The third instalment of our Environmental Insights series coincides with Water Quality Month. Here, Martin Ballard highlights the role construction can play in maintaining and enhancing water quality in the UK.
Martin works as Group Environment Manager for Willmott Dixon and is also a contributor to the Environmental Manual.
Please explain a little about your role…
As Group Environment Manager for Willmott Dixon, I am responsible for ensuring the business protects itself from environmental risk. I also ensure we explore new opportunities to perform, with a focus on compliance, assurance, audit and training. Prior to that, I worked with Anglian Water, Environment Agency & National Rivers Authority. So, I have seen first-hand the importance of water quality for our own being, livelihoods and all economic sectors.
Construction is one of the major contributors to water pollution incidents in the UK
Various factors contribute to water pollution. We often don’t see water quality as a construction issue, but this needs to change. We present a cumulative potential impact on water quality, as well as pollution events from fuel spills to oil leaks. The controls for these are much improved and must be sustained. There is a greater ecological risk from siltation and mud runoff, especially with the increase in extreme weather events.
Coagulation of construction dusts
An area few think about is the coagulation of construction dust, or the microplastics for construction products. Chiefly, how these could contribute to the local impact over many years.
Blue Planet did a great job of highlighting the issues of plastics from communities. However, our sector needs to understand its part as a contributor.
Polystyrene and insulation fragments from materials used in foundation formworks and for insulation presents local risks unless materials are well managed at source or in cutting stations. This can prevent thousands of micro-plastic beads being created when cutting or abrasion, which are lightweight and easily blow away even in the lightest breeze, entering adjacent habitat and watercourses.
We need to think about how trades and project teams manage materials. Crucially, how we cut operations, offcuts and waste, as well as implementing tight control of dust through good housekeeping at the source. Not only will this be helpful for occupational health reasons, but also to protect the environment. All of this is key to avoiding the creeping impact on pollution.
What are concretebergs?
Another aspect recently mentioned in Construction News is ‘concretebergs’. These have appeared as a result of poor concreting practices.
Greater attention needs to be made by sub and superstructure contractors when concreting. This should ensure we don’t displace concrete into void surface water drains or sewers. Until set, concrete will have a detrimental impact on water quality by displacing pH levels and adding to siltation. Consequently, the impact on communities and the environment from blocked drains is significant and costly to rectify. Wherever we can trace it, the polluter pays principle applies for pollution clearance and drainage repairs.
What can construction sites do to prevent water pollution incidents?
There are 3 things sites can do:
- Understand the site layout and its setting within the local environment. Put in place logistics controls to ensure any risk is furthest away from the lowest point in the site. This way, you can contain and manage issues like runoff/material storage on-site.
- Understand pollution pathways. Ensure controls are set up at the source of each risk, whether it be COSHH, fuel storage, silt runoff or material cutting stations. Good barrier controls and waste management are crucial. Create designated areas and buffer zones between the hazard (at least 10m from drains or watercourses) and the pathway to the environment. This could include road buffer between open ground and road, to prevent tracking waste soil onto the highway. Nothing should leave the site or go down storm drains that is not silt free and clear, whether groundworks, demo or wet trade-related.
- Check the measures and maintain buffer zones at least weekly. Also, reset controls immediately. There has been a rapid flux of weather extremes recently between heat and summer storm. Plus, the Beast-from-the-East has brought cold spells followed by swift thawing and runoff. As a result of these, the effectiveness of site controls will be tested. These phenomenal events will challenge even the most experienced site team to think about how weather events may affect projects and defeat any controls in place.
Our sector often exercises its site pollution plans. However, more often the scenario used is limited to fuel spill drills. What are the risks that each of your sites has? Is it just refuelling? And, how can you prepare sites and drill for those scenarios, considering the impacts of changing weather patterns?
It’s Water Quality Month in August. So, why is good water quality important in our rivers, streams and watercourses?
