardrobe …

Just before Christmas, I assembled a flat pack wardrobe for my daughter, and it got me thinking about waste, or rather non-waste.

I was impressed. We ordered it over the internet, picked our day and a four hour delivery slot (10-2). The day before, the courier reduced this to a two hour slot (10-12), and on the day a text informed us that delivery would be within the hour, which it was. And at 11.30am, two packages totalling 88kg (big wardrobe with drawers …) were sitting on the floor ready for assembly. Unpacking took a while, with a small mountain of cardboard wrapping & polystyrene spacers set to one side. Not one scratch, ding, chip, mark … at all. Four poly bags of fittings, 319 items in total. By 5.30pm, it was fully assembled, in position, doors aligned, and safety-fixed back to the wall. And all that was left over was four poly bags. The fittings were exact. None missing, none left over. Spot on. Exactly what I needed, no more, no less.

(One beef, oh flat-pack-furniture industry … why polystyrene? Why not blocks of corrugated cardboard that can go into the recycling bin instead of the landfill bin? Just a thought … )

So, what impressed me? Well, firstly; I got what I wanted, when I wanted it. With excellent communications so that I could be at my daughters at the right time, and not waste any of my day sitting twiddling my thumbs wondering where it was, when it would arrive, or whether it would even arrive that day at all. Secondly, it arrived in good condition, carefully handled, with the right amount of packaging to ensure nothing was damaged or missing. No having to argue about delivery damage, or getting replacements. And thirdly, all 319 parts that were delivered fitted somewhere. They all went in … I had nothing whatsoever left over. They had confidence in their take-off & packing systems: nothing extra delivered “just in case”.

And in the New Year, I’ll be back on construction sites again, looking at all the surplus materials delivered “just in case”, lying forlornly in the rain and snow, and destined for the skips at the end of the job because they’re too heavy/awkward/tatty to take to use somewhere else. And I’ll be walking around picking up (as you do) all the screws/bolts/widgets strewn around the floor and putting them back into their nearby boxes. And thinking about my wardrobe experience. And the 120 million tonnes of waste that the UK construction industry generates every year.

The waste that costs an average project about 0.5% of the project value to dispose of. The waste that if you look at it properly and think of it’s true worth, really costs a project 10x-20x it’s disposal cost. (How much did you pay for the things you’re throwing away, their delivery, storage & handling on site, and eventual movement to the skip?) In other words, the waste in your skips, rather than being a minor consideration, represents 5-10% of extra profit, or improved competitiveness. And I know many Commercial Managers in the industry who would sell their grandmothers for a tiny slice of that. (Bet you smiled … because you know it’s true.)

A thought: The construction industry contributes about £100 billion a year to the UK’s GDP. What’s 5-10% of that?

Back to the wardrobe & the things I learned. It is possible to have just what you want, delivered just when you want it, adequately packaged and in good condition. We know that consolidation centres and just-in-time deliveries work for construction projects, but these are the exception rather than the rule as soon as you move away from congested city centres, but why? Isn’t it time to spend some of the £5b – £10b we waste every year embedding this approach into the industry so it becomes the norm everywhere rather than the exception? I have no doubt it would pay dividends immediately if properly done. And stop a lot of waste.

It’s time to stop talking about “recycling”, and “zero waste to landfill” as aspirational targets – these should now be the norm. It’s now time to start talking about completely removing waste from the construction process – just “Zero Waste”.

Modern Slavery Act 2015

CSLz17PUwAAw4f4This may be a strange thing to see on my website as slavery was abolished nearly two centuries ago, but anti-slavery groups estimate that between 21 million and 38.5 million people are trapped in involuntary employment. With the introduction of the Modern Slavery Act, the UK Government is requesting (not “requiring“) companies to take steps to ensure slave labour is not used in their supply chains. The legislation was passed in March, is likely to come into force in shortly (exact date to be confirmed following consultation) and applies to companies with a revenue in excess of £36m.

