An Analysis of Construction “Waste” Reuse Regulations
Are current legislations sufficient to achieve 21st century environmental targets?
INTRODUCTION
Having identified current issues about material transport, waste generation and greenhouse gas production; as a group we decided to propose a platform which presents a missing tool to connect providers who hold construction waste to customers who are looking for construction materials. Our development model, 0.WASTE.LAND, is UK based and works at a national level. The circular approach to reuse materials considered as “waste” avoids unnecessary import, transportation and production; benefiting the environment. The platform connects designers, contractors, architects and builders by providing a service to exchange recycled materials and reuse waste materials.
To achieve an efficiently working platform one of the most important aspects is to analyse and apply current regulations related to reuse of construction materials. This is to assure the products accomplish necessary material qualities in prospective projects. Therefore, the essay initially looks at the development of waste reuse regulations and analyses the current issues in the construction industry. Later, improvements and alternatives on the current legislations are proposed; as advancements in regulations are essential for the platform to function and fulfil its mission in the best way possible, as well as, to move a step forward in getting closer to economic, social and environmental justice.
DEVELOPMENT OF WASTE REUSE REGULATIONS
i. Waste Production
In 2015, the Department for Environment, Food & Rural Affairs (DEFRA) reported in the Digest of Waste and Resource Statistics that while efforts have been made to decrease the industry’s contribution to our waste problem, very little has been achieved. DEFRA also reported in their February 2018 edition of UK Statistics on Waste that in 2014 the UK generated 202.8 million tonnes of waste and construction; demolition and excavation was responsible for 59% of this number. Especially as 55% of the global industrial carbon emissions come from the manufacture and processing of materials, it is important to actively reuse to move away from linear production.¹ (Figure 1)
ii. Reuse Targets in the EU
The European Commission’s 2018 Circular Economy Package is an overarching policy that also covers waste legislation. The revised Waste Framework Directive (WFD) defines the waste hierarchy in waste management and establishes waste prevention as the highest priority (Figure 2). It sets clear objectives for the reduction of waste and requirements for waste management and recycling, including quantitative recovery targets to be achieved by 2020.²
iii. Reuse Regulations in the UK
There are a wide range of legislations and policies in the UK which have direct and/ or indirect impacts on construction waste management and the need to recover resources from demolition. These are broadly classified into environmental protection and sustainable construction regulations; waste management regulations, and; fiscal policies. Whilst some of the legislations and policies are voluntary standards such as Code for Sustainable Homes (CSH) for private housing, others are simply best practice and many more are a strategy document such as Waste and Resources Action Programme (WRAP), Sustainable Construction Strategy and ICE Protocol. However, a number of these waste management legislations are mandatory, some of which were originally employed under a voluntary code of practice such as the Site Waste Management Plan (SWMP).³
a. Building Regulations
The Secure and Sustainable Buildings Act 2004 has extended the scope of the Building Regulations to cover the use of recycled and re-used materials, and specifically includes a duty on the Secretary of State to report on the recycled content of buildings in England and Wales every two years.⁴ In addition, BS 8895–1:2013 creates awareness on the material selection and defines material efficiency as: “The process of undertaking a building project to enable the most efficient use of materials over the lifecycle of the building and its components. It may also include the adoption of alternative means of design/construction that result in lower materials usage and lower wastage levels including off-site manufacture and use of pre-assembled service pods.”⁵ (Figure 3)
b. Planning Policies
In 2005, ODPM’s Planning Policy Statement 1 said that: “Development plan policies ‘should seek the use of waste as a resource wherever possible” and following this recommendation, a growing number of regional and local authorities are including a requirement for recycled content in their Regional Spatial Strategies, planning policies and Supplementary Planning Documents.⁶
CURRENT BARRIERS IN REUSING CONSTRUCTION AND DEMOLITION WASTE
i. Certification and Legal Issues
Reluctance to use products without certification of tested performance is one of the biggest barriers to reuse, particularly in a structural capacity.⁷ There are difficulties for CE-marking as scope of harmonised product standards do not cover waste related materials and systems for implementation of the End of Waste concept is lacking in many countries.⁸ In addition, testing of performance can be expensive and often there is very little information on where the product has come from and its length of use in a particular application which is essential information in getting the material certified.⁹
