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

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)

Are paint tins Hazardous Waste?

I’m frequently asked whether empty containers that have had hazardous substances in them (gloss paints, adhesives, etc) are always Hazardous Waste (Special Waste in Scotland), and if not, when do the containers stop being considered hazardous? The strict answer to this is contained in Example 10 (p.A48) of EA Technical Guide WM2, but the slide below illustrates the basic principles:

De minimisAfter the first question about what the container itself is made of, is whatever you’ve been using only hazardous because of a solvent in it? Consider: If you had to throw away whatever you’ve just painted, or treated, or glued together, would you consider THAT hazardous because of the product you’ve used on it? If you would (for example applying a timber preservative), the container remains hazardous even if its nominally empty and completely dry unless you wash and clean the container to remove all traces of the product from both the inside and outside surfaces. If however it’s just a solvent that’s the issue, you can move onto the final test.

So, how much of the product remains, and what’s the risk of the solvent remaining other than in the very short term? For the first part, WM2 uses the phrase “nominally empty” which is normally accepted to be the same as the old “de minimis rule” – it’s “nominally empty” if less than 1/1000 (0.1% – a common risk threshold) of the original contents remain in the container. The final part is about whether or not the residue is open to the atmosphere so that any solvent remaining in the last 1/1000th can evaporate. So, a nominally empty gloss paint tin with its lid on would still be hazardous waste, but if you remove it, it’s not. The same principle applies to depressurising aerosol cans such as spray markers – left sealed they remain hazardous waste, but open them up (and providing all the other conditions are met), they are no longer hazardous waste.

But – if in doubt, it’s better to err on the side of caution and assume it’s hazardous unless you are certain it’s not!