Deconstructing the DoWCoP

The introduction of the CL:AIRE Definition of Waste Code of Practice (DoWCoP) for the development industry heralded a pragmatic approach to handling excavated materials from construction sites.

For developers, it represents a cost-effective alternative to waste handling, whilst for the environment it limits the amount of material unnecessarily going to landfill. In this article, we look at how the DoWCoP works and why it is essential to have the involvement of Qualified Person (QP).

Under the current EU Waste Framework Directive, any site-won materials would be categorised as waste; whether it was suitable for reuse or not. Unless, that is, you obtained an exemption from the Environment Agency. This wasn’t always the easiest of processes, so a lot of useful materials ended up in landfill and developers were faced with additional costs for shipping and disposal.

The introduction of the DoWCoP enables the development community to assess materials independently of the Environment Agency and can eliminate the need for an environmental permit or a waste exemption license. This provides a range of immediate benefits, not least of which is the potential for significant cost savings and less environmental impact.

Whilst adherence to the DoWCoP is voluntary, there is the need for oversight to ensure compliance with the published standards. Developers are required to produce a Materials Management Plan and a Remedial Method Statement, which is subject to review by a Qualified Person. (Only QPs are authorised to sign-off on DoWCoP project declarations. A register of QPs can be found on the CL:AIRE website).

When it comes to establishing the suitability of site-won materials for reuse, there are four key criteria that should be considered as a part of the Materials Management Plan. First up, protection of human health and the environment. This ensures that the principals of the Waste Framework Directive are not undermined by creating unacceptable levels of risk to people and places.

Second is the suitability of materials for use. Any materials must be fit for purpose in term of their chemical and geotechnical properties – whether in their “raw” reclaimed state or following remediation. Third is the certainty of use – usually a requirement of the development proposal and approved as a part of the planning process.

And finally; quantity of material. The volume of excavated material allocated for reuse on-site must not exceed that which is required for the specific purpose. Basically, excessive reuse of site-won materials may be regarded as waste dumping.

The role of the Qualified Person is essential in the development process, as they will be responsible for assessing a range of critical documentation; including the site investigation report, remedial method statement and materials management plan.

Once they are satisfied, the QP will sign off on project declarations as relate to site of origin, direct transfers or cluster projects. These declarations are submitted to CL:AIRE, which administers the scheme on behalf of the Environment Agency.The duties of the QP do not end with the declaration. They have an ongoing responsibility to ensure compliance with the Code of Practice and will be instrumental in the production of the verification report, once the project is completed.

The duties of the QP do not end with the declaration. They have an ongoing responsibility to ensure compliance with the Code of Practice and will be instrumental in the production of the verification report, once the project is completed.With the increased emphasis on brownfield development sites, the accurate classification of waste materials has become even more important. Inaccurate classification can have a significant impact on both development budgets and timescales.

With the increased emphasis on brownfield development sites, the accurate classification of waste materials has become even more important. Inaccurate classification can have a significant impact on both development budgets and timescales.
For your next project, make sure you engage with a geotechnical consultant early in the process and make the most of your site-won materials.

Russell ThompsonAbout the author:

A Chartered Geologist with 25 years’ experience in the construction industry, Russell Thompson heads CET’s East Midlands consultancy. A Qualified Person under the CL:AIRE Code of Practice, he provides QP services in addition to site investigations, remedial method statements and materials management planning. The QP service is also available to consulting engineers and remediation and earthworks contractors.

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