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Fortnightly Bulletin – 1st July 2024

1 July 2024



Using unbound incinerator bottom ash aggregate (IBAA) in construction activities: RPS 247  

This Regulatory Position Statement (RPS) applies if you use unbound municipal IBAA in certain construction activities. The RPS also covers storing of IBAA for later use.  

Unbound IBAA includes IBAA in hydraulically bound mixtures (HBMs). A HBM is where IBAA is mixed with water and a binder, such as cement, to form a mixture which then sets.  

This RPS does not apply to any other activity, even if it is under the same legislation. You may still need other permits or licences for other activities you carry out.  

This RPS does not change your legal requirement to get an environmental permit for waste and groundwater activities when you use IBAA in: 

  • building a road sub-base, 
  • building a construction or structural platform, 
  • pipe bedding. 

However, the Environment Agency (EA) will not normally take enforcement action against you if do not comply with these legal requirements provided the activity meets the description set out in this RPS and you comply with the conditions set out in the RPS. 

In addition, your activity must not cause (and is not likely to cause) pollution of the environment or harm to human health, and you must not:  

  • use, or supply for use, IBAA underneath any residential building or garden, 
  • store IBAA for more than 6 months before use, 
  • cause a risk to water, air, soil, plants, or animals, 
  • cause a nuisance through noise or odour, 
  • adversely affect the countryside or places of special interest. 

All aggregate products must comply with the standard BS EN13242 or any revision of that standard. You need to pay for this standard.  

Conditions to comply with 

Using IBAA may produce hydrogen so appropriate safeguards must be taken.  

You must:  

  • follow the hydrogen safeguarding guidance in the material safety data sheets, 
  • comply with the guidance on disposing of business or commercial waste, 
  • comply with hazardous waste controls if you identify these wastes, 
  • store unbound IBAA safely and securely, 
  • keep records for two years to show that you have complied with this RPS, 
  • make these records available to the EA on request.  

You must not store or used IBBA within a groundwater source protection zone one or two, or within 50m of any spring or well, or any borehole used to supply water, including private water supplies.  

For the purpose of this RPS a surface water body is a relevant territorial water, coastal water or inland freshwater as defined by the Water Resources Act 1991. 

The EA will withdraw this RPS by the 31st of January 2025. You will need to check back then to see if the RPS still applies or you need to apply for an environmental permit or take appropriate alternative action.  

Source: Gov.UK 

For the full guidance, click here.  

Articles of Interest

Chartered Institution of Waste Management (CIWM) sets out ten ‘policy asks’ for next UK government 

The CIWM has reviewed the Department for Environment, Food and Rural Affairs (DEFRA) ‘Resources and Waste Strategy for England’ to determine its ongoing relevance, and to identify any policy gaps where it fails to support the UK’s future requirements. 

CIWM’s recommendations are split into those which should be prioritised in the first two years of the new government, and those which can be developed in the following three to five years of the term. 

Source: FMJ 

For the full article, click here  

Aldi introduces recycled plastic to crisp packs in UK supermarket first  

Aldi is rolling out recycled plastics to its own-brand label crips packaging in a UK supermarket first. 

The change will see Aldi incorporate a minimum of 35% recycle content across its specially selected hand cooked range nationwide. Aldi’s own-label popcorn and lentil chips are set to follow towards the end of the year.  

The move is expected to eliminate 78 tonnes of virgin plastic from use annually and forms part of Aldi’s grocer’s target to include 50% recycle content into its plastic packaging by 2025. 

Source: Grocery Gazette 

For the full article, click here  

Jacob’s cream crackers cut plastic packaging by 78%  

Pladis, the global snacking company, are in partnership with sustainable packaging manufacturer DS Smith. They have changed the packaging across its Jacob’s Cream Crackers boxes to reduce plastic by 78%.  

The new packaging, which is made from sugarcane pulp and lined with polyethylene film, is set to save 346 tonnes of plastic a year. 

Source: Grocery Gazette 

For the full article, click here  

Previous enforcement action

Supermarket supplier fined 29K for ‘appalling’ pollution

This article is a reminder of the risks the food and drink industry face if they get it wrong. This article was published on 9th December 2021. 

A ‘disgraceful’ supermarket cheese supplier was fined £29,000 for contaminating a river with slurry. 

The company, which sold to various supermarkets, let manure from its farm in Bristol run into the Congresbury Yeo in June 2019. The leak continued throughout July, despite environment officers visiting the farm three times. Two months later, it contaminated the same stretch of the river after spreading pig slurry on nearby fields. 

For the full article, click here 

Enforcement taken against packaging company   

This enforcement goes back to April 2020 and is a reminder to those in the packaging sector the risks when things go wrong. 

The offence was operating without or other than in accordance with an environmental permit, water discharge activity. Unauthorised discharge of printing ink and pollution of a tributary of the River Ouse, Huntingdon, Cambridgeshire in April 2020. 

The packaging company was required to: 

  • Update its induction process and training. 
  • Provide training for existing staff and install new signage. 
  • Install a waste ink treatment system. 
  • Reimburse clean-up costs. 
  • Cover the Environment Agency’s costs. 

The packaging company also contributed £20,000 to Little Ouse Headwater Project. 

For the full enforcement undertaking accepted by the EA, click here 


Environmental Monitoring Solutions (EMS) led and CITB accredited: Site Environmental Awareness Training Scheme (SEATS)   

Delivered in-house at customer sites or remotely over two consecutive days  

EMS provide CITB accredited training on site environmental awareness, ideal for construction site managers, supervisors, and foremen.  

The course topics are:  

  • Environmental impacts and the issues associated with construction activities.  
  • Sustainability.  
  • Environmental management systems.  
  • Waste management.  
  • Pollution prevention and contaminated land.  
  • Water management.  
  • How to be a good neighbour.  
  • Being a responsible contractor.  


To register, click here   

Plastic Free July 

1st to 31st July

The Plastic Free Foundation are running a ‘Plastic free July’. This is a global movement that helps millions of people be part of the solution to plastic pollution.   

Sign up for the various online ideas and challenges and what others are doing to reduce plastic use. 

Source: Plastic Free Foundation 

To sign up, click here   

CIWM – Reviewing simpler recycling for local authorities  

10th July, 12.30 – 13.30 BST online

Non-member £20.00+VAT 

Local authorities are required to make numerous changes as part of the Simpler Recycling Reforms across England. Key stakeholders will share their experiences and expertise and discuss what changes are planned for local authorities and what has been implemented so far with the upcoming deadlines. 

The online seminar will include:  

  • The latest update on government announcements to the reforms, including New Burdens Funding.  
  • Meeting the deadline for new household waste collections – where to begin? 
  • Reviewing data and patterns to leverage insights for Simpler Recycling next steps and behaviour change requirements. 
  • How to drive behaviour change with all market segments. 
  • Where clearer guidance is still required to help with implementation. 

Source: CIWM 

To register, click here  

Working with technology for a circular economy 

14th August, 12.30 – 13.15 BST online  

This webinar will look at where the resources and waste sector currently sits, from a technology adoption perspective, and what this means for the circular economy.  

The webinar will include: 

  • How we can push to drive change internally through technology innovation vs waiting for policy and legislation to lead the way. 
  • The great progress that has been made thanks to machine learning and AI. 
  • How the sector can gain more advantages and opportunities from these technologies.  

Source: CIWM 

To register, click here. 

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