Environment Bill

Written Evidence submitted by Camfaud Concrete Pumps Ltd (EB69)

Environment Bill 2019-2021

1. About Camfaud

1.1 Camfaud Concrete Pumps Ltd (‘ Camfaud ’) is the largest nationwide mobile concrete pump provider in the UK .

1.2 The principal activity of the company is to provide concrete pump equipment, supplying mobile concrete pumps, static pumps, stationary placing booms and other concrete pumping accessories to the UK construction industry .

1.3 Camfaud currently operates from its Head Office in Epping, Essex and has key operational centers across the UK, in cluding South West ( Fareham ), North (St Helens) and Scotland ( Airdr i e ) .

1.4 Camfaud is involved in many key infrastructure projects across the UK. Recent examples include CrossRail , Hinkley Point Power Station and HS2.

1.5 Camfaud is committed to health and safety in the industry and recognizes its role to support environmental change.

1.6 Camfaud also o perate s the largest concrete pump training and testing school in the UK. It is an approved centre under the CITB S kills Awards and more than 300 individual operators have been trained in the last 10 years.

1.7 Camfaud is a member of the CPCS (Construction Plant Competence Scheme) and the company is a member of the Construction Plant-hire Association (CPA) as well as an active member of its Concrete Pumping Interest Group.

2. Executive summary

2.1 Camfaud welcomes the proposed Environment Bill 2019-2021 and supports the overall targets, plans and policies of improving the natural environment.

2.2 Camfaud particularly supports the proposed legislation outlined in Chapter 3, Part 3 ‘Waste and Resource Efficiency’.

2.3 Camfaud would urge the committee to specifically outline legislation that references the specific treatment, control and environmentally responsible disposal of concrete waste (including cementitious materials) and concrete washout.

2.4 While this subject is covered in various best practice approaches from key organisations such as the Environment Agency (EA), Camfaud consider the Environment Bill 2019-2021 as an opportunity to address some of the challenges that remain around the impact of concrete waste and concrete washout.

2.5 The legislation is also an opportunity to address existing fragmented guidelines and overall enforcement around appropriate treatment concrete waste and concrete washout.

2.6 However, Camfaud consider the fragmented guidelines and interpretation to be connected to the existing definition of concrete waste and concrete washout as potentially a nonhazardous waste.

3. Concrete washout water

3.1 Under the Environmental Permitting (England and Wales) Regulations 2010 (as amended in 2012) and the Water Resources Act 1991 (as amended), it is on offence to discharge polluting substances to controlled waters (surface water and groundwater) without prior approval from the Regulators (Environment Agency (EA) England or National Resources Wales (NRW).

3.2 The risks and adverse impact of inappropriate treatment of concrete waste and concrete washout can be summarized as the water is highly alkaline due to the presence of calcium hydroxide.

3.3 It typically has a pH value of between 11 and 13.6. At this level of alkalinity, even small quantities represent a serious risk to the environment. It is illegal to discharge untreated water into the sewers or allow it to drain away on site.

4. Recent cases/examples of adverse impact caused by untreated concrete waste and concrete wash water

Concrete Waste - London Sewer

4.1 A recent example (2019) of the damage caused by inappropriate treatment and disposal of waste concrete can be seen in a London sewer which was blocked by a 330ft-long (100m) ‘concrete berg’ which weighed 105 tonnes.

Source: https://www.bbc.co.uk/news/uk-england-london-47976904

Washwater - Harron Homes

4.2 Harron Homes repeatedly failed to control the silt run-off on site and samples taken by the Environment Agency showed there to be nearly 35,000 milligrams of suspended solids per litre of water, whereas a healthy watercourse is expected to have a concentration lower than 30 milligrams per litre.

4.3 Speaking at the time, Mark West, environment management team leader at the Environment Agency, said:

"These pollution incidents had a significant impact on the water environment over a number of weeks and were entirely avoidable. In West Yorkshire there has been a worrying increase in the number of pollutions incidents reported to us that on investigation are attributable to the construction sector."

"Construction companies should consider the potential environmental impact of developments they undertake at the initial planning stage and must adhere to environmental permitting rules and invest in appropriate management systems to prevent their activities from affecting the local environment."

Source: http://watery-news.co.uk/harron-homes-fined-120000-construction-pollution/

5. Proposed Amendments

Concrete washing and disposal service to be required by law

5.1 One key objective of the bill is to:

"Provide the legislative framework needed to deliver on many of the commitments in the Resources and Waste Strategy, by introducing new powers and amending existing legislation such as the Environment Act 1995 and Environmental Protection Act 1990."

5.2 Camfaud proposes that in order to deliver on this commitment that the legislation specifically defines concrete waste and concrete washout as a ‘hazardous waste’ as set out under the definition of the ‘waste list’ set out in Annex II to the Hazardous Waste Directive in the Hazardous Waste (England and Wales) Regulations 2005, and as under the Environment Protection Act.

5.3 Camfaud recommends that concrete waste and concrete washout are specifically defined under the bill and supporting legislation as a material or substance which is a hazardous waste.

5.4 Contractors who produce or handle hazardous concrete waste continue to have a responsibility as a ‘duty of care’ and Corporate Social Responsibility but under the bill and proposed legislation will also have a legal obligation.

5.5 We propose an amendment to the bill and supporting legislation which will require any contractor to effectively manage concrete waste and concrete wash water.

5.6 These amendments would provide scope for procedures, policies and plans for the containment and disposal of concrete waste and the containment and disposal of concrete wash water to be set within the construction.

5.7 Designated washout facilities would be need to be identified and made available on-site, and the effective treatment and safe removal of concrete waste and concrete washout from construction sites would be a requirement for all contractors across the UK.

6. Proposed amendments

(i) Environmental Bill Part 3 – Waste and resource efficiency (Clause 57 62ZA 2B)

‘for the giving of directions by waste regulation authorities with respect to matters connected with any activity in relation to hazardous waste; including the defining of hazardous waste;

(ii) Environmental Bill Part 3 – Waste and resource efficiency ( Clause 57 62ZA 2C)

‘imposing requirements about how hazardous waste may be kept (including requirements about the quantities of hazardous waste which may be kept at any place, and a plan and schedule for safe disposal of hazardous waste ) ;’

September 2020