Article Contaminated Land Laboratories

CLEA LAUNCH

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Tags: Assessment of Land CLEA model Land Contamination Land Exposure Soil Guideline Values Toxicological

The official launch of the CLEA model took place on 17 March 2002, covering:-

  • CLR 7 Assessment of Risks to Human Health from Land Contamination. An overview of the Development of Soil Guideline Values and Related Research

  • CLR8 Priority contaminants for the Assessment of Land

  • CLR9 Contaminants in soil: Collation of Toxicological and Intake Values for Humans

  • CLR10 The Contaminated Land Exposure Assessment Model.

  • Soil Guideline Values: SGV1 Arsenic; SGV3 Cadmium; SGV4 Chromium; SVG5 Mercury; SGV7 Nickel, SGV9 Selenium; SGV10 Lead.

Much of the documentation (but not the model) can be downloaded from the web.

Publications CLR7-10, Tox reports and SGV reports are available to download from the DEFRA website.
CLEA webpages can be found at www.environment-agency.gov.uk by navigating to the Land Quality and then to the Contaminated Land section.

Article Uncategorized Contaminated Land Loss Prevention

SITE INVESTIGATION SHOULD BE FOR CONCRETE DURABILITY IN ADDITION TO SOIL STRENGTH PARAMETERS

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Tags: brownfield concrete foundations Site Investigation

All too often Site Investigation work is seen solely to provide soil strength parameters to enable economical foundation design. There is a need for the site investigation industry to make clients more aware that the aggressive nature of the ground should also be accurately determined if adequate precautions are to be taken in the design of a durable concrete for use in the foundations.

The problems associated with the thaumasite form of sulfate attack (TSA) have been well documented and in August 2001 BRE Special Digest 1 was published. Part 1 of the digest is particularly relevant to the site investigation industry. Without the necessary soil and ground water testing to determine the extent of those aggressive chemicals present at a particular site the concrete cannot be designed in accordance with best practice. It is where possible beneficial to have results from both groundwater and soil samples.

Many Site Investigation reports are issued without fundamental site-related parameters to enable the adequate design of the concrete.

The site assessment procedures should vary depending on whether the site can be defined as natural ground, brownfield containing industrial wastes or pyritic ground, reference to BRE Special Digest 1 should be made for full details.

In general it will be necessary to determine the water soluble sulfate in 2:1 water/soil extracts and the pH in 2.5:1 water/soil extracts. Many Site Investigations where they report any chemical testing only show an occasional soluble sulfate result which is often inadequate to determine the Design Classification for the concrete mix. Where the sulfate in the soil extract exceeds 3.7 g/l SO4 or in the groundwater sample exceeds 3.0 g/l SO4 it is necessary to also determine the Magnesium content. The mobility or otherwise of the groundwater on site also has an affect and should be established.

Where a site is brownfield it will generally be necessary to obtain the Chloride and Nitrate content in both the soil and groundwater samples if the aggressive chemical environment for the concrete is to be accurately determined. Where Pyritic ground conditions are anticipated more substantive testing is required to enable the total potential Sulfate and hence the concrete design requirements to be determined, for full details reference should be made to BRE Special Digest 1.

It should be apparent from the above that greater consideration needs to be given to determining the aggressive chemical environment at the site investigation stage than is currently the case, to determine site-related parameters for strength in one site investigation and then undertake further work at a later date to enable the Aggressive Chemical Environment for Concrete to be determined is no way for the industry to improve its standards or its advice to clients.

It should also be noted that BRE Special Digest 1 has superseded BRE 363.

D.Brightman Technical Manager, Rock & Alluvium

Article Contaminated Land Loss Prevention

ENVIRONMENTAL INSURANCE

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Tags: environmental insurance solutions loss prevention risk exposures

The AGS Contaminated Land Working Group organised a seminar in July 2001 to provide an update on the latest position of environmental insurance. Seminar presentations were provided by speakers from both insurance brokers and underwriters (Mike Patterson of Willis, Tony Lennon of ECS, Ian Evans of CERTA and Richard Davies of AIG).

Introduction

The regeneration of brownfield land has been hindered by the absence of a coherent redevelopment framework, the entrenched attitudes of some regulators and the previous availability of greenfield alternatives.

Concerns over the inherent complexity of the Contaminated Land regime and its ambiguous liability principles are causing ongoing uncertainty in the property industry. Research carried out on behalf of the RICS has demonstrated that concern about contamination is still the major barrier to brownfield land regeneration.

