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Interesting that you use the example of possibly one of the lowest risk ACM’s, bitumen adhesive.

And it is not avoiding the central issue discussing “technicalities”:

1. Can you legally crush material contaminated with ACMs? The terms of a Standard Rules Environmental Permit prohibit this. Will the EA allow it if you ask permission? Possibly, possibly not.  It’s a SR EP for a reason…

2. Will aggregate contaminated with asbestos meet the requirements of the Aggregate Protocol such that it is not a waste? Possibly not. Still, it’s possible for the EA to issue a permit for its use/disposal. How many house builder clients want that burden?

3. If such contaminated material is reused at depth, under dwellings, gardens, public open space, hard top, does the developer have an ongoing duty to inform, by flagging on deeds, etc.? Many developers don’t want the risk/hit on bottom line and state “no asbestos”…

4. EA’s position is that if material has to be ‘capped’ in order to break a significant pollutant pathway, this is a ‘disposal’ operation, which requires a Permit…

5. Are you going to use a U1 expemption? Criteria apply: strict waste codes/prohibited materials, e.g. 170107 Mixtures of concrete, bricks, tiles and ceramics not containing hazardous substances, compliance with the Aggregates Protocol, Planning Permission…

The regulatory landscape is fraught, and the outcome often depends on where in the country you are.

I wrote a report for a house builder justifying reuse of SOILS with residual free fibre concentrations at low level below dwellings, gardens and POS, according to certain design criteria. It was accepted by planning and the CLO at the Local Authority.

At the same time, another CLO/different LA refused another house builder permission for reuse of similar materials AFTER the development had incorporated them at depth. The house builder agreed to retrospectively remediate the development by removal/replacement, at significant cost.



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