Your Materials Management Plan is in Place – What Next?

What is a Materials Management Plan?

A Materials Management Plan (MMP) can allow the re-use of contaminated or uncontaminated soil, Made Ground and other material in earthworks without the requirement to go through the lengthy and costly process of obtaining an environmental permit. The CL:AIRE Definition of Waste Code of Practice (DoWCoP) was developed to provide a simplified process to enable the re-use of site-won materials (‘waste’ and non-waste), either on the site of origin, or on another nominated site without the need for an Environmental Permit.Once your Material Management Plan is in place, the next step is ensuring soils are tracked, recorded, and verified correctly so your project remains compliant and avoids unnecessary delays or regulatory issues.

Managing Soils On-Site

Once you have the Materials Management Plan in place, it’s easy to think of it as just a bit of paperwork that can sit in the drawer or filed away on-site. That is not the case, and the methodology for tracking and managing soils on-site needs to be followed. Due to the implications of not correctly managing soils, we are finding more and more that people seem to be so scared of doing it wrong, that they don’t want to try to do it right in first in place!

Hopefully through this blog post, we can dispel some on the common fears and demonstrate how managing and tracking soils on-site can be easy.

Regardless of the complexity of your soil re-use, the principles of managing the soils remains the same.

Plan

As well as having your Materials Management Plan in place to demonstrate that soils are suitable to be re-used on-site, it is important to also have a plan on how you are going to track these soils.

One of the most effective methods of tracking soils is to implement a grid-based system across the site. The grid squares can be as large or small as they need to be depending on the complexity of your site.

For example, if it’s really important that soils from 1 corner of the site are only re-used in another small area, it would be better to have smaller grid squares. Whereas if you are only re-using clean materials, and they can be used anywhere on the site, it would be practical to have larger grid squares that represented close to the amount of soils that could be moved per day.

Once you have your grid system decided, you will also need to set up a tracking form to record where materials have arisen from, where they are stockpiled, and where they end up. You can also use this form to record any required testing, import tickets and disposal tickets.

Track

The purpose of the tracking form is to clearly demonstrate where materials have come from, and where they have been placed. To ensure your soils are tracked the whole way through a project, it is key to decide who is going to be responsible for completing the tracking form. This ensures it doesn’t just fall through the cracks with everyone assuming someone else will pick it up.

Drone Surveys/Photographs

Using Drone surveys on-site is becoming more and more popular and is a great way of recording what is happening on-site at a given time. When you compare weekly drone photographs of the site, it is easy to see how things have evolved on-site over time. You can use these images to document your stockpiles and soil re-use, by annotating them and linking them back to the tracking form.

Recording movements on-site doesn’t have to be as high-tech as using a drone though. You might have weekly site meetings where you print out a large drawing of the site and draw on where your stockpiles are, what areas are completed, where soils are due to be cut etc. This method is just as effective, you just need to keep a record!

They key with whatever method of tracking you use, is that it needs to be simple, and a small addition to the works the developers are already doing. It is very likely that they are already recording the information needed for managing soil reuse under an MMP.

Audit

Throughout the soil movement phase of works, it can be helpful to have a 3^rd party (such as Omnia) review your records to advise on the information that is being recorded, and to also offer guidance and advice of any problems that may have arisen.

It can be helpful to start the process with a pre-start meeting to discuss the requirements with all parties who will be involved on-site, and come up with the most appropriate tracking system for your site.

Verification & Reporting

Once all the soil movements are complete, you will need to “close out” the MMP with CL:AIRE, which can only be done by submitting a Verification Report.

The CL:AIRE Definition of Waste Code of Practice (DoWCoP) sets out the following will be needed within a Verification Report:

1. Appropriate site plans;
2. Experience and qualifications of the person preparing the report in relation to the specific project;
3. Description of the project;
4. Description of how the use of materials links with the Remediation Strategy or Design Statement (which should be set out in the agreed MMP already);
5. Reference to site investigation data if applicable (which should be set out in the agreed MMP already);
6. Reference to risk assessments (including qualitative risk assessments) (which should be set out in the agreed MMP already);
7. Reference to the MMP and associated tracking system, including alterations made and why;
8. Suitable for use criteria;
9. Treatment records (if applicable);
10. Laboratory analysis (if applicable);
11. Reference to waste transfer documentation, including return loads (if applicable);
12. Signed delivery tickets (if applicable);
13. Record of contingency arrangement(s) that had to be implemented;
14. Record of quantity of materials used (this can be calculated using a pre start and post completion topographic survey); and
15. Copies of signed Declaration(s) by Qualified Person(s).

If you do not submit a Verification Report for your MMP, the project could be considered “non-Compliant” and the imported/excavated/reused material could potentially be considered as an illegal deposit. CL:AIRE may share such data with the EA / NRW and HMRC.

If you have a site that might require an MMP or an MMP Verification, get in touch with our team to discuss, we are always happy to help.