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100111 Intro Swmp Overview Presentation (78)
1. Site Waste Management Plan Regulations 2008
Guidance for Local Authorities What do you want to gain
from today?
Global construction consultants
Objectives Agenda
Introduction
Understand the SWMP Regulations 2008
SWMP Regulation 2008 Overview
Vinci Construction - ‘The SWMP Experience’
Agree how your Authority can enforce the Break
Regulations
Enforcement and Supporting Environment
EA Approach
Align your approach with the Environment Agency
Lunch
Identify ways to drive performance Working session –your approach?
Present outputs
Close
Waste in the UK
Why is construction waste important?
2. Why is construction waste important? True Cost of Waste
Impact on the environment: Disposal costs and escalating
• Depletion of resources landfill taxes
• Embodied carbon
Value of materials wasted
• Pollution
• GHGs from landfill Project programme
Impact on productivity Lost revenue
• Financial
• Competitiveness Transport
Shortage of landfill capacity Management
(linked to Planning)
Trades’ time
Fly-tipping
Processing
Efficient material use
Sustainability
goals
Energy Materials Water
What should the industry be doing?
Materials Materials
‘In’ ‘Out’
Maximise the reuse of Waste Materials
reclaimed materials reduction recovery
What is a SWMP? SWMP driving improvements
Document which contains:
A forecast of waste types/quantities; Site Waste Management Planning – managing waste and
Intended waste management & end destinations; and resources on a project to achieve reductions in waste to
Actual waste produced. landfill
SWM Plan – document
containing waste forecasts,
action plans and actual waste
types/quantities
3. Key Principles Opportunity Curve
Planning Implementation
Review Monitoring
Outline Detailed Pre Construction Post
Design Design Construction Completion
Regulation versus Good practice
Design
Waste
Out
policy
waste
Updating
Waste
with actual Storage
forecasts What is the industry doing?
data
Evidence of
Management Completed
reduction &
Actions plan
recycling
Outline Detailed Pre Construction Post
Design Design Construction Completion
Government Action Policy Context
Strategy for Sustainable Construction
Strategic Forum
Construction Commitments: Halving Waste to Landfill
Government Policy Code for Sustainable Homes
Waste crime strategy
Fly-tipping protocol
Legislation Taxation
Support
4. Waste Disposal Regulations Landfill Tax
Duty of Care 1991 Active waste rate for 2009/1010:
Registration of Carrier 1991 £40/tonne
Waste Management Licensing 1994 Increase to £48/tonne in
Landfill 2002 2010/2011
Clean Neighbourhoods and Makes up about 60% of
Environment Act 2005 construction waste
Hazardous Waste 2005
List of Wastes 2005 A lower rate of £2.50/tonne
Waste Electrical & Electronic Equipment applies to inactive waste
2006
Makes up around 40% of
Site Waste Management Plans 2008 construction waste
Difficulties arise, but…. Support
Forecasting waste WRAP
Envirowise
Awareness levels still low BRE
Constructing Excellence
Issues of ownership often confused NetRegs
Data collection
Industry Action
SWMP Regulations 2008
5. Site Waste Management Plan
Why Regulate?
Regulations 2008
1. Improvement in materials
Came into force 6 April 2008 resource efficiency
2. Reduction in fly-tipping
Legal requirement on all projects > £300K
(increased requirements for >£500K) Construction is a major waste
producer
Clients and Contractors have legal Concern with Duty of Care
obligations compliance
Fly-Tipping is a growing problem:
Cost to taxpayers = £50mpa
LA and Environment Agency enforcement 20% of fly tipped waste is C&D
powers waste
31% of worst incidents involve
C&D waste
‘Soft’ enforcement for the first 2 years 40% of all incidents involve
C&D waste
How do Regulations help? What are the benefits - LA?
Tracking waste by ensuring that those responsible for construction Reduced fly-tipping and a cleaner,
projects know: safer, greener local environment
The intended destination of waste removed from site; Savings in LA functions such as
That their waste is being managed by legitimate registered cleaning-up fly-tipping
waste carriers; and Helps to raise awareness and
That their waste is managed responsibly, in line with waste compliance with existing legal
management controls provisions, e.g. fly-tipping, waste duty of
care
Improving resource efficiency by: Save investigations into illegal waste
activity
Raising awareness
Less demand on landfill
Considering waste early, to plan and mitigate
‘Modern resource efficient industry’
Basic overview
SWMP should include:
• Headline information about the
project, client & contractor;
• Name of person responsible for the
plan;
What do the Regulations require? • Forecast the quantity/type of waste
to be generated;
• Identify clear actions for each waste
type to reduce waste, and increase
recycling;
• Record actual quantities and end
destination for each waste stream;
• Provide declarations.
