Article Contaminated Land Laboratories

BS 10175 Updated

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Tags: contamination Geoenvironmental Geotechnical risks

BS 10175:2011 (Investigation of Potentially Contaminated Sites – Code of Practice) was published in March 2011. It is much improved compared to the 2001 version both in content and the way that guidance and information is presented. It meets the initial brief for the revision and has also addressed a number of other issues (see Box). There have been many changes and those familiar with the old version should not assume that they know what the new version says. It must be read, pondered on, and digested.
Unfortunately, there is no reason to expect those who ignored the old version to pay any more attention to the new one unless induced to do so by regulators and informed potential clients. Contamination has been an issue for at least 35 years (the Greater London Council first published guidance in 1976) but we still see reports that would have been regarded as poor thirty years ago. The bottom end is as bad as it ever was. Some reports proudly announce that they have been done in accordance with BS 5930 with no mention of BS10175 thus revealing the writer’s ignorance of good practice.
There is a place for well crafted combined geotechnical and geoenvironmental investigations that properly address both aspects. However, there remain some geotechnical specialists who still think that a few samples taken from random depths from a few random locations and analysed for an unjustified suite of potential contaminants constitutes an adequate investigation for contamination. I should add here, that when I have checked, the culprits have not been AGS members – and that in itself says something about them.
PPS23 (Planning Policy Statement 23: Planning and Pollution Control – Annex 2: Development on Land Affected by Contamination) is about to be withdrawn. This currently indicates that site investigations for contamination should be in accordance with BS10175:2011. It seems likely to be replaced by a single phrase in the simplified planning guidance that the government is intending to introduce. This will make it all the more important for AGS to continue to try to educate both its members and clients about good practice.

 

BS10175:2011 What has changed?

BS10175  gives recommendations for, and guidance on the investigation of land potentially affected by contamination and land with naturally elevated concentrations of potentially harmful substances, to determine or manage any risks.

The brief for the revision was to:

  • align BS 10175 with International Standards (e.g. ISO 10381 series) especially those adopted as British Standards
  • update in relation to legislation and authoritative guidance
  • update technically
  • include additional guidance on sampling uncertainty
  • extend guidance on application of on-site analytical methods (align with draft BS ISO 12404)

All these issues have been properly addressed during the revision. In addition, a number of other significant “general” changes have been made:

  • clearer separation between “Normative text” (i.e. guidance) and informative text
  • clarification of some terminology, e.g. “contamination”
  • emphasise on the importance of early consultation with regulators and including provision of information on the role of local authority “contaminated land officers”
  • tightened reporting requirements
  • introduction of  a requirement concerning the qualification of drillers etc. (as in CP 5930 as amended 2010).

The importance of the conceptual model is emphasised and the process of investigation is characterised as one that seeks to reduce the uncertainty in the conceptual model.

The definition of “contamination” has been amended to:

  • Presence of a substance or agent, as a result of human activity, in, on, or under land, which has the potential to cause harm or cause pollution.

There is no assumption in this definition that harm results from the presence of contamination.
The change aligns BS10175 more closely with the definition in “BS ISO 11074 Soil quality – Vocabulary” and helps to make it clear that the definition in Part IIA of the Environmental Protection Act 1990 has only a narrow application. It should also help to discourage the use of the oxymoron “natural contamination”.

Requiring Planning Conditions or similar regulatory requirements to be noted in the introduction to reports will, hopefully, discipline consultants to get proper briefing from their clients and to consult regulators when they are required to do so (the potential benefits of consultation with regulators when there is no formal requirement is also emphasised). It will be clearer whether regulatory concerns have been addressed and proper consultations carried out.

 

Article Contaminated Land

Supporting the contaminated land community

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Tags: contamination data FASA MCERTS

Dealing with uncertainty and heterogeneity in the risk-based land management process continues to present challenges for the contaminated land community.  The up front investment required to more accurately define risk is sometimes difficult to communicate to all stakeholders involved in projects which can, in some instances, lead to regretful compromises.

 

The EA’s MCerts Policy has increased confidence

Application of the Environment Agency’s MCerts Policy, which standardised laboratory based analytical procedures, has delivered increased confidence in the outputs of samples analysed by laboratories, however the relative cost per sample continues to offer opposition to increasing sampling density. This challenge is recognised by many, including the Environment Agency, however, there is a growing body of evidence to support the conclusion that greater emphasis needs to be placed upon overcoming it if we are to continue to develop potentially contaminated sites whilst eliminating risk and future liabilities

 

Added value…

Portable field analytical tools are, therefore, being increasingly considered to have an important role in supporting the community overcome this challenge. Their appropriate application can offer many added-value and commercial benefits. These include:

 

  • more rapid and cost effective determination of spatial and temporal variations (i.e. heterogeneity);
  • the optimisation of sampling strategies for subsequent laboratory analysis which, ultimately, increase the quality of site data and confidence; and
  • in the right circumstances, they can even enable on-site decision making, thereby dramatically saving time and money.

 

Such tools have been available for several decades and have been rigorously applied in other environmental fields, such as the trade effluent and stack emission monitoring.  However, their application in the contaminated land sector has been relatively low to date. There are many rational reasons for this, including a lack of awareness and confidence in their application, due, in part, to a lack of case history providing technical and economic evidence; a lack of available skills within the practitioner community; and a limited level of acceptance in their application and interpretation throughout the community.

 

FASA workshop

To this end, FASA, the Field Analytical Suppliers Association, hosted x4, one-day workshops this year, to provide attendees with a practical introduction to field analytical tools.

 

These events included:

  • the provision of information related to how they fit within the UK regulatory framework, kindly provided by Bob Barnes and Brian Bone from the Environment Agency;
  • an overview of available tools and case study information detailing the application of five of the most commonly applied; and
  • attendees were provided with the opportunity to see the tools for themselves and gain answers to their individual needs during afternoon demonstration surgeries.

 

What is FASA?

FASA is an independent body created to support the efforts of regulators, industry and laboratories in the management of potentially contaminated environments. It is funded and coordinated by suppliers and manufacturers of field tools in the UK and is supported and administered by IPM-Net.

The workshops described form part of its commitment to assist the community gain an informed understanding of the application of field analytical tools and their appropriate use. FASA aims to further assist the community by working with key stakeholders to develop guidelines, training material, best practice QC/QA procedures as well as technique specific information, such as case studies and evaluations.

 

Following analysis of the attendees’ feedback from the workshops it is clear that such information will assist the community, with 81% and 77% stating that the lack of available guidance and performance information, respectively, were barriers to their uptake. Their perceived costs, a lack of regulation and a lack of information on how to use field tools were, individually, seen as barriers to 60% of attendees.

 

New guidance being developed

The Environment Agency is currently developing guidance on the use of field analytical tools within the risk-based approach to land contamination. This document will discuss, amongst other aspects, the application of field tools in the context of sampling and analytical plans, fit for purpose decision making, building lines of evidence and informing conceptual site models. The first draft is likely to be circulated to the FASA committee by the end of this year, with further release anticipated to occur in the Spring of 2007.

 

For further information contact:

 

Mr Perry Guess , FASA Chairman

Tel:               01865 610504

E-mail:          perry.guess@earth.ox.ac.uk

 

FASA representatives will give a presentation at the next Contaminated Land WG (20 February 2007) on the use of field analytical tools.