The main concerns tend to centre around financial uncertainties such as escalating clean up costs, the long term liability exposures and the potential impact of stigma. The risks are compounded by a perceived lack of clarity in relation to the consistent enforcement of the new regime by the local authorities (and regional Environment Agency offices) and the practical application of the risk assessment process

Notwithstanding these concerns, Government policy, new fiscal incentives and other commercial pressures are encouraging the mainstream property sector to reconsider its historic aversion to land with a previous industrial usage.

The evolution of new environmental insurance solutions over the past five years has had a significant impact on brownfield land development. New risk transfer products are being used to remove residual risk exposures and maximise financial certainty.

It is recognised that insurance should be considered in the context of a risk management strategy as indicated below:

RISK IDENTIFICATION AND EVALUATION

RISK RESPONSE

AVOID – abstain from activity or purchase
CONTROL – loss prevention / monitoring
RETENTION – retain the risk
TRANSFER – insurance, contract, warranty

This article will review the main environmental insurance products and markets as outlined in the seminar.

Environmental Risk Exposures

Most operations and business ventures are exposed to environmental risk. Practical sources of risk arise from three sources a) Operational risk – may lead to pollution at some time in the future and typically arise form sources such as industrial plant, vehicles and transportation, fuel and chemical storage or waste products b) Historical risks – relate to past activities that may have left a legacy or dormant or active pollution. c) Contractual risk – liabilities and warranties agreed in contract such as sale and purchase agreements, leases, indemnities and warranties etc.

Many organisation perceive that environmental risks are covered by their existing public liability or property damage insurance however these usually have pollution exclusion clauses and do not cover own site clean-up.

Potential consequences of these risks include own site / off-site damage and clean-up costs, business interruption, regulatory authority notices, legal costs, bodily injury and property damage.

The Players

The design and placement of an appropriate environmental insurance solution usually requires input form many parties. Policies cover potentially enormous loss scenarios and may represent significant capital outlay. It is therefore important to recognise the pitfalls and obtain objective advise.

The players potentially involved comprise:

“PLAYER” ROLE BROKERS Professional intermediaries who have access to the whole market and range of products, acts in Clients interest to obtain best solution. Not to be confused with underwriting agents or insurers eg. Willis, Aon, Marsh,

AGENTS Acts on behalf of a specific insurer offering their products and conditions eg. CERTA are agents for Allianz Cornhill insurers

INSURERS Underwrite the risk eg AIG, Allianz, ECS / XL Capital, Zurich

REINSURERS Insure the insurers eg Swiss Re LLOYDS Private and corporately funded syndicates

INSUREDS Varied but includes industry, commerce, banks / pension funds, governments etc etc

The Products

The main environmental insurance products include :

  • Historical Contamination Cover Insurance can be arranged for liabilities associated with pre-existing contamination ie not liabilities associated with current activities or future “new” pollution. Cover is typically provided for both third party damage claims (resulting from off-site migration) and statutory clean up costs. It can however be extended to cover issues such as business interruption or economic loss associated with contamination (eg rental income, loss in property values etc). Policy periods typically vary between 5 and 15 years.

Policies can be worded so that they are fully transferable and often jointly insure various parties (eg vendor, developer, acquirer and financial backers etc).

  • Remediation Cost Cap Insurance Cost cap insurance is designed to minimise the uncertainty associated with clean up projects by providing the extra funds to complete the works in the event of a cost overrun resulting from the discovery of additional contamination, failure of the remedial technology etc. It is often combined with a ‘wrap up’ cover to protect against pollution liabilities associated with the actual clean up operations and the long term effectiveness of the scheme.

  • Contractors Pollution Liability Remediation and construction operations present an on-going risk of pollution or contamination. Public liability policies typically exclude gradual pollution risks and will not cover any on-site remediation costs. Specialist cover is however available to indemnify the contractors against on-going pollution risks resulting from unanticipated discharges, leakages or spillages etc

Future Pollution Cover (Operational Pollution Risks) Public liability policies generally provide cover only for the costs of third party damages and injury arising from pollution incidents that are sudden, accidental and unexpected. Most PL policies do not therefore provide cover for claims arising from gradual pollution such as leaking underground storage tanks. In addition PL policies do not cover clean up of the insured’s own land and may not respond to clean-up orders from the regulatory authorities. Future Pollution cover is designed to “plug” these gaps providing for own site clean-up, claims from neighbours for damages or injury, legal defence costs and clean-up notices from regulatory authorities. Such insurance is available for policy periods between one and five years.