6. Scope Applicability
Any client intending to carry out a Full range of projects
construction project on one site with Buildings
an estimated cost greater than Infrastructure
£300,000 must, before work begins,
prepare a SWMP New-build
Refurbishment
Evidence of a ‘planned project’ may SWMPs apply to all aspects of
include planning consent, building construction work
regulations approval or relevant Demolition
contract documents Excavation
Exemptions Level of Detail & Updating
Routine maintenance For projects with value of £300- £500K
Part A installations Identify roles
Nuclear licensed site with an Integrated Forecast waste types (inert, non-
Waste Strategy (IWS) hazardous or hazardous), volumes,
recovery/disposal routes
Record quantity, type, carrier, license
If a project is planned before 6 April no., site waste taken to
2008 and the construction work begins Copy of or reference to WTN
before 1 July 2008 then the requirement Within three months of completion
to prepare and implement a plan does
• Confirm regularly monitored and
not apply updated
• Explain deviations from the plan
Failure to update is an offence
Level of Detail & Updating Availability of SWMP
For projects with value over £500K Must be kept on site
As basic SWMP + All contractors must know where it is
Whether site operator holds a permit or kept and it must be available to any
is exempt contractor carrying out work included
Update 6 monthly & within 3 months of in the plan
completion
Compare estimated versus actual Keeping plans
quantities Must be kept for two years after
Estimate cost savings completion of the project
The identity of the person removing
the waste Failure to comply is an offence
Failure to update is an offence
7. Additional Duties: Schedule 1
Principal Contractor
Coordination of the work
Cooperation among contractors
A Contractors viewpoint on SWMPs
Site induction
Job specific information/training
Manage waste within the terms of the SWMP
Ensure, so far as reasonably practical, waste is reused, recycled and
recovered Victoria Hill
Jade Hunt
Client Richard Smith
Give reasonable directions to any contractor to enable PC to comply
Client & Principal Contractor
Review, revise & refine SWMP as necessary
Clearly communicate changes in roles & responsibilities
Ensure security to prevent illegal disposal of waste
VINCI Construction UK The Group
VINCI Construction UK Limited incorporates the heritage and experience VINCI Construction UK has an annual turnover exceeding £1 billion.
of major UK construction brands to provide a fully integrated service in VINCI PLC is the parent company of VINCI Construction UK and forms
the following sectors: part of VINCI, the world’s leading concession and construction group.
Building
Civil Engineering
VINCI has a turnover of €33.5 billion and 164,000 employees in 90
Air
Countries around the world.
Facilities
Technology
SWMPs – our experience SWMP Stages
Subsidiary companies using SWMPs since 2000 Pre-Tender SWMP
- Promotes waste reduction and recycling - Often non-existent!
- Reduces costs - Can be asked for in tender documentation by Client
- Improves overall site performance
- Increases control in accordance with Duty of Care Regulations Pre-construction SWMP
- But was generally reactive monitoring (e.g. Client requirement) - Developed by Principal Contractor
Introduction of Regulations was welcome Live SWMP
- Encouraged proactive waste consideration - Monitoring and measurement of actual verses predicted waste volumes
- Created a level playing field
- Elevated waste ‘up the agenda’
Post-construction SWMP
- Resulted in better resource management
- Rarely undertaken with Client, but can offer rewards.
