The Environment Agency has recently published (June 2019) an update to the Model Procedures for the Management of Contaminated Land (CLR11), that underpinned the remediation of contaminated sites since it was first issued 2004.  The new update is known as Land Contamination: Risk Management (LCRM).

Practically all contaminated land in the UK (and in Ireland who adopted the UK model), was done on the principles set out in CLR11.  In 2016 the UK government commenced their smarter guidance project which should have seen CLR11 being archived.  CLR11 was however too widely used and reference to suffer this fate.

Whilst the scope, purpose and framework of CLR11 remains largely the same, LCRM brings it up to date in a more accessible format.  All practitioners dealing in contaminated land should become familiar with the new guidance.   CLR11 will be shelved in six months.

The original CLR11 guidance was a technical framework for applying a risk management process in dealing with sites affected by contamination.  In broad terms, it set out a model of identifying, making decisions on, and taking appropriate and measured action to deal the issue in a consistent way that is in line with current policies, standards and legislation.

CLR11 had three parts:

  • Procedures – The Risk Management Process
  • Supporting Information – Technical Detail to Support the Process
  • Information Map – Sources of Further Information.

This provided a hierarchy of information to assist stakeholders involved in dealing with contamination including landowners, developers, professional advisors, regulatory bodies and finance providers.

LCRM is designed to be a more user-friendly both for experienced practitioners and first-time users. It sets out what types of reports are required, and the information that should be included.  It also references some external industry guidance such as the LQM/CIEH S4ULs (for assessing human health risks), and also the CL:AIRE WALL (Water and Land Library).  In addition, there are links to relevant standards such as BS5930 and the CIRIA guidance.

It is important to note that LCRM requires that a Suitably Qualified Professional (SQP) must produce the relevant reports.  An SQP must for example

  • have a recognised relevant qualification
  • have sufficient experience with risk management and the type of contamination you’re dealing with
  • be a member of a relevant professional organisation

Conor Armstrong, Managing Director of Avada Environmental notes that “On occasion, individuals who did not meet the criteria of an SQP were operating in the Contaminated Land industry. Hopefully, the adoption of LCRM will see an end to this.  For too long, stakeholders have suffered from poor decision making based on a lack of technical understanding resulting in failed remediations.