In many situations the correct business risk solution involves the combination of historical contamination cover and future pollution cover for example. This provides cover for claims for third party damage and injury arising from historical contamination migrating off site and future spills, run-offs and leaks. It also provides for clean-up orders for the insured’s own site or third party land from enforcement authorities – for example remediation notices from the local authority.

Where sites are heavily contaminated and remediation is required, cost cap cover can be placed to limit escalation of costs, backed up by historic contamination cover to provide assurance for financial consequences of potential residual contamination not dealt with by the remediation.

The Finale

Most industrial operations and business ventures are exposed to environmental risk. Constantly tightening legislation coupled with an active merger and acquisition climate means that these risk area becoming more significant. Environmental insurance is providing a rapidly expanding armoury of solutions to these risk exposures. The environmental insurance market in the UK has seen substantial increases in insurance premium volume and innovative deals to demonstrate the value of environmental insurance. Willis estimate up to £25 million in premium was written in the London insurance markets during 2000 and this figure was almost doubled during 2001. This represents very rapid growth – five years ago premium was negligible. Insurance should form only part of an integrated risk management approach to environmental liability exposures but can be a valid and real part of the solution.

For further information please contact Fiona Rooney (Director – Environment Practice, Willis Ltd)
Tel 0118 949 8035, rooneyf@willis.com

 

Article Loss Prevention

PI INSURANCE DOES THE CLAIMS EXPERIENCE EXPLAIN THE INCREASED PREMIUMS? A talk given to the AGS Members Day by Charles Hayward Griffiths & Armour

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Tags: Changes in the Insurance Market Claims Lower Interest Rates and Investment Returns Speed of Settlement

Recent press cuttings all testify to an increase in premium rates:-

“Indemnity cover to soar by 50%”

“Professional Indemnity premiums are soaring for consultants, hitting the biggest on their bottom line and threatening the viability of smaller firms.”

“PI rates soar by 600% for high risk contractors….premiums for surveyors civil and geo-technical engineers are seeing rate rises of several hundred percent”

Where “It” = the increase in PI premiums.  Why is It? · What is It ? · How can you deal with It?

Why has it come about?

1. Claims

  • The driving force is the poor claims experience. Under ACE scheme, claims continue to increase.

  • Year No. of circumstances reported 1961 39 1971 96 1981 320 1991 540 2001 674

  • A lot of design errors – in spite (because) of technology and in spite of QA, maybe because engineers are busier, maybe less experienced staff being supervised less

  • D&B claims have become a major influence – contractors are more prone to claim and very often their sub-consultants are the only people they can claim from – because fixed price there is no opportunity to mitigate loss by arguing betterment – harder to defend because difficulties in establishing the evidence

2. Speed of Settlement

3 developments all with the same broad and worthy intention – to speed up justice and the resolution of disputes

  1. Woolf Reforms (otherwise known as the Civil Procedure Rules) – designed to bring a more open handed and transparent approach to civil litigation with a view to accelerating or even averting cases going to court.

  2. The increasing use of Mediation to settle claims at an earlier stage

  3. Statutory Adjudication

Overall these developments have been beneficial – claims which once were taking 4/5 years to settle are now being settled in maybe a year with a consequent reduction in defence costs. However there have been some adverse consequences namely a quicker outflow of cash for insurers which, combined with …

3. Lower Interest Rates and Investment Returns ..

..has served to increase underwriting losses.

Whereas previously we were in a position where underwriting losses were made tolerable by investment income earned over the 5 years it took for a claim to settle, we are now in a situation where there is nothing to subsidise the bad underwriting results. Insurers used to be able to aim for an underwriting loss knowing that investments would then steer them into profit – that is no longer the case.

4. Changes in the Insurance Market

Direct The withdrawal (either voluntary or enforced!) of some PI insurers – Cox – HIH – Independent – London and Edinburgh – SEPIA – AXA – Colonia – Admiral (effectively by withdrawing “each and every” cover), – a number of Lloyds syndicates.

Few if any major newcomers to fill the gap. The litigious nature of society, a general increase in claims, some adverse court decisions, highlighting deficiencies in policy wordings and difficulties in reinsurance arrangements have all made PI insurance a less attractive proposition to underwriters.