- But focus of Regulation missed most significant opportunities
- No obligation on Client
8. Pre-Tender SWMP
Responsibility of CLIENT
Document approximate waste types and volumes
Design in reuse where possible
Minimise waste through smart design
Missed opportunity, rarely considered before design is near
completion
No push from clients to minimise waste
SWMP – Design Decisions
Bath Hospital Project
Pre-construction SWMP
Waste volumes predicted by Site Waste Manager or
estimating team
Can be difficult to estimate, but the main purpose is to
improve the management of anticipated waste streams
Encourages early communication with waste management
contractors
Develop resource management plan, prevent materials
becoming ‘waste’
SWMP - Forecast
Sheffield BSF School Project
Live SWMP
Responsibility of Site Waste Manager
Each transfer of waste is logged
Waste volumes reviewed at intervals
Assists contractors to monitor Duty of Care requirements
Can identify anomalies and determine cause (only if predictions
are sensible)
9. Live SWMP - Waste data log
Gatwick Airport Project
Post construction SWMP
Review lessons learnt
Review waste volumes – reasons for increase/decrease
Client can benchmark contractors on repeat schemes
SWMP – Case Study SWMP – Case Study
T4 CIP Lounge T4 CIP Lounge
Good information relating to decisions made to reduce waste: Variability between forecast and actual volumes:
Phase ‘effectiveness’ What do we expect from Regulators?
Construction phase - limited influence
Consistency and fairness but;
What is the purpose of the Regulations to you?
Reduce waste? Reduce fly tipping? Increase recycling?
Regulations obligate the Client and Contractor
Only the contractor is actually regulated
Estimated that 30% of waste can be designed out
Why are the regulations focussed on construction phase?
10. Reduce waste? Reduce Fly tipping
LA enforcement should focus on CLIENTS
- Planning stage ensure
- Fully predictive SWMP LA enforcement should focus on SMALL
- Inclusive of design decisions to minimise waste
- Add as a planning condition
projects
- Defra announced fly-tipping had decreased by
Addresses waste at the top of the hierarchy 9.8% in 2008-2009
- Local Authorities costs were £54.9million
Few Clients embrace the spirit of the Regulations - Large projects with major contractors are less
and pass their obligations onto the Contractor likely to suffer from rogue waste activities
If waste reduction was paramount, Clients would Review Duty of Care controls and waste
challenge Designers
transfer notes not waste data.
Reduces the volume of waste that contractors
have to manage
Increase recycling VINCI Experience and Needs
LA enforcement should focus on
LARGE projects Only aware of one planned Environment Agency
visit and no Local Authority visits to date
Checking that the SWMP exists is not enough
- Increased waste generation
(Fixed Penalty Notice)
- More opportunities for effective recycling
- Informed officer visits
- Tie in with Contractors Halving Waste to
Landfill Commitments - Influence design
- Push the industry towards overall waste reduction
- Obligate client
Review waste data, are opportunities
for recycling considered?
Minimise waste to landfill
Where is the waste going to – have
- Increase recycling
opportunities been lost?
- LA need to support infrastructure developments
Conclusions
Are the Regulations working?
- Not as anticipated (threshold level)
- Missed a good opportunity to push Designers and Clients
- Little or no visible enforcement
Site Waste Management Plan Regulations 2008
The Enforcement and Supporting Environment
Can the regulations work?
- Yes! Large contractors are meeting requirements
- More Client involvement – they need to be regulated too!
Focus of visits
- Dependant on LAs goals (reduce, recycle, minimise fly-tipping)
- Interrogate data, challenge the Site Waste Manager/Project Manager
Global construction consultants
11. Enforcement Offences
Key Aim: Ensure that a compliant SWMP has been written and Fail to
implemented Make a SWMP
Keep at site & make available
Record waste disposals
Regulators Review 6 monthly where > £500k
Environment Agency Confirm & analyse within 3 months of completion
Local Authorities Keep for 2 years after completion
Produce upon request by LA/EA
Produce supporting evidence
Enforcement
Power for regulators to check SWMPs Obstruct or furnish false/misleading information
Defined types of offences
Schedules of Penalties Fail to comply with Duty of Care
Penalties
Fixed Penalty notice for failing to
produce SWMP
£300, to be paid within 14 days
On summary conviction How & who should enforce?
Fine up to £50,000
On conviction on indictment
Unlimited fine
Duty of Care at the core of SWMPs
Potential custodial sentences
How & who should enforce? When - Planning?
Add to existing local enforcement
strategies, e.g. additional tool for dealing
with fly-tipping?
Planning
reqs.
Or…separate SWMP agenda?
Partnership with the Environment Agency?
Outline Detailed Pre Construction Post
Design Design Construction Completion
12. When – Site Inspections?
How do I determine an offence?
