CITB Managers Environmental and Waste Management 2 — Questions and Answers
Question 1: A construction site is adjacent to a watercourse. Under the Environmental Permitting (England and Wales) Regulations 2016, what offence would be committed if site run-off containing silt enters the watercourse?
- No offence, as silt is a natural material
- Causing or knowingly permitting a water discharge activity without an environmental permit (Correct answer)
- Only an offence if the silt is contaminated with chemicals
- Only an offence if the Environment Agency has previously issued a warning
Correct answer: Causing or knowingly permitting a water discharge activity without an environmental permit
Under the Environmental Permitting Regulations, it is an offence to cause or knowingly permit a water discharge activity (including discharging polluting matter into inland freshwaters) without an environmental permit or exemption. Silt-laden run-off is a pollutant that can cause significant ecological harm to watercourses.
Question 2: What measures should a construction site manager implement to prevent pollution of nearby watercourses?
- Only erect warning signs near the watercourse
- Install silt fences or settlement ponds, maintain spill kits, implement a surface water management plan, and brief all workers (Correct answer)
- Only prevent oil spills — other run-off is acceptable
- Rely on natural filtration through the ground
Correct answer: Install silt fences or settlement ponds, maintain spill kits, implement a surface water management plan, and brief all workers
Effective pollution prevention requires multiple measures: silt fences, settlement lagoons or tanks, wheel washing, covered material storage, spill kits and drip trays, a surface water management plan, designated refuelling areas away from drains, and worker training. The approach should be proportionate to the risk identified in the site-specific risk assessment.
Question 3: Under the Site Waste Management Plans Regulations (now repealed but considered good practice), what is the main benefit of maintaining a site waste management plan on a construction project?
- It is only useful for meeting planning conditions
- It helps plan waste management, reduce waste volumes, improve recycling rates, ensure legal compliance, and reduce disposal costs (Correct answer)
- It is only needed for projects over £300,000
- It has no practical benefit since the regulations were repealed
Correct answer: It helps plan waste management, reduce waste volumes, improve recycling rates, ensure legal compliance, and reduce disposal costs
Although the Site Waste Management Plans Regulations 2008 were repealed in 2013, maintaining a SWMP remains industry good practice. It helps forecast waste types and quantities, plan for segregation and recycling, ensure compliance with duty of care requirements, demonstrate due diligence, and typically reduces overall waste disposal costs.
Question 4: A construction manager needs to dispose of fluorescent light tubes removed during a refurbishment project. How should these be classified and disposed of?
- As general waste — they can go in a skip
- As hazardous waste due to mercury content — they must be handled, stored and disposed of through a hazardous waste route (Correct answer)
- As recyclable glass — they can go in the glass recycling skip
- They can be disposed of in any electrical waste container
Correct answer: As hazardous waste due to mercury content — they must be handled, stored and disposed of through a hazardous waste route
Fluorescent tubes contain mercury, a hazardous substance. They are classified as hazardous waste under the List of Wastes (EWC code 20 01 21*). They must be stored safely to prevent breakage, collected by a licensed hazardous waste carrier, and accompanied by a consignment note. Specialist recycling facilities recover the mercury and glass.
Question 5: What is the maximum period that hazardous waste can be stored on a construction site before it must be removed, without requiring an environmental permit?
- No time limit
- 6 months if producing less than 500 kg, or 12 months if registered as an exempt site (Correct answer)
- 30 days
- 3 months
Correct answer: 6 months if producing less than 500 kg, or 12 months if registered as an exempt site
Under the Environmental Permitting Regulations, construction sites can temporarily store hazardous waste under a waste exemption. The storage duration depends on the quantities: sites producing less than 500 kg of hazardous waste can store it for up to 6 months, while registered exempt sites may store for up to 12 months, subject to conditions.
Question 6: Under the Environmental Damage (Prevention and Remediation) Regulations 2009, who can be held liable for environmental damage caused by construction activities?
- Only the waste carrier
- The operator responsible for the activity that caused the damage (Correct answer)
- Only the landowner
- Only the Environment Agency
Correct answer: The operator responsible for the activity that caused the damage
The Environmental Damage Regulations implement the EU Environmental Liability Directive. The 'operator' responsible for the activity that caused or threatened environmental damage is liable for prevention and remediation costs. This could be the contractor, subcontractor, or any party whose activity directly caused the damage.
CITB Managers Environmental and Waste Management 2
A construction site is adjacent to a watercourse.
Under the Environmental Permitting (England and Wales) Regulations 2016, what offence would be committed if site run-off containing silt enters the watercourse?