Waste management or construction activity?
By Terry Quarmby19 March 2008
What we do find, as an industry sector, is that we are expected to fulfil the desires of sustainability and those expectations dictated by national governments, non–governmental organisations and our clients alike. In so doing we often need to change our methodology. The demolition industry has never had a glamorous side, although the fascination created by the reduction of a structure is plain to see, particularly when the works are carried out in busy city or town centres. What the public, and sometimes our clients, see is a spectacular collapse of a structure. What they don't always appreciate is the process that is carried out before that stage. To the practitioner, the ‘knocking’ of a building is the easy part, it is the strip out, and where appropriate, the preweakening that is the hardest or most involved. To those of us that have spent endless hours stripping out a large complex and managed the removal and movement of heavy volumes of waste materials, will be the realisation of the effort required to perform large scale logistical exercises. Add to this the growing legislative, regulatory and monetary constraints to which the contractor is exposed, and one can begin to appreciate that the act of demolition has little or no affinity with that described within a dictionary. Equally, it has little bearing from a purists point with construction. It is in fact moreakin to waste handling, removal, processing and disposal. In other words it is very definitely a process of waste management.
Nowhere is this better highlighted than in case law. A close relative of demolition is the scrap metals sector. In 1999 the UK's Environment Agency (EA) decided to make an example of Meyer Parry Recycling Limited and pushed for the licensing of the scrap recovery process under the Waste Management Regulations 1994 and subsequently the Waste Management Licensing Regulations 1994. The judge who found in favour of the EA declared; “Accordingly, materials which are to be reused, but whichdo not require any recovery operation before being put to their new use, are not treated as waste. Similarly, materials which are made ready for reuse by a recovery operation cease to be waste when the recovery operation is complete.”2 If one were to extrapolate on this rule and substitute the act of demolition to incorporate soft strip, materials handling, recovery or wholesale strip out for scrap metals recovery, is there really an difference. Plainly, there isn't and on must wonder when the EA will decide to tackle a demolition contractor under this ruling. The majority of materi handled on ademolition site will fall un the classification of ‘directive waste controlled waste.
According to Schedule 4 to the Wa Management Licensing Regulations 1994 a substance or object should be regar as ‘directive waste’ if it has been disca by the holder or he intends to/is requ to discard it and that by discarding will make the substance fall out of the no commercial cycle or chain of utility. Lo at this from a practical angle, I would sa if our client no longer wanted his bu and its contents, then that structure a that went with it would constitute a was as such would fall within the scope for management licensing!
What of the future
To some of you reading this article it was no surprise that I am talking this wall, it is not as if we have not already a question of the EA, it is just that they have not given us a straight answer. At a fairly recent seminar of the UK's Institute of Demolition Engineers, which took place at 1 Great George Street, London, Mr Crouch, a guest speaker from the EA, was asked point blank as to whether or not there was any intent to bring demolition activities under waste licensing. His answer was that he was not aware of any such move in the near future. Neither did he rule it out altogether!
There is a ground swell of opinion within the industry that some form of licensing regime is inevitable as we edge ever closer to becoming a full waste management process. Both the demolition sector and the waste sector are small. With around 160,000 employed in the waste industry and a little under 11,000 people in the demolition industry in the UK, combined we would only reach 17% of the number employed in the UK's construction industry.3However, legislation and regulation for the waste sector can be seen to be just as prolific about everything. As building projects changed and we moved towards mechanical demolition, materials recycling slumped. Today, it is a struggle to move all but the traditional materials unless there has been a large capital investment made in purpose built recycling centres and transfer stations. I have no doubt that those within the industry that have made this move will find that the benefits are rewarding but that the skills needed to manage that process successfully bear no similarity to those used in the past.