Of those that are left even they are reducing because of the forces of Market Consolidation

– 7 major composites down to 3 – RSA, Aviva, Zurich – Lloyds syndicates (number of syndicates down from 156 to 108 predicted by some to reduce to 50 within a year)

Amongst those insurers who are left, there is a renewed determination that they want to write for a profit. There is no sentiment for loss-making classes of business.

It would be disingenuous of me to tell you that your insurance premium has increased solely as a consequence of September 11th. No direct effects for PI but a massive impact upon insurers generally and most insurers need to increase their premiums across the board just to refurbish their balance sheets.

By contrast Enron has had a massive impact on PI – not just a big direct loss for underwriters (£250M on Andersons PI) but some major ancillary losses will also arise e.g. Bonds and Guarantees – overall loss could be $10bn.

However even if by some miracle a particular insurer had emerged unscathed from either of these 2 catastrophes then it is almost certain that their Reinsurers will not have done and it is reckoned that they alone are looking for a 25% premium increase.

The net effect is a situation where an increasingly unattractive class of business is looking for an insurer amongst a reducing number of more discerning providers all of whom are demanding a higher price. In short – a sellers market where insurers can dictate prices and terms.

Not only PI but also other classes of liability insurance. In Employers Liability the industry-wide ratio of claims to premiums is reckoned to be 150%. Public Liability rates reckoned to be increasing by 100%. Directors & Officer rates up by 300-400%.

What is the increase?

On ACE scheme the Premium increase is 1.3% of fees on top of whatever you were paying previously. Excess levels are up to 1% of net fees.

However – cover is still there – using the same quality insurers who have demonstrated their long term commitment to the scheme – still able to write large Limits of Indemnity – up to £50M – cover for pollution and contamination still available as before – aggregate plus one – wider than available elsewhere – even now the average premium rate is still lower than it was in 1988 (the last “hard” Insurance market) – in real terms excesses are back to 1988 levels

What needs to be done?

1. Need to raise your fees

Not just to pay the premiums (!) but also because there is a fear that you are selling your services too cheap at a price that does not reflect the risk that you are taking on; nor one which allows you to reward and invest in your employees who, besides being your major asset, are also your prime source of liability. A lack of money in the system will lead to reduced training, supervision, and innovation which in turn will result in yet more claims.

2. Need to avoid claims

Individually for your own future insurability and viability – with such large excesses 2 claims a year is 2% of turnover!

Even if you yourself are “clean” and continue to keep yourself clean, you could become guilty by association if your profession (or your particular branch of that profession) gets a reputation for big claims. Therefore a need for collective action if you are to ensure future availability of PI.

* * * *

How to reduce claims

An analysis of all the major claims from ACE scheme in last 10 years shows that Geotechnicals are capable of producing some hefty claims at an average cost of just under £500,000.

A review of some of those major claims also provides an indication of the source of claims. Projects include highways, dams, swimming pools, high rise buildings, rivers, site investigations, landfill sites with claim costs ranging from £100k up to several million pounds.

· Design error requiring redesign after job completed · Even more expensively, a design error spotted at review but prior to commencement on site led to contract delays · Inadequate number of boreholes · Inadequate analysis of water containment properties of rock for a reservoir · Calculation error when assessing shear strengths · Overlooking the complexity of the geology on a highways project · A personal injury claim when Gas main was struck during a borehole investigation. Contract stipulated that developer client would undertake a search on services – the client had indeed established that there was a gas main on site but he decided not to tell our insured engineer about it. Whilst the client was held to be primarily responsible, the HSE also held engineer to have been partially culpable for failing to check with the client that they had undertaken the search. They reasoned that if they had checked then the problem would have been disclosed.

A review of some current claims also indicates the source of claims

· Failure to warn of possibility of solution features in chalk soil · Failure to expressly warn a contractor client that a particular method of temporary works would be inappropriate for a certain slope · Negligently describing made ground as Grade V chalk · Contaminated land investigation on a development site – a calibration error caused an overstatement of contamination present – the successful purchaser has sued for wasted costs whilst another unsuccessful bidder has also sued for lost opportunity! · Allegation that remediation contract was poorly supervised – inadequate and incomplete record-keeping

What ought you to do?

1. Don’t Make Mistakes

Nobody willingly makes mistakes but there are things that you can do lessen the chance of mistakes happening or to stop mistakes actually resulting in any loss. – train staff – supervise – Peer reviews and checks – review report formats/standard letters/site inspection reports. But it has to be said that not even that you are never going to avoid claims altogether.