Fundamentally, we depend on water for life. The ecological health of the river catchments ensures we protect water supplies now and for the future. The built environment relies on a sustainable water supply. It ensures we can continue to build, maintain and thrive in the places where we live. Runoff of silt and associated pollutants from urban areas presents a significant risk. Therefore, the construction and facilities maintenance sector have a great part to play to ensure we deliver services sustainably.
Having sustainable access to water is critical for us all. Besides, we all have a part to protect these daily.
If you see something that’s not right, sort it immediately and report what you’ve done or seen to help control water quality, on or off sites. There’s always something to learn and help each other understand how best to behave to protect water quality and the health of our watercourses.
The CIP Environmental Manual contains guidance and an explanation on water quality & pollution and is available as a Hardcopy and CDROM, and online at www.cip-knowledge.com
If companies don’t plan and prevent water pollution, what are the consequences?
Firstly, there is a reputation and brand aspect for our sector. More importantly, there is a potential financial impact if we get things wrong.
The regulator may give a verbal warning. However, if the company fails to heed this or the offence warrants it, the regulator can issue a ‘yellow card’ with a formal warning or caution.
The polluter pays principle applies. Well before the recent Fee for Intervention applied by HSE, the environmental regulators have recovered costs and applied fees for their involvement.
If conditions of permit or exemption are breached, prosecution or legal enforcement may be taken. The impact of the Sentencing Council guidelines for environmental offences are significant and escalate in relation to the business’s turnover, whether sole trader, SME or large organisation.
Fines that have been issued since 2015 have been far more significant for water and environment. In fact, compared to health and safety events, they’ve been 10 times higher, with the highest water/waste fine recorded as £20m.
An SME housing developer was fined £120k for silt pollution in 2018. With legal costs and fees awarded, this is equivalent to £250k. Planning, understanding the pollutant pathways and controlling risks costs less than fines and associated costs.
Where can companies get support on adopting good best practice measures to prevent water pollution incidents?
Guidance and support for the water quality topic are readily available for businesses of all sizes. Accessing these resources can ensure the right controls are in place.
The CIP Environmental Manual (www.cip-books.com) is a fantastic resource written by the industry for the industry.
In addition, the Supply Chain Sustainability School (www.supplychainschool.co.uk) has free resources. It helps businesses understand the source of the pollution, the pathways and controls, and ensure a plan of action if they breach controls.
The construction industry’s site environmental awareness training scheme (SEATS) and equivalents offer practical tuition.
Considerate Constructors Scheme has really helped to promote best practice on drainage and gully protection, road sweepers and many more through its hub. So, this is well worth a look.
There are often simple solutions such as hessian netting, which we can use for debris netting over drains. We need to take care, though, that plastic debris netting does not contribute to microplastic pollution, as easily worn and frayed.
There are many cost-effective and sustainable solutions to protect risks at source and break the pathway to the environmental receptor. All of these are better value than a day in court.
Is the water legislation the same in England, Scotland and Wales?
The principles of water legislation are the same. However, in all the devolved countries of England, Wales and Scotland there are nuances. There are some exemptions that benefit the sector for certain activities. The CIP manual covers the different legislative frameworks and what you need to do for your project in each region.
Who enforces the water legislation?
The government’s competent authorities enforce water legislation in their respective areas:
- Environment Agency (EA in England)
- Natural Resources Wales (NRW)
- Scottish Environmental Protection Agency (SEPA)
Any discharges must be with the agreement of the asset owner. To a sewer, this must be with the agreement of the water company (trade effluent consent. If it’s an ordinary watercourse of drainage ditch, the local authority is the asset owner. For canals and managed waterways, or landowners with riparian ownership, it’s the Canals and Rivers Trust. Competent regulators regulate all water quality.
What is your top tip for businesses working in construction around this issue?
My best tip would be to plan for water at the earliest opportunity in any project. Good planning will prevent any issues further down the line. Always think about the changing weather events.
If in doubt, engage with the regulator to clarify concerns as early as possible. We don’t tend to see water as the same risk as waste or nuisance. However, as a sector, we need to change this. Mandating water and silt control management plans could be a positive progression for the industry.