The construction (design and management) regulations (CDM) require that the designer identifies all health and safety risks of a project, both during construction and in use. It is the responsibility of the designer to design out risks. Any residual risks are highlighted in a health and safety plan which is included in the contract documentation supplied to tenderers. The successful contractor is required to produce method statements detailing how these residual risks will be safely managed.
The CDM process will cover environmental risks which also pose a risk to human health and safety. The principle should also be applied to other environmental risks.
Most pollution incidents should therefore be avoided. Careful planning, a sensible site management, and caring how wastes are removed from the site can substantially reduce the risk. In this way, building operations can be part of a sustainable approach to development.
| Most measures to prevent pollution cost very little, especially if incorporated during the planning of a development.
Also, pollution prevention and waste minimisation can offer substantial economic benefits:
- Reduced need for expensive raw materials
- Fewer site accidents
- Reduced risk of prosecution for environmental offences
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Do Not Pollute
© HMSO |
Understand Pollution and Plan to Control It
The extent, intensity and type of existing pollution will vary across the site. Before planning the development, it is important to identify areas where remediation will be necessary, and also where the least sensitive land uses, such as parking, are best located.
Start with understanding - so that everyone on the site knows and cares about reducing pollution risk. CIRIA and the Environment Agency have produced a video to help with training Please see sources of info at the bottom of this page.
Understand and Manage Your Environmental Impacts
There is a wealth of ideas and techniques that can make this easier:
- Contact the Environment Agency
- Check suppliers and contractors environmental credentials and introduce policies and systems to manage them positively
- Join a 'Considerate Constructors' scheme
- Use the model Code of Practice on particulate emissions, prepared by the Building Research Establishment, to help control particle emissions from construction activity and reduce their impact on human health and the local environment.
Environmental Management Systems (EMS), such as ISO 14001 and the Eco-Management and Audit Scheme (EMAS), allow accurate monitoring of environmental impacts throughout the supply chain, and help to identify mechanisms for reducing them. Although some businesses have been reluctant to seek formal agreement, any major site can benefit from these systematic approaches.
Contaminated Land
As discussed in
Think About the Whole Place, the new contaminated land regime requires developers to submit remedial proposals to the district council for approval. The district council will normally consult with the Environment Agency, and the developer should take the comments of both these bodies into account when designing the remedial measures.
Site Drainage
Groundwater is particularly vulnerable to pollution and it is generally impossible to restore the quality of polluted groundwater. Specialist advice should be sought from the Environment Agency concerning vulnerable locations.
In developed areas, rivers, streams, ponds and groundwater, are among the aspects of the environment most vulnerable to pollution from building works. So any construction site needs planning to identify the precautions to ensure the complete protection of watercourses and groundwater against pollution.
If a watercourse actually runs through a site, extra care will be needed. Specialised advice is given in Pollution Prevention Guidelines 5 'Works in, near or liable to affect watercourses', by the Environment Agency. An on-site meeting should be held with local EA Officers before the project begins, and regularly throughout. The advice given, both before work starts and during the operations, may prevent serious problems arising.
In developed areas it is likely that there will be two types of drainage from a site - surface and foul. Good practice is for manholes on site to be colour coded, for example using blue for surface water and red for foul. It may seem an obvious point, but on a surprisingly large number of sites, simple mistakes and lack of thorough assessment result in foul water being discharged into fresh water streams.
a. Surface Water
The surface water drain is designed to carry uncontaminated rainwater directly to a local stream, river or soakaway. In some cases this may be some distance from the site. Nothing which could cause pollution, including silty water, should enter the surface water drains.
b. Foul Water
The foul water drain carries domestic sewage and trade effluent to a sewage works for treatment, before discharge to a watercourse or soakaway. All connections or discharges to the foul sewer require the approval of the sewage undertaker or water company (NWL). Where no foul sewer is available, alternative arrangements will be necessary for sewage disposal. Please see Sources of info at the bottom of this page - Pollution Prevention Guidelines 4.
Dealing with Silty Water The water running off a site will contain dust and silt unless very carefully managed.
Always ensure that adequate provision for dealing with silty water is included in the site working plan.
All discharges off the site will require approval. | |
Where possible, discharge to the foul sewer. Discharges to streams, watercourses or soakaways must have the approval of the Environment Agency, which should be obtained well in advance, (a Discharge Consent can take up to 4 months to obtain, or even longer for difficult cases). Suitable treatment will be required, which could involve the use of a settlement lagoon, a tank or a grassed area.
Water containing silt should never be pumped directly into a river, stream or surface water drain. Silty water can arise from excavations, exposed ground, stockpiles, plant and wheel washing and site roads:
- Excavations: where possible prevent water from entering excavations. Use cut-off ditches to prevent entry of surface water and well point dewatering or cut-off walls for ground water. Use the corner of the excavation as a pump sump and avoid disturbing that corner. Do not allow personnel or plant to disturb water in the excavation.