ii. Removal of Materials
The material streams that currently arise from renovation and demolition work are an inheritance from the linear economy and are not always easy to disassemble and some, such as glued materials and spray insulation, do not allow for reuse or high-grade recycling.¹⁰
iii. Material Performance
Products manufactured from recyclables must perform as well as those made with virgin materials, or at least meet high-performance criteria. Usually, the mineral part of Construction and Demolition Waste (C&DW), when recycled, is used in rather low-grade construction materials such as non-structural concrete applications but in these utilisations, the inherent value of C&DW is lost to a great extent as their potential structural properties are not exploited. Therefore, it is important to use C&DW in high- grade products that would avoid down-cycling and follow the spirit of a circular economy.¹¹
a. Example: Concrete
High-grade concrete recycling is especially relevant as it accounts for 42% of building materials used in construction. In the production of concrete, fine and coarse aggregates, sand and gravel; cement, water and additives are mixed. Coarse aggregate obtained from demolition works can be used to partially replace natural aggregates in high-grade concrete applications. Recovery of a high-quality stony fraction for recycling sets requirements on all steps of the value chain starting from the planning of demolition activities. This requires tight quality control and new agreements between stakeholders in the value chain to guarantee high-quality feedstock from demolition activities.¹²
European standards, such as EN 206: Concrete — Specification, performance, production and conformity; and EN 12620: Aggregate for concrete allow the use of recycled materials in concrete. Their use in different applications is regulated by national standards. Up to 20% substitution of virgin aggregates with concrete waste is not considered to lower the new concrete’s properties or influence the its workability. The use of more than 50% of concrete waste triggers the need further testing to prove acceptable properties and the concrete is usually only suitable for certain applications.¹³
The main obstacle for recycling aggregates from concrete waste in new concrete is the low price of virgin materials and the processing costs of demolition waste to secure high-quality material for recycling. Concerns about the quality and potential presence of hazardous materials, such as asbestos, lead to a lack of confidence or trust in the recovered waste streams.¹⁴
b. Example: Steel
All structural steel reclaimed for reuse is to be inspected and tested. Central to the testing regime is the grouping of fundamentally identical members into groups, whereby one or more members are assumed to be representative of the entire group, thus moderating the requirements for testing. After reclamation of steel, the responsibility of the holder of the stock is to inspect every member and maintain records that include: dimensions, straightness, any loss of section, signs of damage, or plastic strain, age of the steelwork and meeting the geometric tolerances of EN 1090–2.¹⁵
PROPOSED LEGISLATIVE IMPROVEMENTS
Looking at the development of reuse regulations over the past few years and analysing the current barriers in using C&DW, it is evident that our planning and regulatory policies do not solve issues in reusing waste. Although there are some frameworks that advise for material efficiency, these are usually not mandatory and not sufficient to achieve 21st century environmental targets. Therefore, it is detrimental to carry out legislative improvements and develop services, regulations and systems that are more nature-based and promote circular economy approaches. In doing so, these improvements would also lead to the better use of our platform, 0.WASTE.LAND, by increasing the demand and awareness to reuse C&DW.¹⁶
i. Recycled Content Standard
It is important that a requirement for recycled content is clearly communicated and is fully incorporated into project operations.¹⁷ In accordance with practice adopted by leading bodies in both the public and private sectors, it should be mandatory that construction clients and developers include a requirement for a minimum amount of recycled content and a request for good practice in their project procurement.¹⁸
a. Case Study: Partnership for a Better Scotland
Following a positive response to consultation, in 2006 the Scottish Government asked all public bodies in Scotland to set a minimum requirement of 10% for recycled content in their tender specifications and contracts when procuring major construction projects, and to ask organisations which they are funding to follow the same targets. Therefore, at least 10% of the total value of materials used on a project should be acquired from recycled and reused content. Councils including Aberdeen, Glasgow, Midlothian, South Ayrshire and the Shetland Islands have already taken partnership in this and the initiative has been successfully implemented since then.¹⁹
ii. Material Performance
