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Site Waste Management Plans Now Needed for Landfill Development and Restoration Projects

Although the following topic is not directly a landfill CQA issue we thought that it would be of real interest to many of our readers.

Compulsory site waste management plans (SWMPs) for construction projects over £300,000 in value, have been a legal requirement in England since April 2008, and are therefore needed for landfill works contracts. The intention is that the plans will forecast all waste produced on site and how much will be recovered or disposed of.

The SWMP should help businesses manage construction waste as part of a project rather than an afterthought. By planning for construction waste much earlier than has been the practice it should be possible to do much better in managing construction waste. Early experience that has been reported has suggested that in building projects it has been possible to achieve substantial savings which exceed the costs of producing and updating the site waste management plan.

A landfill site lining development or surface restoration project is undeniably a construction project, and almost all will exceed the threshold cost. Therefore, each project will need a site waste management plan, which starts with the designer and becomes the responsibility of the principal contractors on commencement of the work on site.

The regulations set out a range of offences relating to the failure to produce or implement a plan, punishable by a fine of up to £50,000 on summary conviction, or an unlimited fine on conviction on indictment.

On these landfill projects there will be little if any construction waste produced at all, apart from possibly some spoilt or unsuitable material, and the usual site facilities wastes. As ever, these otherwise laudable regulations make little sense in some applications, and in landfill in our view, we have such an example.

So how does a landfill contractor set about writing his site waste management plan after being awarded the contract and receiving the client’s design stage plan, for a landfill project?

What should the SWMP contain?

According to NetRegs, the level of detail that your SWMP should contain depends on the estimated build cost, excluding VAT. Their summary suggests the following:-

For projects estimated at between £300,000 and £500,000 (excluding VAT) the SWMP should contain details of the:

  • types of waste removed from the site
  • identity of the person who removed the waste
  • site that the waste is taken to.

For projects estimated at over £500,000 (excluding VAT) the SWMP should contain details of the:

  • types of waste removed from the site
  • identity of the person who removed the waste and their waste carrier registration number
  • a description of the waste
  • site that the waste was taken to
  • environmental permit or exemption held by the site where the material is taken.

At the end of the project, you must review the plan and record the reasons for any differences between the plan and what actually happened.

The contractor, or anyone else exporting waste from the site must still comply with the duty of care for waste.  However, because it will now be necessary to record all waste movements in one document, having a SWMP will help the site contractor’s management to ensure they comply with the duty of care.

For help in preparing your SWMP see the video on the Site Waste Management Plan hub page, or  Landfill Site Waste Management Plan page.

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