The purpose of the act is to require larger businesses to be transparent about what they are doing to address this global issue. It requires any commercial organisation supplying goods and services wholly or partly in the UK with a turnover in excess of £36m to produce a Slavery and Human Trafficking Statement for each financial year. The statement must be approved and signed at the highest level, for example by a Board of Directors, and must be prominently displayed, for example on a corporate website, so it is visible to interested parties, members of the public and NGOs.

A Slavery and Human Trafficking Statement must describe the steps the organisation has taken to ensure that slavery and human trafficking are not taking place in any part of it’s own business or in its supply chain. This statement may incude information about:

  • The organisation’s structure, it’s business and its supply chains
  • Its policies in relation to slavery and human trafficking
  • Its due diligence processes in relation to slavery and human trafficking in its business and supply chains
  • The part of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk
  • Its effectiveness in ensuring that slavery and human trafficking is not taking place in its business and supply chains, measured against such performance indicators as it considers appropriate
  • The training about slavery and human trafficking that it makes available to its staff.

Interestingly, businesses could comply with the legislation by publishing a statement that they are doing “Nothing”, although this approach risks attracting negative stakeholder, public, and media attention …

(Image copyright Liz Ackerley, with thanks. Click on the image or visit her blog here)

Great crested newts – a new approach

Great crested newtA pilot project is currently underway in Woking that may herald major changes to the way great crested newt conservation is undertaken in the UK, minimising cost and disruption to development sites under the present restrictive system whenever newts are present in the area.

The trial, being undertaken jointly by Natural England and Woking Borough Council, aims to identify to size, location and connectivity of newt populations in the area by testing for trace newt DNA in pondwater. This new survey technique will be used to produce a local conservation plan for the newts, linking up and protecting the most important populations, specify where new habitat should be created to ensure a healthy overall population, and identify areas where development will have least impact. The Council will then put the new habitats in place so that when development results in habitat loss, habitat gains will already be in place to compensate.

Speaking of the new proposals, Andrew Sells, Chairman of Natural England, said:

“This innovative pilot in Woking is an exciting opportunity that I hope will bring significant benefits for conservation. The current licensing system for European Protected Species in England is quite a rigid way of protecting great crested newts, placing the emphasis on individual newts, rather than the species as a whole. By making the system more flexible and strategic, it will enable us to establish habitat for great crested newts, where their populations will most benefit from being in a wide network of habitat, rather than being squeezed in around development. Alongside creating strongholds for great crested newt, this ground-breaking approach will streamline the delivery of much-needed development and lift constraints on the layout and design of development land.”

…. Go to the original CIEEM article

Resource recovery – a waste of time?

Over the summer, I’ve been providing interim cover on a largish site for a couple of days a week. In the two days this week, I became aware of an issue with lost resources – hired-in tower scaffold components that had been dismantled, and pretty much lost around the site, for which the contractor was facing a potential bill of around £3000. So while I was doing my normal day-job of keeping an eye on everything, I began to keep half-an-eye open for the missing bits … and started spotting them in stray corners and buried under rubbish and other materials. So, as I hate the idea of these bits ending up in a skip in the last few days as the site was crash-cleared, I grabbed the component list and started to collect them together and drop them back into a storage unit. And over a couple of days, I recovered all but one component, with the final collection looking like this:

Tower scaffoldSo, was it worth it? In my mind yes, most definitely:

  • I managed to recover about a tonne of high quality aluminium tower scaffold components and get them back into productive use. (To be fair, the site would probably have done this anyway, provided they didn’t run out of time at the end of the job!)
  • This avoided about a tonne of aluminium entering the scrap metal market and being recycled, with the energy and emissions associated with this process
  • By recovering the original components, we avoided the hire company having to replace them, with all the manufacturing impacts associated with this process
  • And finally – it avoided the penalty charge to the contractor of at least 10x the cost of my time (probably less than half a day in total) to find them and get them back into the contractor’s control.
  • (Oh, and it was pretty good exercise too …!!)