Planning
SWMP inspection
reqs.
Outline Detailed Pre Construction Post
Design Design Construction Completion
How do I determine an offence? Recommended Initial Checks
Who should I be Is there a need for a SWMP?
asking? Is there a SWMP?
Are the key details correct?
What should I be
looking for? Are you speaking with the person
responsible for drafting the plan?
When should I be
looking?
Recommended Initial Checks Digging a little deeper…
Are there forecasted estimates of waste Have waste minimisation techniques been
type and quantity? employed during the design phase?
Is the plan a good description of the
activities on site? Can they explain how the plan has been
implemented, down to subcontractor level?
Is there documentary evidence of all waste
removed from site? E.g. waste carrier Can they explain how the site is managed
registration, waste transfer or hazardous to accommodate waste storage and
waste consignment notes? recovery?
Have the types and quantities of waste Are all tasks being recorded and updated
produced been reconciled against the on the SWMP?
estimates in the plan?
13. What action should I take?
Is the offence intentional?
Is penalty due? High profile cases?
What action should I take? Who do I penalise? Client or
contractor?
Should I liaise with the Environment
Agency?
Should I encourage good practice
through local support and signposts to
guidance?
Our aims - new corporate strategy
A better place for people & the environment
Site Waste Management Plans
Reduce Protect & Work with
Put people &
climate improve air, businesses &
communities at
change & its land & water public sector to
Kay Champion Iain Regan the heart of what
consequences quality we do use resources
Project Manager Principal Waste Officer
wisely
Be the best we can
Our interest in the Construction Sector Construction Sector - The “hidden” costs……
Consultee on land use planning
Regulator of licenses, exemptions, permits & consents All England & Dealt with •A fifth of all fly tipping incidents
Wales by EA are of construction and
Provide advice & guidance Proportion of fly- 7.1 28.5 demolition waste
Statutory duty for strategic water resources planning tipping incidents (%)
New environmental planning role: infrastructure gaps Estimated cost of 5,476,245 37,544 •A third of bigger and nastier fly
clearance (£) tips include construction,
As a construction client Estimated cost of 1,281,145 demolition and excavation waste
enforcement (£)
Estimated total fines 42,147 6802 •Removing fly tipped waste costs
(£)
the taxpayer almost £74 million
Our interest in SWMP Regulations 2007/08
We will only intervene where non-compliance is linked to an
incident such as fly tipping.
14. Site Waste Management Plans – A useful tool SWMP Campaign - NetRegs
Travis Perkins 2007/8:
Short-term:
160,000 leaflets to TP customers at road shows
Reduced environmental crime
Increased legal compliance 824 sign ups to email updates
Decrease in pollution risks & incidents
Manage waste better FMB survey Nov 2008:
51% unaware SWMPs are mandatory for projects > £300,000 in England
Longer term: 45% that used SWMPs reported money savings
Higher standards on site 25% that had used SWMPs say they have helped them to win new business.
Reduced environmental crime
Resource efficiency
Joint promotion with Envirowise & SW Regional Development Agency
Increased Corporate Social Responsibility
Increased awareness of benefits of good practice
Over 50,000 downloads of Simple Guide
Stabilised market for recycling and recovery sector Over 6,000 construction SMEs on email updates
Better trained workforce will skills for more sustainable construction
SMEnvironment survey 2009 South East Intervention Campaign
Low environmental awareness.
Confused where to go for advice
Compared to the other sectors Construction SMEs were:
least likely to introduce practical measures to prevent / reduce harm to the
Working with the Pathway to Zero Waste we
environment. aim to significantly reduce construction and
Of those 40% that had introduced practical measures, compared to the other
sectors they were:
demolition waste crime and by doing so
least likely to recycle their waste, 59% (20% less than Healthcare)
second least likely to reduced waste, 37%
stabilise the recycling and recovery markets.
least likely to have made energy efficiency or water reduction improvements, 19%
second least likely to have assessed their impact on the environment, 12% (agriculture 23%)
least likely to have carried out a programme of environmental improvements, 8% (agriculture
17%)
one of the most likely to have made someone responsible for environment, 10%
94% have internet access
An intelligence led approach to waste crime
South East Intervention Campaign
Proactive approach
Prioritisation – hitting the big bad and nasty for maximum effect
Problem Profile
Enables best utilisation of resource
Targets identified
Cradle to grave mapping - identifying the offender
Repeat & Known Offenders
Number of investigations and operations on-going
Geographical Hot spots
Variety of preventative measures Crime Types
Obtaining intelligence from a range of sources (can someone else take care of the problem?)
