TESTING SERVICES & EQUIPMENT
Harriet Coles, a specialist in environmental safety compliance for the rail industry, here explains the importance of Construction Environmental Management Plans for major projects.
T In
oday, managing and improving environmental performance has
become a recognised cornerstone of effective organisational practice. In fact, the ISO 14000 standards that cover environmental management celebrate their crystal (15th) anniversary this year.
many cases, translating those environmental management standards into policies and practices for large- scale projects uses a Construction Environmental Management Plan (CEMP). This often lengthy document demonstrates how the project will meet legislative requirements and address the specific practical challenges arising.
From the outset, rail-related projects face a number of challenges, not least due to the distances and variety of environments involved. It is likely that there will be a number of key stakeholders, whose own environmental policies will need to be taken into account as part of creating the CEMP. Typically this may include more than one local authority, local residents and environmental groups, the client, their partners and contractors.
Therefore, a CEMP should cover: the works planned and how they will be delivered (in clear detail); how the works will comply with regulatory and planning
Relevant primary legislation • Ancient Monuments and Archaeological Areas Act 1979 • Control of Pollution Act 1974 • Wildlife and Countryside Act 1981 • National Heritage Act 1983 • Environmental Protection Act 1990 • Town and Country Planning Act 1990 • Water Resources Act 1991 • Water Industry Act 1991 • Clean Air Act 1993 • Environment Act 1995 • Pollution Prevention and Control Act 1999
Relevant secondary legislation • Controlled Waste (Registration of Carriers and Seizure Vehicles) Regulations 1991
• Controlled Waste Regulations 1992 (as amended in 1993)
• Conservation (Natural Habitats) Regulations 1994 • Waste Management Licensing (Amendment) Regulations 1995 • Hedgerows Regulations 1997 • Control of Pollution (Oil Storage) (England) Regulations 2001
• Control of Noise (Code of Practice for Construction and Open Sites) Order 2002
• Control of Substances Hazardous to Health Regulations 2002
• Hazardous Waste (England and Wales) Regulations 2005
• Site Waste Management Plans Regulations 2008 • Waste (England and Wales) Regulations 2011 • Environmental Permitting (England and Wales) Regulations 2010
• Clean Neighbours and Environment Act 2005 • Environmental Noise (England) Regulations 2006
requirements; the environmental risks
identified and how they will be minimised; the proposed environmental management framework; the planned control measures and procedures; and how the works will meet stakeholder environmental commitments and policies, both during and after the project.
Each section of the CEMP needs to provide sufficient detail to ensure that little is left to chance:
Just as there is much legislation to consider, so it is likely that there will be many environmental risks to take into account throughout the project. Those responsible for drafting the CEMP will need to determine what these risks are and how they will be mitigated. The lists below give some idea of the risks we have typically encountered in rail projects:
Planning and design phases
• Whether any contaminated land is involved and if so, its extent and the risk it poses to human health and controlled waters; • The baseline noise levels (as well as those for vibration, dust and air quality), in order to ensure that the works do not exceed agreed tolerance levels either during the project or after its completion; • The current ecology, including whether any invasive plant species are present. Japanese Knotweed, for example, will need to be removed under highly-controlled conditions and if trees are to be felled, this should ideally be done between October- February, to avoid nesting season; • The potential for flood risk. Flooding can cause a risk to the project itself and in turn, the planned works may have a potential impact on latent flood risk – both need to be planned for; • Potential heritage and cultural risks. Archaeological excavation may need to adhere to strict guidelines and restrictions may apply to particular structures, requiring them to use specialist materials or processes (in the case of flint walls subject to a preservation order, for example) – any of which may affect the project schedule or budget significantly.
Construction phase • Managing health and safety risks for
construction workers, including working with hazardous materials or at heights, and operating machinery – good practices need to be in place and followed; • Controlling the discharge of surface water and dewatering waters; • Implementing waste management plans including waste reuse, segregation and classification; • Implementing materials management plans;
• Controlling the measures and monitoring of noise, vibration, dust and air; • Spill containment; • Materials storage, especially oils, fuels and chemicals; • Managing the removal of invasive plant species.
Delivering the plan also presents its own challenges. In most cases, the appointed contractor is responsible for adhering to the requirements of all applicable legislation during the course of the construction phase. This includes complying with any planning conditions imposed upon the development and the employer’s conditions of contract. Therefore, it is critical to ensure that the appointment process identifies contractors who are well qualified and experienced for the task at hand – whether they are working on- or off-site.
To conclude, while the CEMP is a vital document, it could also seem a little daunting. We hope that the points above will help to provide some guidance on the aspects to include. In our experience, the most successful projects are those where the CEMP has been considered in detail before work begins on site. In fact, the earlier the planning begins, the better; it allows more time for identifying the critical issues, developing effective and practical mitigation plans and consulting with stakeholders. As a result, the projects are not only more likely to satisfy regulatory requirements effectively, but they are also more likely to come in on time and within budget too.
Harriet Coles is rail account
manager
for Environmental Scientifics Group.
Harriet Coles
FOR MORE INFORMATION Visit
www.esg.co.uk
rail technology magazine Apr/May 11 | 195
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