OK, it’s not the normal day-job of a site Environmental Manager, but on the other hand, why not?

Disposal of composite cladding panels

Composite metal-faced insulated foam cladding panels, also known as “sandwich panels” or “engineered panels” have become a common construction product since their introduction for cold stores over 40 years ago, and are now used extensively as external cladding systems for a wide range of buildings. With a design life of 30 years or more, many early panels (and buildings)EPIC cover 600 will be reaching the end of their useful life, and are likely to be subjected to extensive refurbishment and / or alteration, resulting in the need to dispose of unwanted panels.

However, this is not as straightforward as it may at first seem, as many early panels used CFCs and later HCFCs as blowing agents for the foams – gases which damage the ozone layer if released into the atmosphere (Ozone Depleting Substances, or ODS) – and as a consequence their release is strictly controlled by legislation; for example, the requirement that domestic fridges are recycled in an inert atmosphere and their ODS recovered for destruction. And in exactly the same way, those construction insulation foams that contain these same gases are also “Hazardous Waste” if the proportion of ODS exceeds the 0.1% threshold (see below) and must also be disposed of in a similarly controlled manner.

There is an industry guide to help identify and correctly dispose of metal faced composite foam panels (click on the image to go to the website where you can download the pdf guide) but here are a few simple rules to help identify foam insulation panels containing ODS:

  • If the insulation foam is polystyrene (PS) of any date, it does NOT contain ODS

For other insulation foams, such as polyurethane (PUR), polyisocyanurate (PIR) and phenolic resin foams (PF)

  • If the foam panel was manufactured before 1990, it almost certainly DOES contain ODS
  • If the foam panel was manufactured between 1990 and 2004, it MAY contain ODS
  • If the foam panel was manufactured after 2004, it does NOT contain ODS

If in doubt, the blowing agent can be identified by laboratory testing. However, even the newer (flammable) hydrocarbon blowing agents such as pentane are not free from problems as a recent EA report demonstrated, and since December 2012, all wastes containing hydrocarbon blown insulation foam must be consigned as Hazardous Waste to minimise the risk of explosions and fires at metal processing facilities.

For the relatively small number of ODS panels that have been discarded to date, the normal method of disposal has been to cut the panels up with a reciprocating saw into maximum 2m x 1m sections and dispose of them in one of the four domestic refrigerator recycling plants in the UK. However, with the commissioning of a new industrial-scale panel recycling facility capable of safely processing both ODS and pentane-containing foams, the need to carry out this labour-intensive operation has now been removed, and any panel that can be fit inside a 40-yard roll-on roll-off container can now be processed directly without size reduction.

The determination of ODS-containing foams as Hazardous Waste

Regulation (EC) 1005/2009 on substances that deplete the ozone layer sets down in Annex 1 substances that deplete the ozone layer, including a wide range of chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs). Regulation (27) specifically states:

“Directive 2006/12/EC … and 91/689/EEC … provide for measures on the environmentally sound disposal and recovery of waste and controls on hazardous waste. In this regard, special attention should be paid to ODS in construction and demolition waste (my highlighting) and in equipment falling within the scope of Directive 2002/96/EC on waste electronic and electrical equipment (WEEE).”

This has been directly incorporated within the List of Wastes Regulations for WEEE waste with a specific entry in section 16 02 “wastes from electrical and electronic equipment” :

“16 02 11* discarded equipment containing chlorofluorocarbons, HCFC, HFC”

but no similar entry exists for construction wastes other than generalised references to “dangerous substances”. Reference to EA Guide WM2 “Hazardous Waste. Interpretation of the definition and classification of hazardous waste” indicates that on p.20, Risk Phrase R59 “Dangerous for the ozone layer” applies to substances that appear in Annex 1 to Regulation (EC) 1005/2009, ie a wide range of CFCs and HCFCs – the common blowing agents for earlier foams – and sets a Hazardous Waste Threshold Level of 0.1%. The waste type is therefore a “mirror entry” waste, and should the threshold be exceeded in a construction foam, the Hazardous Waste entry should be used when consigning waste. This guidance is repeated in Appendix C14 of EA Guide WM3 “Guidance on the classification and assessment of waste” against Hazard Statement H420 “Harms public health and the environment by destroying ozone in the upper atmosphere” with a similar 0.1% threshold.

