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Understanding the importance of soil waste classification and waste acceptance criteria for construction sites

(Pictured at a recent breakfast briefing on Article 27 to the Construction Industry Federation (CIF) are Malcolm Dowling (Verde) who presented a post-guidance appraisal of Article 27 (Is it still a realistic option?) and the alternatives for soil disposal or recovery. Also pictured is fellow presenter, Professor Yvonne Scannell from Arthur Cox and members of CIF (from l-r) James Benson, Executive, Construction Industry Federation, Eastern Region; Hubert Fitzpatrick, Director, Housing, Planning & Development, Construction Industry Federation; Tom Parlon, Director General, Construction Industry Federation)
As the rate of Construction increases, so does the need to undertake Soil Waste Classification on construction sites.

The EPA has recently (22 March 2018) released statistics for construction and demolition waste and whilst any such release is welcome, the usefulness of the information provided is somewhat reduced given that the statistics relate to 2014!

What we can say is that in 2014, 3,314 ktonnes of C&D waste were recovered or disposed of with soil & stones accounting for 74 per cent of the total quantity.

In 2018, it is fair to assume that the amount of soil and stone generated is far greater than that presented in the latest statistical release. Reflecting this and the continued prevalence of cranes on the skyline, we are seeing an increased demand for our soil waste classification service.

Site investigation, soil sampling and analysis are critical components of the development of any site. Accurate classification of soil waste is required to comply with Ireland’s waste management regulatory regime. Classification can, of course, have a significant impact on development costs as can waste characterisation using the Waste Acceptance Criteria, commonly known as WAC limits.

The gate fee for accepting a material is largely determined by its classification and there is a significant difference in material that is hazardous versus soil that is considered non-hazardous. There are additional options and less cost involved in managing inert soil waste. Issues arise where material fails the Inert WAC criteria and is considered suitable for acceptance at non-hazardous waste facilities. There are dwindling options currently available and it is fair to say that a capacity crisis is fast approaching.

Understanding the importance of soil waste classification and waste acceptance criteria

A crisis in terms of inert soil waste disposal options could also be on the cards. There are currently only two licensed inert waste landfills in the country. There are several licensed soil waste recovery facilities in the Greater Dublin Area but few elsewhere and of course we have a plethora of sites that are permitted or certified by local authorities.

In terms of the soil waste recovery facilities, however, draft guidance on the setting of soil trigger levels suggests that it will become much more difficult to find a home for non-hazardous, inert soil material. More stringent limits are being proposed for soil recovery facilities, moving away from reliance of WAC except for in the case of licensed inert landfill facilities. It will be interesting to see what the outcome of the consultation will be and of course, to see if similar control will be assigned to waste acceptance at permitted sites.

Additional capacity pressures could result from the failure to allow by-product status to clean/uncontaminated soil and stones. The opportunity to re-use soil and stone as a by-product is positive on many levels. By declaring by-product status on a material, the beneficial re-use of existing secondary resources is facilitated. Waste is minimised and natural resource consumption is less. Whilst there is a need to regulate the widescale movement of soil materials, in cases where imported materials are required for development, it should be possible to readily assign by-product status on material sourced from greenfield sites and those brownfield sites where natural soils are characterised and shown to be clean and uncontaminated or devoid of anthropogenic contamination.

Guidance published by the Agency in November 2017 highlights that the scope of acceptable Article 27 declarations is narrow in their view. Despite this, and perhaps cognisant of several legal challenges, the number of By-Product declarations has risen with 18 alone in March 2018 (the majority of which involved soil and stone).

Whether or not soil is declared a by-product, an analysis exercise should be undertaken to determine the nature of the material. Is the material clean and inert or lightly or heavily contaminated? Does it contain natural contamination? Has it been impacted by human activity?

Where it is determined that soil is a waste, then accurate classification of that material is of paramount importance before soil is moved off-site to an authorised destination.

Call in the Experts

Verde Environmental Consultants have a team of scientists and chemists with extensive experience in the soil waste classification process.  Our team help clients assess the composition of the material and determine the concentrations of the hazardous substances in the material, if present.

Our Approach

Our team carry out a phased approach to soil waste classification:

  • Investigation and Sampling – design investigation and sampling frequency
  • Analysis – laboratory testing for potential contaminants
  • Classification – determining the most appropriate List of Waste (LoW) code for the waste
  • Comparison – comparison of the analytical data with Waste Acceptance Criteria (WAC). Wastes can only be accepted at a landfill if they meet the WAC for that class of landfill.
  • Options – Depending on results, Verde can offer advice on various available options
FREE Licensed Soil Waste Facilities Map of Ireland

We have put together a map of all Licensed Soil Waste Facilities in Ireland, along with waste type accepted and costs per tonne.  This will be updated quarterly in our Newsletter.

If you would like to receive this very useful FREE resource, subscribe to our Quarterly Newsletter here.

FREE Soil Waste Classification Briefing

The requirements imposed by environmental regulations on businesses are expanding and there is a need for managers and staff to continue their professional development (CPD).

Verde have developed a range of FREE courses enabling progression through key disciplines including Soil Waste Classification and Waste Acceptance Criteria. In this FREE 40 minute briefing which we can give at your premises, you will learn the importance of the correct classification of soil waste, as the stringent regulatory waste management procedures in Ireland make it a statutory requirement for waste to be characterised & assessed to see if it meets specific Waste Acceptance Criteria (WAC) prior to disposal at a landfill site.

Soil Waste Classification CPD trainingKevin Cleary, Operations Director (1st from right) and Malcolm Dowling, Principal Environmental Consultant (2nd from right) of Verde Environmental Consultants providing FREE Professional CPD training on Soil Waste Classification and Waste Acceptance Criteria to staff at Cogent Associates Ireland in April 2018.

Sign up for your FREE Company Briefing here.