2. Watch What You Sign

Be careful on your appointments. The emergence of D&B and other new methods of procurement is leading to ever more weird contract forms – for the sake of your claims experience and your insurability you need to resist such overtures.

General principles

  1. As far as possible sign up before you do the job – at very least agree heads of terms.

  2. Limit your liability both in money (at the very least to your Limit of Indemnity) and time (avoid going beyond 6 years). Remember if you sign up undertaking to provide £10m Limit of Indemnity there is a real possibility that in the current market you may not be able to afford that level of cover next year. 3. Transfer risk – at very least do not accept unfair risks.

Do Not Sign

  • Absolute obligations irrespective of negligence e.g. which allow client to recover damages which would otherwise considered to be too remote or ordinarily be reduced either by the client’s duty to mitigate or by contributory negligence or because not properly or reasonably incurred

  • Fitness for purpose warranties (watch out for stealth clauses)

  • Clauses conferring rights on Third Parties or which allow unlimited assignment

  • Adjudication clauses – those which whilst within the letter of the law otherwise flout its spirit

  • Deeds/signing under seal – extending the right to claim beyond 6 years

  • Loss of copyright

  • Unreasonable insurance clauses – either too much or too long

Do Sign 

  • Liability Caps

  • Net Contribution Clauses – these are being broadly accepted

  • “Evaporation” clauses – limit indemnity to amount recoverable from the PI policy

  • Sub-consultants on a back-to-back basis

Charles Hayward
Griffiths & Armour

Article Contaminated Land

New Guidance from the Environment Agency

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Tags: Environment Agency Procedure Soil Sampling

Secondary Model Procedure for the Development of Appropriate Soil Sampling Strategies for Land Contamination  (Technical Report P5-066/TR)

Prepared by Monitor Consultants for the Environment Agency and the DETR, the Secondary Model Procedures describe the procedural approach for specific activities that support, or are part of, risk assessment, the evaluation and selection of remedial measures, and  the implementation of risk management measures (which are intended to be covered in the primary model procedures).

Technical Aspects of Site Investigation – Volumes I and II 
(Technical Report P5-065/TR)

Supporting technical guidance for specific activities that are part of the activities covered by the primary and secondary procedures.

The above documents are available from:  Environment Agency R&D Dissemination Centre, c/o WRC Frankland Road, Swindon, Wilts  SN5 8YF   Tel: 01793 865 000    Fax: 01793 514 562  email publications@wrcplc.co.uk

Article Contaminated Land

Our man in Europe..

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Tags: contamination issues EC extraction procedures Gravimetric method soil

Note by: Peter Rodd, JacobsGIBB representative on the AGS Committee and Contaminated Land Working Group who attended a meeting of the ISO/TC 190 Committee in Snekkersten, Denmark as the UK representative

The BSI asked the AGS to propose a representative to serve on their TC 190 EH/4 committee that is involved in the harmonisation of standards in the EC and internationally for Soil Quality. The standards being worked on are largely aimed at soil in the soil science sense but soil is defined as all material above bedrock thus geotechnical and contamination issues are also addressed. The BSI required an expert in the physical properties of soil and I was proposed and accepted.

I attended the next meeting of the EH/4 committee in September 2001 and was asked to go to the annual meeting of ISO/TC190, in early October, to represent the BSI and attend the sessions of SC5 (considering physical properties of soil) and its working groups.

JacobsGIBB allowed me the time to attend the Meeting in Snekkersten, a small town about 30 – 40 miles north of Copenhagen. I chose my route to the meeting via Malmo and then by rail over the new double decker bridge (road over rail) between Sweden and Denmark. To my surprise the train went through to Snekkersten (one stop before the end of the line at Helsingor, home to Hamlet’s Castle) without the need to change.

The first session attended was for SC5/WG3 looking at standards for water content. The working group was dealing with two standards. One of these; BS ISO 11461: 2001, Soil Quality – Determination of soil water content as a volume fraction using coring sleeves – Gravimetric method, had been recently issued as a full standard and was not discussed.

The second document, ISO/DIS 16586, Soil Quality – Determination of soil water content as a volume fraction on the basis of known dry bulk density – Gravimetric method, is at a late stage of development. (DIS – Draft International Standard). Comments from member countries were discussed and adopted where appropriate. One issue was a conflict between the two documents – BS ISO 111461 contains a note suggesting that drying at 105oC for samples containing significant organic mater will not greatly affect the result, ISO/DIS 16586 suggests it will. This will be resolved when the recently issued standard comes up for review.