For such materials, my choice of LOW code and expanded description for unstripped (whole) insulation panels containing threshold-exceeding ODS or hydrocarbon blowing agents would be:

  • 17 04 09* metal waste contaminated with dangerous substances (ODS or Hydrocarbons in foam)

and for stripped panels where only the threshold-exceeding ODS / hydrocarbon-blown insulation is consigned:

  • 17 06 03* other insulation materials consisting of or containing dangerous substances (ODS or Hydrocarbons)

Energy Targets for Buildings

Derbys Eco-Centre 600With the UK Government’s decision to scrap Zero Carbon energy targets for new buildings comes the opportunity to consider better and more practical targets to minimise energy use in the near (25 years) future.

The problem with the Zero Carbon energy target was that it addressed only one form of building energy use (Operational) whilst ignoring Embodied energy – the energy used to manufacture the materials for the buildings that would use the operational energy. If this was relatively small, this really wouldn’t be a problem, but for a modern building constructed of conventional building materials (steel, concrete, masonry, timber), this can be the equivalent to 30 years or more of operational carbon – carbon emitted before the building is even occupied. And this is only the “Initial” embodied carbon – the carbon used to first construct the building; to this must be added the “Recurring” embodied carbon – the carbon required to maintain and refurbish the building over its lifecycle and maintain its’ fitness for purpose and use.

This “recurring” carbon can be relatively minor but frequent – cleaning, for example, or more significant but less frequent – replacement of carpets & finishes or redecoration. However, at some point of the building’s life, a major refurbishment may be take place, for example replacement of the building’s roof or walls – a significant future expenditure of carbon. Or repurposing to make the building suitable for a different use.

Is there a better alternative? Yes, there is – to give all new buildings a “Carbon Budget” for the next 25 years based on total energy use: Initial Embodied (IE) + Operational (O) + Recurring Embodied (RE). For commercial buildings, this could be “functional” for example “Per square metre of internal floor area”, whilst for domestic this could be performance based “Per occupant” (based on say design bedroom occupancy). However it’s measured, the impact would be the same. It wouldn’t matter whether the design was simple (low IE) but with higher operational (O) emissions, or complex (high IE / RE) with low “O” – after 25 years, the total carbon emissions would be exactly the same.

And if you want to improve the performance of buildings year by year, simply reduce their Carbon Budget.

(I’ve written about this topic before – you can read my 2011 article on this here)

UKCG Ethical Stone Procurement

Recognising that there are environmental and ethical concerns about how dimensional stone is quarried and processed the UK Contractors Group encourages members to address the environmental and socio-economic issues in their supply chain through the following commitment:

“The UK Contractors Group, recognising the inherent risks in sourcing dimensional stone, will give preference to suppliers demonstrating leadership in the ethical stewardship of their supply chain. This can be evidenced through compliance with a recognised responsible sourcing scheme, certified by a third party, or active participation in the Ethical Trading Initiative (ETI Stone Group), the TFT Responsible Stone Program, or the United Nations Global Compact, and membership of the Stone Federation GB.”

The concern has been brought about by quarry owners in India (70-80% of UK imports) and China (15% of UK imports) who have little awareness of the environmental impacts of quarrying, leading to deforestation, pollution of ground water and failed rehabilitation of abandoned quarries. In addition, media reports have highlighted labour abuses and other social issues in the quarried stone industry.

(“Dimensional stone” is natural stone that has been selected and fabricated – trimmed, cut, drilled, ground or other – to specific sizes and shapes)

Separate business waste collections

Back in 2011, Regulations 13 & 14 of the Waste Regulations required that from 1st January 2015, all waste collection authorities must make arrangements for the separate collection of dry recyclates of waste glass, paper, plastic and metal, the implication being that businesses would have to separately store these wastes at source. The regulations did however permit comingling of these wastes in a single container for collection and separation elsewhere, rather than requiring four separate containers for these waste streams.

