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?

Bosch Cordless Metal Saw

Bosch metal sawBosch have introduced their first professional cordless metal saw – the GKM LI 18v Professional, which, thanks to a new “Standard for Steel” saw blade, cuts steel with speed, precision and virtually no sparks. Looking at the video, you can’t help but think that this is streets ahead of grinder-type cutters in terms of environmental and H&S impacts. According to the makers, the 2.7 kg saw has a 4Ah battery and can make in excess of 300 cuts in a 20mm pipe on a single charge.

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)

Acoustic barriers

Echo Barrier 02Acoustic barriers are often seen as something to be used in town centre locations, positioned around the site perimeters to protect passers-by from noise pollution and minimise nuisance to neighbours. But, using such barriers within the site also reduces the risk of hearing  damage to operatives, and the need to wear bulky and uncomfortable hearing protection in hot weather. Many Echo Barrier 01systems are panellised and can be used to shield noisy items of plant and equipment within a site, preventing noise breakout, and resulting in a quieter and more comfortable working environment.

Use of such equipment away from town centres can also be beneficial for wildlife, reducing the risk of disturbance of protected species when working on sensitive sites, including nesting birds in early summer.

(Click on an image to visit the company’s website)

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.

Waste Transfer Notes

The need for a written description of a waste to accompany every waste movement so that the person receiving it knows what it is and can deal with it appropriately has been one of the four fundamental duties of the Waste Duty of Care since it was introduced into legislation in s.34 of the Environmental Protection Act 1990. Over the years, this gradually evolved into a requirement for (in England and Wales) a “Waste Transfer Note” or “WTN”.

WTN 500Detailed requirements for the content of a WTN were brought up to date in Regulation 35 of The Waste (England & Wales) Regulations 2011 (SI 2011/988), all of which was incorporated onto the standard form produced by the Environment Agency and readily available online. However, the use of this form was not mandatory providing that any alternative WTN form contained all of the information required by Regulation 35. This permitted larger waste companies to produce their own versions of it for issue to their customers whenever waste was collected from site.

On 6th April 2014, s.6 of the 2014 amendment to the Waste Regs (SI 2014/656) replaced “transfer note” in Regulation 35 with “written information”, permitting a much wider range of documentation than formal WTNs, such as invoices or skip exchange notes – however the need to provide all the Reg.35 information remains.

At the same time “edoc“, the “electronic Duty of Care” online waste documentation and tracking system, has come into use, permitting companies to register their waste activity online, and to register and track waste movements electronically without the need for paper documentation.

Overall, the relaxation of WTN requirements permit a far more flexible approach to proving compliance with the waste Duty of Care, but does not remove any of the obligations on waste producers to be able to demonstrate and document compliance with the Duty if challenged by the Regulators, including provision of all the information required by Regulation 35 that would previously have been documented on a formal Waste Transfer Note.

Invasive Species “Control Order” Proposals

At present in England and Wales, whilst it is a criminal offence to “cause to spread” invasive non-native species such as Japanese knotweed, there are no real controls on allowing to continue growing on your land if you already have it, However authorities in Scotland have for some time been able to apply “Control Orders” to existing infestations, and as a result of new European pressure, the Law Commission reviewed the Scottish approach during 2014, and made recommendations for the introduction of essentially similar legislation in England

The 74 page report makes 45 separate recommendations, starting from a recommendation that “there should be a power to make species control orders to control invasive non-native species in England and Wales modelled broadly on the procedure introduced by the Wildlife and Natural Environment (Scotland) Act 2011.”

In taking this approach, the Law Comission recommends that species that could be controlled by such an order should be BOTH:

  • Invasive – if not controlled would have an adverse effect on biodiversity, other environmental interests, or social or economic interests, AND
  • either an animal or plant not ordinarily resident in or a regular visitor to Great Britain, or one listed in Schedule 9 of WACA 1981

For such species, the recommended process would follow four distinct steps:

  1. Investigation – recommendations include powers to permit regulators to enter land (but not buildings) to establish whether or not a species is present that meets the tests above.
  2. Species Control Agreement – a voluntary agreement between the regulator and the landowner / occupier to carry out works to control or eradicate invasive non-native species. If an agreement is put into place and the works are carried out, the process would stop at this point.
  3. Species Control Order – a requirement for the landowner / occupier to carry out specific works to control or eradicate invasive non-native species.
  4. Enforcement – Should the works agreed in a Control Agreement or specifies in a Control Order not be carried out, the authority can carry out the works themselves, or arrange for them to be carried out.

The are also provisions for omitting the first two steps in emergency situations. However, some of the more interesting recommendations are tucked away within the report, including the recommendation that the cost of control or eradication should be borne by the public purse, except in instances where the situation has been made worse by wilful action or neglect by the landowner / occupier. Similarly, any proposed control actions should be proportional to the wider risk posed should the species remain unchecked on that site.

Overall, in the case of invasive plant species, I could see this being primarily used where infestations are spreading across boundaries, or in instances where plants have been spread through neglect of proper procedures. It will be interesting the see the final form of the legislation once implemented.