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Posted By Steve T.
My query is, should Waste Management Plans be issued as a separate document or as an appendix of the Construction Plan.
The term "principal contractor" is mentioned in the legislation regarding Waste Management Plans but not linked to the CDM 2007 Regulations.
Your thoughts are welcomed
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Posted By Robert K Lewis
Steve
Although the plan must be implemented by the start of the construction work I tend to see it as a separate entity. You do need to update the information throuout the job and for lager jobs review it within 3 months of completion. The CPP should however refer to it.
I think clients will ask CDMCs to check it is in place together with the CPP as the client and contractor commit an offence if it is not in place at the start of construction.
Bob
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Posted By Smiff
It really doesn't matter how you structure the documents. I have asked both DEFRA and the EA and they have no preference or even care particularly. What is frustrating is that if you already have this info in another form (in our case as part of mobile treatment licencing) DEFRA want you to duplicate it! We are looking at how to absorb these requirements into our system with the minimum of additional work. Our CPHSPs are set up in sections with some blanks at the back so for bigger jobs we can easily slot in a SWMP, it gives it a convenient home and brings it under existing document control.
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Posted By Martin Mulholland
Steve,
Site Waste Management Plans (SWMPs) is not an explicit legal requriement yet - it is only implied by the ACoP to the Construction (Design and Management) Regulations 2007.
It is expected to become legally required under the Clean Neighbourhoods and Environment Act 2005 (expected Spring 2008).
More details can be found at:
www.netregs.gov.uk
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Posted By Smiff
They are a legal requirement in ENGLAND for jobs over £300k
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Posted By Steve T.
Thanks All
There is clearly uncertainty about the location of the SWMP and will i suppose in due course be detemined by the EA/HSE/others.
The APS seem to believe that the SWMP belongs in the Construction Plan and IOSH Technical have sent me the Construction Plan contents and did not answer my question!
Ultimately, the courts may determine the answer.
If the common or indeed legal view is that it belongs in the Construction Plan, then it would become interesting in that both 2 enforcing authorities, EA and HSE could take an interest in the plan!
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Posted By Robert K Lewis
Local authorities and EA enforce not the HSE. It for me is more sensibly kept separate from the CPP and will be much easier to maintain that way.
Bob
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Posted By Bob Youel
CDM and CN&EA are two separate laws so do not forget that
Putting both systems into one plan [as I have done] is not a problem - getting clients to understand and pay is quite another and getting a CDMC [a post that is not recognised in CN&EA] who is also competent re env areas is not easy
Enforcers will not bother how you arrange things; two separate plans or one combined plan, as long as the plans are suitable and sufficient and competent people are in place
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Posted By Tony abc jprhdnMurphy
This troubles me somewhat. as stated before I cannot get excited about the environmental issues even though health & safety is bed fellow. Can anybody recommend a decent course that may light thge fire, tailored to construction waste if preferable?
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Posted By Martin Mulholland
SJA
Thanks for that - I didnt realise they were in place yet!!
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Posted By Bob Youel
As I know it there are no courses readily available that join both the CDM and CN&EA laws together especially re SWMPS / H&S plans other than the ones that I and a small group of colleagues present to groups in the N-West - fellow members please correct me especially re courses etc that are readily available by training companies
Talking to many HSE and EA professionals recently all expressed that they have very limited grounding re the other's areas, although I am lead to believe that this is being tackled
I do like the EA's way of working and their attitude
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Posted By Robert K Lewis
I am having to prepare the courses from scratch for our clients. It really depends on the background knowledge - without a reasonable knowledge of waste maangement the contact hours are around 6.5 for a half decent assist.
Bob
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