However, Regulation 13 was amended and clarified in Regulation 2(4) of the Waste (England & Wales) (Amendment) Regulations 2012 (SI 2012/1889) as follows:

“The duties in this regulation apply where separate collection—

(a) is necessary to ensure that waste undergoes recovery operations in accordance with Articles 4 and 13 of the Waste Framework Directive and to facilitate or improve recovery; and

(b) is technically, environmentally and economically practicable.

So, where an existing waste collection service already includes suitable waste segregation and recovery processes, such as construction waste going to a Materials Recycling Facility (MRF) which will probably report in excess of 95% recovery, separation at source and separate collections are not “necessary to ensure that waste undergoes recovery operations” and is not required under current legislation. However, if a waste collection authority has previously collected mixed waste and simply taken it to a disposal site (landfill, incinerator, etc) without any further segregation, segregation at source and separate collection is now required – provided of course that this is “technically, environmentally and economically practicable“.

Chemical dust suppression

Dust suppression c1Dust on construction sites is a common cause of nuisance to neighbours. To reduce this, many sites damp down dusty surfaces during dry weather using large quantities of (normally) tapwater, which rapidly evaporates in warm, dry weather and needs to be replaced to be effective – often at a time when there may be increased stress on mains water supplies.

However, by adding small quantities of relatively harmless chemicals to the mix. the need to respray can be dramatically reduced. These chemicals fall into two main groups – hydroscopic minerals that both hold and reabsorb moisture, and chemical “glues” that bind particles together into larger clumps, making them less likely to become airborne.

Hydroscopic minerals such as calcium chloride are mixed with water during spraying, and if applied to previously damped surfaces, or after rain, rapidly penetrate 7-10cm into the ground. By absorbing moisture in the surface layers, they maintain moisture content, increasing the shear strength of the surface reducing dust and surface wear. In dry weather, the mineral will dry out to some extent during the day, but will reabsorb moisture at night. In wet weather, heavy rain drives the mineral deeper into the soil, but as the surface dries, capillary action will return the mineral to the surface, maintaining it’s effectiveness in variable weather. The product has been used by the quarry industry for a number of years, and has shown to be effective on heavily used haul roads for in excess of four weeks. In addition to it’s moisture retaining properties, calcium chloride is also a mild weed suppressant, but unless used at excessive concentrations, has little impact on local wildlife and ecology.

Chemical “glues” such as calcium magnesium acetate (CMA) are normally applied “waterless” by spreading with a modified grit spreader onto a clean surface. Rather than binding the soil surface to prevent dusting, they instead bind individual fine dust particles (such as PM10, and to a certain extent PM2.5) into larger clumps that are more resistant to airborne suspension, remaining on the road surface for dispersal on vehicle wheels or removal by road sweepers. Clearly, the effectiveness of such chemicals will reduce with time (depending upon the level of dusting present and the rate of dispersal on vehicle wheels) requiring regular reapplication to control dust in the longer term. CMAs have been trialled extensively by Transport for London since 2011 in attempts to reduce PM10 pollution in the capital, and with regard to environmental impacts in their report they state: “The TfL report stresses that CMA is non-toxic, presents no significant risk of corrosion and is harmless to plants and water supplies. The calcium and magnesium components, the report says, can ‘benefit’ soil, just as liming a garden improves permeability, while the acetate portion biodegrades naturally.

Clearly the two systems act in different ways, and understanding their effect would determine exactly which might be most useful on construction sites. However, as a rule of thumb, hydroscopic minerals such as calcium chloride appear to work well on absorbent surfaces such as haul roads by maintaining a damp surface and minimising surface breakdown, whilst chemical glues are effective on hard, relatively clean, infrequently swept surfaces subject to light residual dusting from vehicle movement such as tarmac access roads.