a. Deconstruction Strategies and Selective Demolition
Design for deconstruction is key to the circular economy yet at present, buildings are generally demolished with little thought about preserving the integrity and value of its components for reuse.²⁰ Mandatory pre-demolition and renovation audits with promotion of reuse is essential which would ideally be undertaken by an independent party.²¹
The overall aim of selective demolition is to recover high-quality (pure) material fractions for recycling or reuse. Selective demolition does not reduce the total amount of waste generated but enables the recovery of fractions for high-quality recycling. Selective demolition is closely linked to waste sorting requirements and for example Belgium, Denmark, Finland and Sweden carries legal requirements for sorting different waste fractions.²² (Figure 4)
b. Standardisation Strategies
Standardisation plays an important role in the assessment of the performance of secondary materials in products replacing virgin materials. Standardisation is often the basis for certification used in trade and business therefore it can ease for the materials to get qualified. The use of standard modules also makes constructions mobile and flexible and thus promote reuse and prolong the lifetime of products. Building information modelling can also be used more easily in this case for data tracking, including information on disassembling structures and components.²³
c. Case Study: The Steel Construction Institute
The Steel Construction Institute has developed a draft protocol proposing a system of investigation and testing to support the common reuse of structural steel. With growing pressure to think more about the impact of construction materials, as well as national and international projects that have successfully reused structural steel, the proposed protocol helps to facilitate the reuse of structural steel sections restored from existing building structures. It proposes a new system of investigation and testing to establish material characteristics, with advice for designers completing member verifications. Responsibilities are placed on the holder of salvaged steelwork, including identification, assessment, control strategies and declarations of conformity. It is founded on the principle that given the appropriate determination of material characteristics and tolerances, re-fabricated salvaged steelwork may be fabricated and CE marked in accordance with BS EN 1090.
iii. Economic and Administrative Instruments
The Landfill Tax escalator and the Aggregates Levy provide a financial incentive to use recovered materials and those with higher recycled content.²⁴ For example, to make the recycled concrete aggregates competitive with virgin materials, it is crucial to increase the market value of recycled aggregate. In some countries such as Belgium and the Netherlands, the use of concrete aggregate is made an economically attractive option through government measures including levies on virgin materials and taxes on landfilling waste.²⁵
a. Case Study: The Rebrick Project
The Rebrick Project in Denmark promotes the reuse of old bricks in facades of buildings rather than new ones which has raised interest in the country. Bricks are carefully dismantled from old buildings, sorted and cleaned. Even though the dismantling and the cleaning processes are labour intensive and increase the cost of the bricks compared to new ones; the reuse saves significant amounts of CO2 and the estimated savings in greenhouse gas emissions is on average about 0.5 kg CO2-eq per brick. The renovated bricks fulfil the technical requirements for reuse and are marketed and patented by Gamle Mursten. This project was put in place with the support of the Danish Environmental Protection Agency as it was key to have an administrative mechanism and a circular economy concept for marketing reusable bricks has been developed efficiently.²⁶
iv. Building Rating Systems
Green materials with recycled content or environmental benefits are often given credits in environmental rating systems for new or existing buildings. Examples of developed protocols are Level(s) from the European Commission and Building Research Establishment Environmental Assessment Method (BREEAM) from the UK’s BRE. The protocols can be used by investors, designers, general contractors and real estate operators for proving the sustainability of a building.²⁷ As these rating systems are voluntary they are not used widely, therefore it would be beneficial to make all or some parts mandatory.
CONCLUSION
Legislative improvements establishing recycled content standards, including standardisation, designing for deconstruction and selective demolition in regulations; as well as, enhancing economic and administrative instruments and forming mandatory building ratings are some of the key ways the barriers in reuse can be resolved. These advancements will also aid to make our platform, 0.WASTE.LAND, work in the best way possible and get closer to achieve environmental, social and economic justice. Working on the 0.WASTE.LAND development model and the Radical Practice course has definitely raised my awareness on these subjects and made me think more critically and I intend to put my learnings to practice throughout my years ahead in the architecture field.
