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Procedure to ensure that Environmental Legislation is complied with on the Association’s sites(OP20:V10:22/04/08)

Responsibility

Head of Surveying, Head of Design, Project Manager, Clerk of Works, Employers Agent, Senior Building Surveyors, Building Surveyors, Contract Adminstrators.

Action

The appropriate Contract Administrator will incorporate the attached Environmental Site Management Policy into every ‘Design & Build’, traditional development, refurbishment and improvement contract.
For Section 106 sites the developer will be expected to comply with The Vale Housing Associations Environmental policy on the sections of the site containing the new dwellings or adhering to their own policy after presenting it to the Association to ensure that the developer is following best practice procedures. (See CP13)
If a contractor fails to comply with environmental legislation they will be made aware of the failure and asked to show how they will achieve compliance in the future. Repeatedly ignoring legislation will lead to either the termination of the contract or no future invitation to tender.
At the pre-start site meeting the appropriate Contract Administrator or Clerk of Works or Employers Agent will remind the site foreman of the Association’s Environmental Site Management Policy and his responsibilities under it. For section 106 sites the developer will be expected to confirm what standards they are working to (see point 2) to ensure that they are acceptable to the Association.
During the regular site inspections by the appropriate Contract Administrator, Clerk of Works or Employers Agent checks will be carried out to ensure that this Policy is being complied with.
Any environmental comments made at site meetings will be minuted.

Recording

The contract documents
Contract Administrator/ Clerk of Works / Employers agent will maintain site / activity diaries recording inspections made.

Contract Administrator / Clerk of Works / Employers agent will keep the inspection records and diaries in the relevant contract files together with minutes of site meetings.

Any environmental incidents should be noted and minuted at site meetings, along with remedial action taken. Compliance with OP20 should also be reviewed and minuted. Both should be reported to Green Team.

The Vale Housing Association’s Environmental Site Management Policy

For Contractors Working Outdoors

Fires (to meet the requirements of the Clean Air Act 1993 and EPA 1990)

The Association has a ‘no fires on site’ policy.
Whenever possible estate roads are to be constructed up to the wearing course before other contract work begins.

Site Drainage (to meet the requirements of the Water Resources Act 1991)

During contract work manholes on site should be colour coded:

Blue - surface water / Red - foul water.
Water containing silt or other pollutants should never be pumped directly into a river, stream or surface water drain. Dirty water should, where possible, be pumped to a foul sewer.
Concrete is highly alkaline and corrosive and can have a devastating impact on watercourses. Washings from concrete mixing plant or ready mix concrete lorries must not be allowed to flow into any drain or watercourse.

Deliveries of fuels and hazardous materials (to meet the requirements of the Water Resources Act 1991)

All deliveries are to be supervised by a responsible person.
Levels on storage tanks / drums should be checked before delivery to prevent overfilling
Diesel pumps and similar equipment should be placed on drip trays to collect minor spillages. These should be checked
regularly and any accumulated oil put in sealed containers and removed from site for recycling.
Where practical, mobile plant should be refuelled in a designated area, preferably on an impermeable surface and away from any drains or watercourses.
A contingency plan should be put into place and suitable materials should be available to deal with any incident.
Employees should be trained what to do in the event of a spillage.

Chemical Storage (to meet the requirements of the Water Resources Act 1991)

All fuel, oil and chemicals shall be stored in a secure location, in well marked, sound containers. The location should be away from water courses and drains.
All oil, spillages and empty or leaking oil drums must be removed from the site immediately and disposed of via a licensed waste disposal contractor.

Waste Storage (to meet the requirements of the Environmental Protection Act 1990 and the Hazardous Waste (England and Wales) Regulations 2005)

All wastes must be stored in designated areas, which are isolated from surface drains.
Skips should be covered when not being used and at the end of the working day and replaced when full.
Used oil, oil filters and many chemicals are defined as "hazardous waste" and need to be collected separately under the conditions of the Hazardous Waste (England and Wales) Regulations 2005.

Airborne Contamination (to comply with the requirements of the Environmental Protection Act 1990 and the Control of Pesticides Regulations 1986)

Dust from cutting or grinding equipment should be contained to the area of source and collected via filtered mechanical means.
Airborne contamination from ‘special waste’ such as asbestos, shall be controlled by only registered and approved companies that have been authorised to do so by the Association.
Chemicals used by pest control to eradicate a pest problem in properties should be environmentally friendly and not contain products or chemicals barred by the Association.

Site noise (to meet the requirements of the Environmental Protection Act 1990, Control of Pollution Act 1974, and The Noise at Work Regulations, 1989 SI 1790)

Part III of the Environmental Protection Act 1990 (1) gives local authorities mandatory powers to control noise or vibration which is causing, or is likely to cause a statutory nuisance. They set noise limits taking into account the character of the local area. Particular care therefore needs to be taken in areas which were quiet before work began. All contractors working on Association sites must comply with the local authority noise limits and any specific noise restrictions stipulated in planning consents.
Local authorities have further specific powers to control noise and vibration from construction and demolition work under Section 60 and 61 of the Control of Pollution Act 1974 (4). If contractors know that their operations are going to create noise nuisance they should apply for a consent from the local authority’s environmental health department in advance.
Contractors should act courteously to local residents and businesses and inform them if noise will be persistent or particularly loud. Under Section 82 of the Environmental Protection Act local authorities can act on complaints from the public and serve an abatement notice to control unreasonable noise and vibrations.
The provisions of The Noise at Work Regulations, 1989 SI 1790 [12] should be complied with on all Association sites. If people have difficulty speaking to each other over approximately 2m, steps should be taken to reduce noise (eg fit silencers to machines) and ear protection should be provided for employees.
Under Regulation 11, The Noise at Work Regulations 1989 all employees should be told about the need to minimise noise and about the health hazards of exposure to excessive noise.
Contractors should do all they can to avoid unnecessary noise. Noise minimisation should be based on the concept of ‘best available techniques not entailing excessive cost’ (BATNEEC).

