So, your site development requires a cut and fill operation, or maybe you’ve got to dig out a basement on your site (i.e. needs a cut) but another site down the road needs raising for flood levels (i.e. needs a fill) and so combining the two issues would surely help everyone. So can you do just that - cut and fill it? Here’s where a materials management plan can help…
What is a Materials Management Plan?
Materials Management Plans (MMPs) are often produced as part of a Site Waste Management Plan (SWMP) in order to reduce the quantity of waste material which needs to be disposed of. In other words, if you can prove you can re-use it on the site you don’t need to pay for the its disposal.
MMPs allow the re-use of material at a site which does not fulfil the legislative test of a ‘waste’. This area of regulation can prove murky due to there currently being a number of factors relating to waste management legislation but none specifically related to materials management. Under European law, any soils dug up on a contaminated site or clean soils imported from another construction site are classified as waste and therefore should be regulated. A materials management plan helps ease this burden by reducing the need for waste management and disposal.
What is required?
In order to determine if your excess material is waste or not the MMP will make you consider four factors:
- Protection of human health and the environment (this will be site specific – will it cause an issue where it’s intended to go?)
- Suitability of the material for use (both the chemical and geotechnical properties for the intended use)
- Certainty of use (are you really going to use it or is it just being stockpiled for now, in which case it would be classed as waste)
- Quantity of material (you should only ever excavate what you need; don’t make a hill in your second site just because you have all this excess material, because the excess will be classed waste).
Utilising materials management plans is helpful because they reduce land-filling costs which is only ever going to help your budget. They also enhance your sustainability credentials by reducing vehicle movements (trips to the suitable landfill) and the unnecessary use of virgin materials. Significantly, the cost and time implications of arranging an Environmental Permit can be vastly reduced if materials management plans are deemed appropriate for a site. Because the materials management plan forms a self-regulating, auditable system, it helps to reduce time submitting work to regulatory review as is the norm in many other areas of waste management.
How is it done?
The materials management plan is an incredibly flexible method and can be applied to developments with very simple requirements such as just moving material within a site as well as complex ones where material requires moving from one site to another for treatment and then back again. There are generally three ways in which the MMP can be implemented: A Site of Origin scenario, Direct Transfer (for clean natural materials only) or a Cluster Project.
- The Site of Origin Scenario has the broadest range of acceptable types of materials. Under this scenario, soils can be treated on site under an Environmental Permit although if treatment is required, some processes will require a Waste Exemption.
- The Direct Transfer method is suitable for use without permits by transferring from a greenfield site to either another greenfield or a brownfield, although naturally reciprocation from brownfield to greenfield is not possible. When considering brownfield to brownfield transfers, at least one of the sites must have a permit whether treatment is required or not.
- A cluster project takes materials from numerous sites to one central hub site although this can lead to potential for a wider variety of unforeseen issues, though if used correctly can be an exceptionally successful method.
How can we help?
Here at EPS, we can run you through the feasibility of a materials management plan for your site(s), prepare it and then have it declared by a Qualified Person. We know that every site is different and that your needs are unique so it’s important to have a two way conversation. If you’d like more information on materials management we recommend you speak to Marcus – he’s our in-house guru on this topic.