I believe legislative instruments in C&DW can help to achieve 21st century environmental targets as they play a crucial role in the built environment and building regulations that tackle these aspects are essential. The Life Cycle approach is needed to be embraced in order to set more effective policy targets for the environment. Policies should be encouraged to move towards a Life Cycle Management, therefore achieving a sustainable management of waste within the new definition of circular economy.²⁸
¹ Jess Sharman, ‘Construction Waste and Material Efficiency’, NBS, 2018 <https://www.thenbs.com/knowledge/ construction-waste-and-materials-efficiency> (accessed 30 December 2020).
² Margareta Wahlstrom, Jef Bergmans, Tuuli Teittinen, John Bacher, Anse Smeets and Anne Paduart, Construction and Demolition Waste: Challenges and Opportunities in a Circular Economy (European Topic Centre Waste and Materials in a Green Economy, 2020), p. 8.
³Chika Udeaja, Damilola Ekundayo, Lei Zhou and Srinath Perera, Material Waste in the Construction Industry: A Review of the Legislative and Supply Chain Issues (University of Salford, 2013), p.15.
⁴ WRAP, Setting a Requirement for Recycled Content in Building Projects, p. 14.
⁵ Sharman, NBS.
⁶ WRAP, p. 14.
⁷ Gilli Hobbs and Katherine Adams, Reuse of Building Products and Materials — Barriers and Opportunities (International HISER Conference on Advances in Recycling and Management of Construction and Demolition Waste, 2017), p. 2.
⁸ Wahlstrom, Bergmans, Teittinen, Bacher, Smeets and Paduart, p. 37–9.
⁹ Hobbs and Adams, p. 2.
¹⁰ Wahlstrom, Bergmans, Teittinen, Bacher, Smeets and Paduart, p. 16.
¹¹ Wahlstrom, Bergmans, Teittinen, Bacher, Smeets and Paduart, p. 18–9.
¹² Wahlstrom, Bergmans, Teittinen, Bacher, Smeets and Paduart, p. 18–9.
¹³ Wahlstrom, Bergmans, Teittinen, Bacher, Smeets and Paduart, p. 18–9.
¹⁴ Wahlstrom, Bergmans, Teittinen, Bacher, Smeets and Paduart, p. 18–9.
¹⁵ Steel Construction Institute, Protocol for Reusing Structural Steel (2019), p. 13.
¹⁶ DML, ‘Radical Practice 2020/2021 Studio Brief’ (Royal College of Art, 2020), p 21.
¹⁷ WRAP, p. 14.
¹⁸ WRAP, p. 5.
¹⁹ WRAP, p. 3,14.
²⁰ pbctoday, ‘A New Protocol for Reusing Structural Steel’, pbctoday, 2019 <https://www.pbctoday.co.uk/news/building- control-news/reusing-structural-steel/62082/> (accessed 30 December 2020).
²¹ Hobbs and Adams, p. 4.
²² Wahlstrom, Bergmans, Teittinen, Bacher, Smeets and Paduart, p. 31–2.
²³ Wahlstrom, Bergmans, Teittinen, Bacher, Smeets and Paduart, p. 37–9.
²⁴ WRAP, p. 9.
²⁵ Wahlstrom, Bergmans, Teittinen, Bacher, Smeets and Paduart, p. 18–9.
²⁶ Wahlstrom, Bergmans, Teittinen, Bacher, Smeets and Paduart, p. 32.
²⁷ Wahlstrom, Bergmans, Teittinen, Bacher, Smeets and Paduart, p. 18–9.
²⁸ Enrico Benetto, Kilian Gericke and Melanie Guiton, Designing Sustainable Technologies, Products and Policies (Luxembourg Institute of Science and Technology, 2017), p.220.