The next session attended was for SC7/WG6. The working group is considering three standards; ISO/AWI 21268-1 Soil Quality – Leaching procedures for subsequent chemical and ecotoxicological testing of soil and soil materials – Part 1: Batch test using a liquid to solid ratio of 2 l/kg dry matter, Part using 10 l/kg and Part3: Up-flow column test.

A large part of the session was taken up with a presentation of results using different extraction procedures. The use of end-over-end shaker or a roller table did not seem to affect the results and so the use of either will be permitted. There did, however, appear to be a system error between the extraction procedures used by the laboratories. As a result further work is required before the standards can move forward. The chairman also asked for feedback from the member countries on the type of containers they recommend. (feedback to PGR please).

(Note feedback on the items discussed should be sent to Peter Rodd   pgr@mpg-ctrl.com)

Article Contaminated Land

Report on Remediation and Waste Management Regulation Regime Seminar

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Tags: EA EC Waste Framework Directive Environment Agency Remediation Waste Management Waste Management Regulation Regime Seminar 2001

By Rob Frost and Hugh Mallett (Enviros Aspinwall)

Background

To bring the UK into line with the EC Waste Framework Directive the Environment Agency (EA) has issued guidance on the application of waste management licences to remediation. This guidance states that contaminants are “waste” as they have been “abandoned” or “control of them has been lost”  because the soil is not discrete from the contaminants that too will be considered waste. In particular circumstances uncontaminated natural arisings from service and foundation excavations on development sites could also be considered waste. The implications of this are that most, if not all, development sites will either require an exemption from Waste Management Licensing or will operate under a Waste Management Site Licence.

Position Paper

The consequences of this guidance are significant in terms of remediation and the redevelopment of brownfield sites.  The AGS therefore published a Position Paper setting out the industry’s concerns (AGS web site) and this paper formed the Agenda for the Seminar with the EA, held at the Institute of Civil Engineers and attended by over 70 delegates.

Seminar

The scene was set by Peter Witherington (Chair of the Contaminated Land Group) who outlined the main concerns described in the Paper.  David Baker (House Builders Federation) then described how the EA Guidance and its interpretation could severely dent the Government targets for redevelopment (60% of new homes on brownfield sites).

Paul Needham of the EA Waste Division then described the EA position with regard to the EC Directive and its interpretation in their Guidance.  He responded specifically to the AGS Position Paper;

  • The EA should not seek a Waste Management Licence for the movement of clean natural soil.
  • Geotechnical processes which generate material should not be classified as waste.
  • Minor re-grading will not normally require a Waste Management Licence (minor not defined).
  • Cover systems may require a Waste Management Licence.
  • Exemptions from Waste Management Licences will be granted for material processed through mobile plant or material that is less than 2500m3and remains at the site of origin.
  • Even if material has a use on site this does not preclude it from regulatory control.

An animated Question and Answer session followed during which the EA failed to satisfactorily respond to the concerns raised in the Position Paper.  The main conclusions of delegates were that;

  1. The Guidance appears to be designed to move remedial strategies away from encapsulation and towards in situ or ex situ on site treatment of soils.
  2. The Guidance appears to be at odds with the principles of risk assessment and sustainability in land development
  3. There is an unresolved incompatibility in the EA’s position which requires that the same Waste Management controls are equally applicable to “landfill as they are to the remediation/ redevelopment of marginally contaminated soils.

Following the Seminar three actions have been undertaken by the AGS;

  1. The AGS was invited to join the “Single Remediation Working Group”. This Group has support from both DEFRA and the EA and has as its prime objective the definition of a dedicated regime for remediation.  Simon Edwards (Merebrook) is the AGS representative and the Group had its first meeting in December.
  2. The AGS has written to the Environment Agency with an offer to assist in their forthcoming revisions of the Guidance on Waste Management.
  3. A written response to the Position Paper has been received from the EA which will now be up-dated.

Members with an interest and/ or experiences associated with Waste Management Licensing and remediation are encouraged to share information with the Contaminated Land Group.  This will be vital in ensuring that the Single Remediation Working Group can properly address industry’s concerns in this most important area of our work.

A copy of the AGS Position Paper can be found on the website.  A flow chart to help decide ‘Is it Waste’ can also be found.