Intervention Strategy
Painting the picture – the size and scale of the problem – raise's profile and makes it a priority!
Prevention
Intelligence gathering and analysis Identifying what we know – don’t know – and want to know Intelligence
Identify why the crime is committed and where best to intervene for maximum effect… Enforcement
15. Waste Flow Mapping
The trial – Waste Flow Inspections
Tracking waste from cradle to grave / grave to cradle
Purpose to:
Prevent waste falling out of legal control
ensure producers describe their waste
accurately
improve awareness and compliance with duty
of care
Reduce the use of un-registered waste carriers
build intelligence on waste movements
increase presence on construction sites
increase risk of offenders being caught
identify and enforce against illegal activities
Construction sites - SWMP Audits SWMP Project - Inspection Pack
Guidance & forms needed to
help officers identify sites and
conduct inspections Understanding SWMP audits
Developed in consultation with Procedure for Preparing and
Conducting the Audit
local authorities, contractors Guidance for Completing the
and CIRIA , WRAP & others Audit Template
Being trialled in the South
East Best Practice Example
Available for use by local
authority staff in the South
East
Heading
Experiences of construction sites &
site waste management plans
16. Experience on construction sites & SWMPs Experience on construction sites & SWMPs
53 rejected load reports from one landfill since January level of understanding of duty of care legislation and
32 SWMP inspections SWMPs
waste segregation
ignorance on site of existence of SWMP
waste dispatch procedures
Mis-describing waste
SWMP not implemented by sub contractors / site
workers.
lack of information on SWMP
SWMP not updated
Key findings - 20 construction site audits:
Opportunities to work together
17 sites breached environmental legislation,
Low Sharing experience, research & information
7 breached the SWMP regulations level about the sector
4 had available & adequate waste transfer notes
5 of the sites had waste inadequate waste storage
Sharing lessons on what works best
3 had incomplete or inadequate duty of care Exchanging messages & contacts
documentation. Bringing our officers together
Duty of Care issues were identified on 17 of the sites: Joint literature & campaigns
Inadequate documentation:
Missing paperwork: Cross referral/ collaborative enforcement
Mis-description of waste was obvious on 4 sites Single point of contact / joint visits
High
No SWMP were available on site 3 of the 6 level
unannounced construction site visits.
SWMP quality was generally very poor.
Working Session 1 – Developing an Approach
30 mins
Discuss in groups
1 person presents back
Site Waste Management Plan Regulations 2008
Working Session – What is going to be your approach?
1. What can be done at the
Planning stage?
2. When and who can enforce
during the project timeline?
3. What is your influence as a
client?
4. What is the benefit case?
Global construction consultants
17. 1. Planning Stage 2. Enforcement during the project
When and who can enforce during the project timeline?
What can be done at the Planning Stage?
Think about….
Think about….
How to identify relevant projects?
How could planning influence site waste management on projects?
At what stage to intervene?
How do you identify projects at this stage?
Who would be best placed?
Outline Detailed Pre Construction Post
Design Design Construction Completion
What are you asking for and/or communicating?
What are you asking for?
How do you do it?
What are the benefits and obstacles to these options?
What are the benefits and obstacles? Need for a coordinated approach?
3. Influence as a Client 4. Benefits Case
What is your influence as a client? What is the benefit case for taking action?
Think about… Think about…
What type of projects are applicable? Whether your Local Authority has relevant sustainability or wider agendas
and/or objectives?
How can you influence a project? How are these delivered?
What would you do? How could the SWMP Regulations fit-in or enforce these agendas?
What would you ask for/communicate? Where do you focus?
How would you identify compliance and/or good practice? Are there benefits to a coordinated approach?
Working Session 2 – Making it happen Working Session 2 - Making it happen
30 mins Who can take Is training needed?
Discuss in groups ownership?
1 person presents back
Who needs to drive the
agenda forward?
Is training needed? What tools/resources are Who do you need to speak to
What tools/resources are required? (internal/external) ?
required?
Who do you need to speak to?