Land contamination: risk management (LCRM), recently published by the Environment Agency (EA) for consultation, provides new draft guidance for managing land contamination. Here are RSK’s thoughts on the guidance and what it means for the industry, based on RSK’s wealth of experience as the largest contaminated land and remediation consultancy in the UK. We have responded to the EA with our comments on the draft guidance.
The LCRM’s purpose is to offer guidance on “How to assess if there’s unacceptable risk, decide which options are the most suitable to manage the risk and implement remediation if needed”. It is based on CLR11 – Model Procedures for the Management of Land Contamination, published in 2004, which will be withdrawn in December 2019.
The EA emphasises that the LCRM’s scope, framework and purpose remains the same as that of CLR11. So, what has changed? One thing that was immediately apparent during our review was that the guidance is less process based; instead it places greater emphasis on the competency of those undertaking land contamination assessments. This can only be a good thing: ensuring that risk assessment and remediation works are done to the highest of standards by only the most capable and most experienced individuals and businesses will contribute towards mitigating risk.
RSK’s ongoing dedication to the training and continuing professional development of its employees will ensure that it can deliver to and above these high competency requirements, something that it has already been doing. RSK has developed and maintains a competency matrix to demonstrate staff competencies in core and technical skill areas within geosciences. This informs our continuing professional development plans and annual performance reviews. It also ensures that the most appropriate and suitably qualified employee is selected for any project role.
One example of LCRM’s greater emphasis on competency is through the many references to the National Quality Mark Scheme for Land Contamination Management (NQMS). The NQMS, launched in 2017, is a voluntary scheme developed by the National Brownfield Forum (formerly known as the Land Forum) that aims to expedite the land development process and improve the quality of advice provided about land contamination.
While the LCRM provides guidance on how to assess risk relating to land contamination, the NQMS Quality Mark shows that a contaminated land report has achieved a certain standard of quality. Key to this is sign-off of reports by a Suitably Qualified Person (SQP). RSK strongly supports the NQMS, which is shown by the fact that it has the largest number of SQPs of any organisation, currently 13. RSK also has a large number (currently 11) of Society of Brownfield Risk Assessment (SoBRA) risk assessors able to support the SQPs in technical reviewing complex land contamination risk assessments, as well as over 50 chartered professionals in the geosciences team alone.
Overall, we believe that the LCRM is a significant step forward for land contamination management. It reflects the present-day key concerns of the industry: ensuring the highest level of competency and making sustainability an integral part of the process. We look forward to seeing the final, revised guidance once the consultation period is over.
If you require more information or advice on land contamination assessment and management, specifically the LCRM, NQMS, SQPs or SoBRA risk assessors, please contact Tom Henman, firstname.lastname@example.org, +44 (0)141 418 0471, or Joanna Wilding, email@example.com, +44 (0)1332 542753.
RSK is the UK’s leading integrated environmental, engineering and technical services business, providing multidisciplinary services across the UK and worldwide. Since 1989, we have been helping organisations across the world realise their business goals efficiently, cost-effectively and with the minimum of environmental and social impact.