What is a Materials Management Plan and Why is it Needed?
CL:AIRE[1] is the Development Industry Code of Practice approach which allows materials to be moved and re-used on-site, and between sites, without being classified as a waste material and therefore not requiring EA regulation through issuing a permit or exemption and associated costs and complexities.
A Materials Management Plan (MMP) is a document detailing anticipated material movements (site-won, imported and exported) to enable the re-use of materials in earthworks materials movements to be undertaken without them being classified as waste or requiring additional Environmental Permit through the Environment Agency (EA).
An MMP can be used when adequately demonstrating the following:
- Environmental and geotechnical suitability for use;
- Certainty of use; and
- Required volume is no more than necessary.
The MMP is based on a geo-environment risk assessment background, including either a Remediation Strategy for sites with contamination, or a Design Statement if contamination has not been identified during ground investigation. Suitable materials can be imported from one or more donor sites (known as ‘direct transfer’), as long as a requirement can be shown.
How are MMPs completed?
A standard CL:AIRE template can be used to detail the requirements of the MMP, including the following for each site:
- Details of the parties that will be involved with the implementation of the MMP;
- A description of the various materials in terms of potential use and relative quantities of each;
- The specification for use of materials against which proposed materials will be assessed, underpinned by an appropriate risk assessment related to the place where they are to be used;
- Details of where and, if appropriate, how these materials will be stored;
- Details of the intended final destination and use of these materials;
- Details of how these materials are to be tracked;
- Contingency arrangements that must be put in place prior to movement of these materials;
The ultimate responsibility for ensuring paperwork is correct for materials movements and that materials movements are undertaken in accordance with the appropriate permissions and plans must sit with the Principal Contractor.
The person commissioning the excavation works is responsible for complying with the DoWCoP.
It is incumbent on all other persons employed in the project/scheme to ensure the requirements of the CoP are met. Therefore, the whole project team must understand the requirements of the CoP.
How long does an MMP take to produce?
We would suggest allowing at least 5 weeks to complete an MMP as generally the regulators need 4 weeks to provide a response to a written request for agreement in principle to the proposed approach.
How are MMPs Regulated?
To ensure that the above steps have been taken, a CL:AIRE Qualified Person must review the relevant documents and provide a Declaration to the EA (via CL:AIRE) in accordance with the Definition of Waste Code of Practice (CoP) prior to the use of materials. When the Declaration is provided to the EA demonstrating that the materials are to be dealt with in accordance with the MMP, the EA will take the view that the materials are not waste as long as they are used in accordance with the CoP.
The ‘Qualified Person’ must review the relevant documents and provide a Declaration to the EA prior to use of the materials. The person who prepared the MMP cannot be the one who will sign it off and submit the declaration as the Qualified Person – that must be someone not involved in the project but can be from the same company.
Fees
In addition to fees for producing the MMP and for the QP declaration, there will be fees to pay related to the volume of the material moved and these would be payable by the Client/Contractor and so a separate purchase order number will be requested when we complete an MMP.
Next Steps – Verification
During earthworks, appropriate records of materials movements need to be maintained and regular site visits may occur.
Verification activities will comprise the record keeping of what was excavated, where it was excavated from and where it was placed, using details from the main contractor.
On completion of the works, a Verification Report must be produced at the end of the works to confirm the material and volumes were as set out in the MMP and submitted.
For more information, email info@geostreamuk.com