- Exposed ground and stockpiles: minimise the amount of exposed ground and stockpiles. Stockpiles can be seeded or covered and silt fences constructed from suitable geotextiles may be useful.
- Plant and wheel washing: wheel washes and plant washing facilities should be securely constructed with no overflow and the effluent should be contained for proper treatment and disposal.
- Site roads: these should be regularly brushed or scraped and kept free from dust and mud deposits. In dry weather dust suppression measures may be required.
Basic Site Management
A lot of what is required to avoid pollution is little more than common-sense site management, but it is surprisingly often ignored.
How contractors handle and dispose of site waste is not only important for the environment - it is also increasingly subject to the law. Design for Minimum Waste deals with the general issue of waste management. For the construction industry, it is particularly important that noise and dust emissions should be minimised, and that builders do not burn waste on site, as this will cause both pollution and annoyance to neighbours.
The following items provide a check-list of issues:
- Refuelling: the risk of spillage is at its greatest during refuelling of plant. Where possible, refuel mobile plant in a designated area, preferably on an impermeable surface and away from any drains or watercourses. Keep a spill kit available. Never leave a vehicle unattended during refuelling, or allow staff to jam open a delivery valve. Check hoses and valves regularly for signs of wear, and ensure that they are turned off and securely locked when not in use. Diesel pumps and similar equipment should be placed on drip trays to collect minor spillages. These should be checked regularly and any accumulated oil removed for disposal.
- Concrete: concrete is highly alkaline and corrosive and can have a devastating impact on watercourses. It is essential to take particular care with all works involving concrete and cement, especially if working near a river, stream or surface water drain. Suitable provision should be made for the washing out of concrete mixing plant or ready mix concrete lorries. Such washings must not be allowed to flow into any drain or watercourse.
- Emergencies: in the event of a spillage on site, the material should be contained (using an absorbent material such as sand or soil or commercially available booms), and the Environment Agency should be notified immediately.
- Deliveries: special care should be taken during deliveries, especially when hazardous materials are being handled. Ensure that all deliveries are supervised by a responsible person; that storage tank levels are checked before delivery to prevent overfilling; and that the product is delivered to the correct tank. Put in place a contingency plan and suitable materials to deal with any incident. Ensure that employees know what to do in the event of a spillage. If properly dealt with, a spillage need not result in pollution.
| | Typical pollution sources:
- Landfill gases
- Vehicle emissions
- Industrial fumes
- Dust and litter
- Road salts
- Oil spillage
- Contaminated surface water
- Fertilisers & pesticides
- Pollution transported through the site
- Toxic material brought onto the site during construction
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Industrial Air Pollution
© HMSO | |
Storage
Many of the materials used in construction operations, such as oil, chemicals, cement, lime, cleaning materials and paint have the potential to cause serious pollution.
All wastes must be stored in designated areas which are isolated from surface drains. Under some circumstances, for example if storing or treating material from a contaminated site, a Waste Management Licence may be required from the Environment Agency.
Skips should be covered to prevent dust and litter being blown out and rainwater accumulation, and should be regularly inspected and replaced when full. Where possible, separate skips should be provided so that wastes can be segregated for recycling, or to prevent cross-contamination. If plant maintenance is carried out on site used oil and filters should be stored in a designated bin, in a bunded area, for separate collection and recycling.
- Fuels, oils and chemicals: these must all be stored on an impervious base within a bund and secured. (ie. used oil and filters are special waste). The base and bund walls must be impermeable to the material stored and of an adequate capacity. Detailed guidelines concerning above ground oil storage tanks are available from the Environment Agency (Policy / Pollution Prevention Guidelines 2). Storage at or above roof level should be avoided. Leaking or empty oil drums must be removed from the site immediately and disposed of via a licensed waste disposal contractor.

- Security: all valves and trigger guns should be protected from vandalism and unauthorised interference, and should be turned off and securely locked when not in use. Any tanks or drums should be stored in a secure container or compound, which should be kept locked when not in use. Bowsers should be stored within site security compounds when not in use.
- Marking: the contents of any tank should be clearly marked on the tank, and a notice displayed requiring that valves and trigger guns be locked when not in use.
- Removal: before any tank is moved or perforated at the end of a contract or particularly during demolition works, all contents and residues must be emptied by a competent operator for safe disposal.
Pipes may contain significant quantities of oil or chemicals, and should be carefully drained and then capped, or valves closed, to prevent spillage.
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Waste Disposal
Under the Duty of Care, the waste producer has a duty to ensure that the waste contractor who removes the waste is registered with the Environment Agency.
| A written description of the waste must be given to the contractor.
