CL:AIRE Materials Management Plan
Whether it involves brownfield or greenfield sites, developers often deal with contaminated or uncontaminated soil that needs to be reused, treated or safely disposed of. From small residential developments to large commercial projects, it is important to guarantee that excavated materials are handled correctly, especially if the condition and category of the materials are unclear.
Without a sufficient plan, a development involving materials from a past use could end up being a costly process and even impact project viability. The CL:AIRE Code of Practice (DOWCOP) offers a framework for reusing what are known as site-won materials, but with an intention to ensure compliance with environmental and waste legislation.
What is a Materials Management Plan?
A materials management plan (MMP) is a structured document that details how excavated materials such as soil, aggregates and other assets are managed during construction. It specifically follows the CL:AIRE Definition of Waste: Development Industry Code of Practice (DOWCOP) and demonstrates the intended use of these materials to avoid them from being wrongly classified as waste and discarded.
With an intention to reuse materials on the site of origin or a nominated site and minimise unnecessary waste disposal, an MMP deals with contaminated land and surplus materials for any excavation arising. Doing this reduces waste classification and carbon emissions while promoting sustainable development and responsible planning.
Although the contents of a plan may vary, it must cover four key principles:
The Four Main Principles of an MMP
- The material must be suitable for use
- The material must not pose a risk to human health or the environment
- The use of the material must be certain
- The use of the material must not be a part of the development
When is a Materials Management Plan Required?
An MMP will be needed whenever a developer intends to reuse excavated materials and wants to avoid having them considered waste. It applies to both uncontaminated and contaminated land, including materials excavated for road construction, site levelling and utility service trenches.
If it weren’t for an MMP, the developer would need to seek the appropriate permitting, classification under waste management legislation, and off-site disposal of the materials. Not only that, but landfill tax rules and waste duty could apply, and they could risk significant fines if the regulations aren’t complied with.
Common Circumstances for an MMP
- Brownfield projects involving protection or remediation measures
- Developments on brownfield and greenfield sites
- Managing a waste material that presents unacceptable risk without proper treatment
- Soil movement between sites
Why Do Materials Management Plans Matter?
Looking at the environmental and regulatory perks of material management plans, we’ve explained why MMPs matter to such a large number of developments across the country:
Environmental and Cost Benefits
Through reusing treated waste materials or non-waste site-won materials, developers can show evidence of reducing carbon emissions associated with transport and landfill. It also lowers landfill tax payments, waste disposal fees and the likelihood of needing new materials or an appropriate environmental permit.
An approved MMP works towards promoting sustainability and supporting the circular economy in construction. If it weren’t for the option to re-use materials, they would be considered waste, adding to tax payments and contributing to environmental impacts.
Regulatory and Planning Advantages
As well as helping to comply with the Waste Framework Directive and other relevant legislation, an MMP provides the certainty of use that the Environment Agency and other regulators ask for.
It supports regulation by avoiding legal challenges, reducing risks and streamlining the planning process, aligning projects with current care requirements for health and the environment.
Material Management Plan in Construction
A correctly produced MMP should follow the development industry code, include sufficient information to ensure the protection of health and the environment, and encourage collaboration between the developer, the geo-environmental consultant and the qualified person (QP).
Each stage in an MMP development is listed below, along with extra details about the necessary information that needs to be taken from an assessment and the legal requirements it has to fulfil.
Steps in Creating Materials Management Plans
1. Site Assessment
Gauging the quantity of material that needs to be excavated and the material’s geotechnical properties before defining the definition set based on the CL:AIRE definition, and ensuring it meets the conditions DOWCOP requires.
2. Material Characterisation
Analysing the material to classify it, detect contamination and work out if it is a material requiring treatment using laboratory testing, forming an understanding of any treated materials on the development site and the potential suitability it has for re-use.
3. Definition of Intended Use
Confirming how and where the material will be reused within the site or on a nominated site, reducing the need for off-site disposal and entirely avoiding waste classification.
4. Preparation of the MMP
Setting out the care requirements, proposed use, site of origin and verification plan, including reference to the code of practice DOWCOP and incorporating a design statement if necessary.
5. Qualified Person Review
The geo-environmental consultant creates the MMP, conducts a review and signs off the plan, ensuring compliance with practice sets established in the industry.
6. Implementation of Measures
Moving, reusing or treating the materials in accordance with the approved MMP, with the reuse reflecting sustainable development goals and promoting real environments.
7. Verification and Record Keeping
Maintaining records of all chosen actions, including terms of waste exemption and evidence required to demonstrate compliance.
Necessary Information
Important details recorded during the creation of an MMP include:
- Description of the development site
- Geo-environmental assessments and laboratory results
- References of agreed soil disposal, treated materials and waste exemptions
- Site plans with integration of the design statement
- Type and quantity of excavated materials
Legal Requirements
As for lawful conditions, an MMP must:
- Align with the CL:AIRE code of practice
- Clarify if an environmental permit is needed
- Fall under the Waste Framework Directive
- Meet the landfill tax rules
- Present an understanding of how soil movement relates to considered waste
- Show awareness of obligations under waste duty
- Use the correct waste code whenever disposal occurs
Materials Management Plan Guidance
It could seem like a complicated procedure, but with the right support, putting together an MMP correctly becomes a more simplified process. Our team can help with site assessments, remediation strategy planning and verification report documentation in design, demolition and construction projects all over the country.
From working with a material excavated during early groundwork to managing other material from ongoing schemes, we can help you to save money, reduce waste and protect human health and the environment, all while helping your development plans to continue.
The Importance of a Qualified Person in Materials Management
In the procedure for assembling a materials management plan, a qualified person (QP) is vital for guaranteeing the validity of the document. As well as ensuring that all legal and environmental requirements are met, a QP can also alter chemical characteristics, reduce liability concerns and align the chosen methods with DOWCOP standards. In simple terms, without the sign-off from a QP, the MMP is invalid, triggering the possibilities of waste duty and/or landfill tax.
It is common for the QP to be different from the geo-environmental consultant undertaking the assessment and creating the plan. Our team, however, is qualified in both areas and can therefore put on both hats and operate in each role simultaneously. By working in this way, we can cut the costs of hiring two specialists to hiring just one and limit any waiting time that would come from a second expert visiting the site later in the process.
Request an MMP Quote Today
If you need help with a materials management plan, our team can step in to support you. It may feel like a significant cost item, but our approach subsidises any unnecessary additional costs. An MMP will also prevent any issues later in the process, saving you time and money in the long run.
Contact our team online, over the phone or via email, and we will give you a free quote based on your site. We can then walk you through the process, tell you about our current availability, and arrange for a geo-environmental consultant to attend your site and start helping you with an MMP.