Supplementary memorandum by Balfour Beatty
and Ciria
1. INTRODUCTION
CIRIA is the leading provider of best-practice
and performance improvement guidance for the UK construction industry.
We bring together stakeholders from across the sector, including
clients, contractors and representatives from all parts of the
modern build environment supply chain, covering building and civil
engineering as well as transport and utilities infrastructure.
As a member-based organisation, we invited members to provide
comment for our submission, and invited Martin Brock, Quality
and Environmental Manager, of Balfour Beatty Civil Engineering
Limited (BBCEL) to represent CIRIA.
Martin is a well-respected industry figure and
has nearly 20 years experience in environmental management, working
as both an enforcer of legislation and as an advisor to industry.
For the last 11 years, he has specialised in the civil engineering
sector, working particularly on major infrastructure schemes such
as the Channel Tunnel Rail Link, M6 Toll, M25 widening and upgrading
of Kings Cross station.
BBCEL is a core member of CIRIA, and Martin
is a member of CIRIA's Environment Advisory Panel. This panel
contains industry clients, suppliers—from both design and
construction organisations and researchers drawn from CIRIA's
500 member organisations. Martin is also the Chairman of the Construction
Confederation's Environmental Forum. Through its constituent member
organisations, the Construction Confederation represents over
4000 individual companies, accounting for 75% of the UK's turnover.
The Environmental Forum meets quarterly and provides a voice for
the industry as well as a vehicle for sharing good practice and
lessons learned.
As, due to transport difficulties, Martin was
not able to attend the Waste Reduction Meeting, this written submission
is provided. The answers below are based upon Martin's extensive
experience as noted above. It also includes, where appropriate,
views from other CIRIA Members.
CIRIA sees the key issues for reducing construction
waste as being:
— Minimising waste to begin with (through
better design, involving contractors in design phase, design for
deconstruction etc).
— Encouraging good waste management
on site (through education, demonstrating how it can be done,
and practicing good waste management consistently).
— Recognising the potential for re-use
or recycling of materials (ensuring education, markets, ease of
transfer and re-use).
— Ensuring that the regulatory and
financial framework encourages reuse and recycling (via appropriate
incentivising, taxing and enforcement, as well as via government
procurement).
CIRIA is involved in a range of knowledge-transfer
activities that support these aims through guidance, training,
events etc.
2. ANSWERS TO
THE QUESTIONS
2.1 What are the primary waste streams in
the construction industry and where do these arise? What proportion
is primary high value waste compared to secondary low value waste
such as packaging?
Members feel that Defra should hold this information.
If it is not already readily available (via sources such as BRE),
we suggest it should be held centrally and available on request.
The primary waste streams arising from civil engineering
schemes (in terms of volume) are:
— Excavated soils—if they cannot
be used on site. These soils could be either inert or contaminated.
— Demolition wastes such as: concrete,
bricks, hardcore, steel, aluminium, wood and cabling.
It should be noted that on civil engineering
projects, very little waste is sent off site in skips. BBCEL's
experience is that this is typically less than 4% of the total
waste removed from the site, the majority being inert soils or
material that is excess to the scheme's requirements.
2.2 Aggregates are often compounds of a variety
of wastes. Are there technical limits as to the quantity and type
of waste material that could be re-used in this way?
There are clearly technical limits on both quantity
and types of material that can be re-used as aggregates. However,
the limits are variable and very much site dependent, according
to influences such as:
— The type of aggregates contained
in the mixture. Typically aggregates with a high concrete content
produce a high-value product and those with a higher hard core
content, produce a lower value material.
— The ability of the site to segregate
and sort the waste to maximise its value. In addition to the technology
and skill required to undertake this activity, projects also need
to consider the following:
— Legislative hurdles in terms of Waste
Management law.
— Space required to carry out the operation
and store both raw materials and recycled products.
— Quality control and testing regimes.
— Logistics and double handling costs.
— The location of good quality waste
materials. Recycled aggregates are a relatively low value product
and as a result their costs are significantly influenced by haulage.
If re-use and recycling schemes are to be commercially viable,
the haulage distances need to be comparable with those for the
virgin aggregate alternatives. Otherwise, the additional costs
of equipment, personnel and land required to run a recycling operation
together with the extra haulage distances would exceed the cost
of an equivalent virgin material.
In BBCEL's experience, the generation and use
of recycled aggregates from waste materials can work, especially
on big projects and it can have significant results. For example:
— The M1 Junction 6A-10 motorway widening
project is a £298 million scheme that is due for completion
in December 2008. Nearly 1 million tonnes of aggregate were required
for the earthworks and concrete structures. To date over 90% (900,000
Tonnes) have been sourced from recycled materials: Roughly this
has been through:
— 500,000 tonnes of demolition waste
imported and treated on site to produce compliant aggregates.
— 250,000 tonnes of material recovered
from the project and treated on site for re-use.
— 150,000 tonnes of recycled aggregates
purchased from the open market.
— There as also been 1.1 million cubic
metres of soils that have been moved around the project as part
of the cut-fill balance and to achieve the scheme's landscaping
requirements.
2.3 What research is being undertaken into
the different waste stream within the construction industry?