A more rigorous Consignment Note system applies to certain hazardous wastes. (Special Waste Regulations) | 
Polluted Open Space as a Result of Fly Tipping. © HMSO |
Noise Pollution
Noise can have a significant effect on the quality of life of both neighbours and employees, and on the tranquillity of the wider countryside. Noise pollution can arise from both the construction and operational phases of a development, and can include the noise of machinery, site operations, traffic and alarms. Noise levels may be the subject of planning conditions, and local authorities have additional powers to control it under The Environmental Protection Act 1990 (Part III) and the Control of Pollution Act 1974 (Part III).
Advice on the control of noise can be found in the Code of Practice on Noise Control on Construction and Open Sites (BS5228) HMSO 1984 and 1986 and from the Environmental Health departments of local authorities.
Effects of noise arising from the construction or use of the development need to be the subject of a detailed assessment where significant impacts are likely to arise.
Plan to minimise noise through good design by:
- maintaining adequate distances between noisy operations and noise sensitive areas
- making best use of the acoustic screening properties of natural topography or existing buildings
- using quieter machinery or quieter methods of working
- containing noise by insulating buildings or using acoustic barriers
- protecting surrounding noise sensitive properties where necessary by installing improved sound insulation
Manage the site to minimise noise by:
- specifying, monitoring and enforcing acceptable noise limits
- controlling the time when noisy operations take place
- restricting the kinds of activities allowed on the site
- minimising traffic flows to, from and around the site
- making sure plant is well maintained
Light Pollution
Artificial lighting, if not properly controlled, can be both wasteful of energy and have a serious impact on the quality of life of neighbours, the tranquillity of the countryside, the darkness of the night sky, and the ecology of the surrounding area. Issues include:
- Sky glow - the cumulative effect of lighting on the night sky which loses its darkness and with it our ability to see stars and planets.
- Glare - the brightness of intense light that is uncomfortable to look at and creates excessive contrast that can reduce both safety and security.
- Light trespass - the spilling of light beyond the site boundary which may make it difficult for neighbours to sleep. These impacts can often be avoided through good lighting design - which will also very often save money.
Advice on the control of light pollution can be found in Lighting in the Countryside: Towards Good Practice (DETR) and the Institution of Lighting Engineers' Guidance Notes for the Reduction of Light Pollution. The Chartered Institution of Building Service Engineers (CIBSE) produce Lighting Guides which give recommended illuminance levels for a variety of applications and guidance on good practice.
Consider the effects of light at the planning and design stages, and in particular:
- consider whether lighting is necessary at all, and if it is, where it is needed and why
- look for opportunities to reduce the need for lighting by; for example, separating vehicles and pedestrians or; introducing traffic calming measures - or using CCTV instead of security lighting
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- adopt limits for the level of illumination appropriate to the wider setting of the development - refer to the Institution of Lighting Engineers Environmental Zones.
Design lighting schemes to minimise pollution by:
- not exceeding the level of illumination required for any given application - refer to published standards
- using low intensity lights to reduce glare and dark spots - softer & more uniform light is often better for security and safety
- directing light downwards rather than upwards - where uplighting is essential use shields and baffles to reduce spillage
- choosing efficient and well designed luminaires which direct light to where it is needed and reduce spillage and glare
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- installing luminaires carefully to reduce glare - keep the angle of any main beam below 70
- only switching lighting on when it's needed - consider a 'curfew' on lighting between certain hours when some lighting can be switched off or overall levels reduced
- keeping decorative architectural uplighting to a minimum - consider using only on special occasions and keeping it understated
- using low pressure sodium lamps where colour resolution isn't an issue
- thinking about views from the wider countryside and making best use of the screening properties of topography, vegetation and buildings
- using motion sensors to switch lighting on - for security lighting these should be set to the minimum time period & adjusted to avoid tripping by cars or animals

Cleaning Up After Flood Damage
© Environment Agency
Rules of Thumb
Sources of Info
- Waste Management - The Duty of Care: A code of practice
- Building a Cleaner Future, training video pack
- Pollution Prevention Guidelines 1: General guide to the prevention of water pollution, The Environment Agency
- Pollution Prevention Guidelines 2: Above ground oil storage tanks, The Environment Agency
- Pollution Prevention Guidelines 4: Disposal of sewage where no mains drainage, The Environment Agency
- Pollution Prevention Guidelines 5: Works in, near or liable to affect watercourses, The Environment Agency
- Industry Profiles, DTLR Publications Sales Centre
- Pollution Prevention Guidelines 6: Working at Construction and Development Sites, The Environment Agency
- Pollution Prevention Guidelines 8: Safe storage and disposal of used oils, The Environment Agency
- Pollution Prevention Guidelines 20: Dewatering Ducts and Chambers, The Environment Agency
- Pollution Prevention Guidelines 23: Maintenance of Structures over water, The Environment Agency
- Planning Policy Guidance 24: Planning and Noise
- Waste Minimisation and Recycling in Construction - A site handbook
- Managing materials and components on site, CIRIA
- Choosing Cost Effective Pollution Control - Envirowise
Case Studies