Wildlife Conservation (to meet the requirements of the Protection of Badgers Act 1992 and Wildlife and Countryside Act 1981)

Under the Protection of Badgers Act 1992 it is an offence to wilfully kill, injure, take or attempt to kill a badger and to interfere with a badger sett.

Emergencies

In the event of a spillage on site, the material should be contained (using an absorbent material such as sand or soil or preferably a spillage kit)
The Environment Agency should be notified immediately, on its emergency hotline number (0800) 807060.

Notify the Association.

Environmental Incidents Register

The site foreman will keep an Environmental Incidents Register, recording all potentially damaging environmental incidents and the measures taken to minimise them eg spillages.

The Vale Housing Association’s Environmental Site Management Policy

For Contractors Working Indoors

Waste Storage (to comply with the requirements of the Environmental Protection Act 1990 and the Hazardous Waste (England and Wales) Regulations 2005)

Skips should be covered when not used and at the end of the working day, and replaced when full.
Where skips are not present all waste must be stored in designated areas, which are isolated from surface water drains.
The occupier of the premises should be notified of the presence of Special Waste and the location of storage.
'Hazardous waste’ such as asbestos, must be disposed of in accordance with its type under the conditions of the Hazardous Waste (England and Wales) Regulations 2005.

Site Drainage (to comply with the requirements of the Water Resources Act 1991)

Concrete and mortar mix is highly alkaline and corrosive and can have a devastating impact on watercourses. Washings from mixing equipment must not be allowed to flow into any drain or watercourse.
Water from heating systems which contains toxic chemical inhibitors or cleansers should not be drained into surface water or foul drains.

Chemical Storage (to comply with the requirements of the Water Resources Act 1991)

All fuel, oil and chemicals shall be stored in a secure location, in easily identifiable sound containers.
Spillages should be attended to immediately, by containing the material using absorbent sand or soil, and maximum ventilation should be provided.
Employees should be trained to deal with the event of a spillage.

Deliveries of fuels and hazardous materials (to comply with the requirements of the Water Resources Act 1991)

All deliveries to be supervised by a responsible person.
Levels on storage containers/drums should be checked before transportation to prevent spillage as a result of overfilling.
Where practical, mobile plant should be refuelled in a designated area, preferably on a impermeable surface and away from drains or watercourses.
A contingency plan should be put into place and suitable materials should be readily available to deal with any incident.
Employees should be trained to deal with an incident.

Fires (to comply with the requirements of the Clean Air Act 1993 and EPA 1990)

The Association has a ‘no fires on site’ policy.

Airborne Contamination (to comply with the requirements of the Environmental Protection Act 1990 and the Control of Pesticides Regulations 1986)

Dust from cutting or grinding equipment should be contained to the area of source and collected via filtered mechanical means.
Airborne contamination from ‘special waste’ such as asbestos, shall be controlled by only registered and approved companies that have been authorised to do so by the Association.
Chemicals used by pest control to eradicate a pest problem in properties should be environmentally friendly and not contain products or chemicals barred by the Association.

Site noise (to meet the requirements of the Environmental Protection Act 1990, Control of Pollution Act 1974, and The Noise at Work Regulations, 1989 SI 1790)

Part III of the Environmental Protection Act 1990 (1) gives local authorities mandatory powers to control noise or vibration which is causing, or is likely to cause a statutory nuisance. They set noise limits taking into account the character of the local area. Particular care therefore needs to be taken in areas which were quiet before work began. All contractors working on Association sites must comply with the local authority noise limits and any specific noise restrictions stipulated in planning consents.
Local authorities have further specific powers to control noise and vibration from construction and demolition work under Section 60 and 61 of the Control of Pollution Act 1974 (4). If contractors know that their operations are going to create noise nuisance they should apply for a consent from the local authority’s environmental health department in advance.
Contractors should act courteously to local residents and businesses and inform them if noise will be persistent or particularly loud. Under Section 82 of the Environmental Protection Act local authorities can act on complaints from the public and serve an abatement notice to control unreasonable noise and vibrations.
The provisions of The Noise at Work Regulations, 1989 SI 1790 [12] should be complied with on all Association sites. If people have difficulty speaking to each other over approximately 2m, steps should be taken to reduce noise (eg fit silencers to machines) and ear protection should be provided for employees.
Under Regulation 11, The Noise at Work Regulations 1989 all employees should be told about the need to minimise noise and about the health hazards of exposure to excessive noise.
Contractors should do all they can to avoid unnecessary noise. Noise minimisation should be based on the concept of ‘best available techniques not entailing excessive cost’ (BATNEEC).

Environmental Incidents Register

All surveyors, supervisors and chargehands shall record all potentially damaging environmental incidents and the measures taken to minimise their impact.