A great deal of diverse research is being undertaken
into different waste streams within the industry. Support organisations
such as BRE, CIRIA, WRAP and TRL are all undertaking research
to support and promote certain wastes being used by the construction
industry. For example the work undertaken by WRAP on developing
Quality Protocols and Guidance Notes to supplement standards has
been particularly useful to this industry. CIRIA works with industry
to ensure such research is disseminated.
A number of the major contractors in the industry
are also conducting their own research to try and find innovative
uses for all manner of materials.
2.4 The Building Research Establishment has
developed a series of environmental assessment methods, known
as BREEAM. What do these assessments involve, how are they applied
and do they include waste reduction indicators?
The assessment methods of BREEAM were ably described
by Gilli Hobbs of BRE. The BREEAM programme applies to buildings.
However, from a Civil Engineering perspective,
the CEEQUAL (Civil Engineering Environmental Quality and Assessment
Scheme) Scheme performs a similar role for infrastructure projects.
CEEQUAL provides a points-based scheme for assessment
of environmental quality. It includes waste management within
the criteria. Further information is available on the scheme website:
www.ceequal.com.
2.5 The Building Research Establishment has
commented that current assessments of life-cycle impacts do not
effectively reconcile the needs of different environmental drivers
such as waste reduction and carbon reduction. How can the weightings
of different environmental aspects affect the output of a life-cycle
assessment and how might that affect the design and construction
of a building?
The weightings of different environmental aspects
can significantly affect the output of a life-cycle assessment.
Life cycle assessment (LCA) can be a useful tool in identifying,
and selecting from, the design and construction options for a
building (or, indeed, any other type of built asset). This is
a complex issue, and CIRIA believes this warrants further research.
2.6 We have heard that once the "waste"
label is applied to materials, this can often hinder their re-use.
Which valuable materials in the construction industry do you think
could be re-used and recycled more effectively and does the definition
of waste limit these activities?
Responses from CIRIA's members indicate that
the legal definition of waste is perceived in the industry as
hindering re-use. This is particularly so when the producer knows
the material has value, but cannot find a practical use at that
point in time, and so must "discard" it.
A good example of "waste" that could
be reused is Pulverised Fuel Ash (PFA). PFA is a by-product of
coal fired power stations and can be used by the construction
industry as an additive to concrete to enhance its chemical and
physical properties, and also as a light weight fill material.
Having provided this example, my experience
is that the legal complexity of the waste regulatory regime is
more to blame for materials being labelled waste. There are three
reasons for this:
— It is too easy for construction materials
to be unnecessarily classed as waste, when in reality they are
stocks of materials that have yet to be processed or allocated
a new purpose.
— The waste regime is too complex and
will often steer contractors towards a solution that utilises
virgin materials rather than complete the necessary paperwork
and wait for the Environment Agency to respond.
— Advice and guidance on what constitutes
waste is ambiguous and leads to variations in approach.
— For smaller contractors, or smaller
sites, storage of materials and lack of opportunities for re-use
on site, combined with difficulties in re-using elsewhere, can
prohibit re-use. The lack of materials recycling facilities (MRFs)
and distances from/between sites can also be a barrier. Consolidation
centres for re-useable materials could assist in this regard.
2.7 Has the landfill tax acted as an incentive
to reduce waste within the construction industry?
The landfill tax has been an incentive but should
not be considered as the only one. The aggregates levy plus the
high cost of tipping waste at commercial landfill sites have also
encouraged contractors to consider recycling opportunities.
To some extent the change in the waste management
licensing regime has exacerbated this situation by greatly reducing
the number of operating landfill sites. This has resulted in fewer
sites, higher gate prices and greater haulage distances.
2.8 Have Site Waste Management Plans (SWMPs),
which have previously been voluntary, been successful at reducing
waste? Do you think that making SWMPs mandatory will have much
effect on waste reduction?
The Regulator has not, to our knowledge, done
a great deal of research into this. We hope that research to quantify
the impact SWMPs have on reducing waste will be conducted now
the new SWMP Regulations are in place so as to demonstrate efficacy.
The Regulations set out how mandatory SWMPs
will be enforced. However, there are concerns about whether resources
are available to rigorously enforce them in practice.
Responses from CIRIA's members indicate that
the administrative burden (or perceived administrative burden)
is thought to be an issue for smaller organisations.
In this industry, the arguments for promoting
waste reduction and recycling can only be won using commercial
drivers.
2.9 Since 1 May, all new homes have to be
rated against the Code for Sustainable Homes which measures their
sustainability against nine categories of sustainable design,
one of which is waste. Do you think that enough weight is given
to the waste category in the overall assessment and how accurate
do you think these assessments will be at indicating the true
sustainability of a project?
We have no comment on whether enough weighting
is given to the waste category. However, CIRIA suggests that the
setting, and monitoring of progress towards, targets is a key
process in sector step-change toward sustainability.
It has been suggested that the revision of the
Building Regulations could incorporate parts of the Code for Sustainable
Homes.
2.10 Defra, through its Market Transformation
Programme, has created a product roadmap for plasterboard, resulting
in the setting of targets to increase the recycling of plasterboard
waste. To what extent was industry involved in this process and
do you view the project as a success?
Consultation with industry is vital to ensuring
both practical targets and industry buy-in. CIRIA would welcome
the opportunity to further engage with Defra or other regulators
on behalf of our members in future.
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