In the third instalment of our Environmental Insights series and to coincide with Water Quality Month, we hear from Martin Ballard on 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 and explores new opportunities to perform, with focus on compliance, assurance, audit and training. Prior to that, I worked with Anglian Water, Environment Agency & National Rivers Authority, so 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. What do you think are the main causes?
The causes of water pollution are varied. Water quality is often not seen as such a risk from construction but this needs to change, as we present a cumulative potential impact on water quality, as well as pollution events, beyond just what many people protect against and traditionally may think about, from fuel spills or oil leaks. However, whilst the controls for those are much improved and must be sustained, the greater ecological risk from siltation and mud run off, especially with the increase in extreme weather events we are experiencing, needs greater attention.
An area few think about is the coagulation of construction dusts or the microplastics for construction products, and how these could contribute to the local impact over many years. Blue Planet did a great job at highlighting the issues associated with plastics from communities, and our sector needs to understand its part as a potential 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, to prevent thousands of micro-plastic beads created when cutting or abrasion, which are lightweight and easily blow away even in the lightest breeze, entering adjacent habitat and watercourses. Thinking about how trades and project teams manage materials, cutting operations, offcuts and waste, as well as to tightly control dust through good housekeeping and controls at source, not only for occupational health reasons but also to protect the environment, is key to avoid creeping pollution impact.
Another aspect recently mentioned in Construction News is ‘concretebergs’ due to poor concreting practices. Greater attention needs to be made by sub and super structure contractors when concreting, to ensure concrete is not displaced 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, though the impact on communities and the environment from blocked drains is significant and costly to rectify. Wherever traced, 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 that any risk is furthest away from the lowest point in the site, so issues like runoff / material storage can be contained and managed 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, with designated areas, buffer zones between hazard (at least 10m from drains or watercourses) and the Pathway to the environment (could include road buffer between open ground and road, to prevent tracking waste soil onto the highway). Nothing should leave site or go down storm drains that is not silt free and clear, whether ground works, demo or wet trade related.
- Check the measures and maintain buffer zones at least weekly, and reset Controls immediately. With the rapid flux of weather extremes, recently between heat and summer storm, or with the Beast-from-the-East cold spells followed by swift thawing and runoff, the effectiveness of site controls will be tested. These phenomenal events as we’ve seen in July, will challenge even the most experienced site team to think about how weather events may effect their project and defeat any controls in place. Our sector often exercises its site pollution plans but 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, why is good water quality important in our rivers, streams and watercourses.
We fundamentally 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, to ensure 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, and 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 and 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.
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 is a potential financial impact if we get things wrong. The regulator may give a verbal warning but, if not heeded or the offence warrants, issue a ‘yellow card’ with a formal warning or caution. The polluter pays principle applies, and well before the recent Fee for Intervention applied by HSE, the environmental regulators have been able to recover costs and apply 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, compared to health and safety events, by a 10-fold magnitude, with the highest water / waste fine recorded as £20m. A SME housing developer was fined £120k for silt pollution in 2018, that with legal costs and fees awarded, would I’d estimate be equivalent to £250k with own non-productive time and oncosts – significant for any business. Planning, understanding the pollutant pathways and controlling risk will be less cost than that on most projects.
Where can companies get support on adopting good best practice measures to prevent water pollution incidents?
Guidance and support for the water quality topic is readily available for businesses of all sizes to ensure the right controls are in place. The CIP Environmental Manual (www.cip-books.com) is a fantastic resource written by industry for the industry. In addition, the Supply Chain Sustainability School (www.supplychainschool.co.uk) has free resources, which helps understand the source of the pollution, the pathways, controls and ensuring a plan of action of the controls are breached. 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 well worth a look. There are also often simple solutions such as hessian netting, which can be used for debris netting over drains. Care needs to be taken 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 environmental Receptors, all better value than a day in court.
Is the water legislation the same in England, Scotland and Wales?
The principles of the 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?
Water legislation is enforced by the government’s competent authorities 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); the local authority if it’s an ordinary watercourse or drainage ditch; the Canals and Rivers Trust for canals and managed waterways; or landowners with riparian ownership. All water quality is regulated by the competent regulators.
What is your one top tip for businesses working in construction around this issue?
My best top tip would be to plan for water at the earliest opportunity in any project. Good planning will prevent any issues further down the line and think about the changing weather events. If in any doubt engage with the regulator to clarify concerns at the earliest opportunity. Water is not seen as the same risk as waste or nuisance but as a sector we need to change this. Mandating water and silt control management plans could be a positive progression for the industry.