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It is also important to remember that any recycled topsoil that hasn't been tested is likely to be still be classified as waste. As such it would be subject to waste controls e.g. waste transfer notes required and the site where it was going to be used would require an exemption/permit. One way of operators proving that the topsoil is no longer waste and has become a product, is to undertake BS3882 testing. While most topsoil providers do test their soil, not all do. Kind Regards, Louise Howard Environment Management Environment Agency Find out if you’re at risk from flooding -----Original Message----- From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Mark Seaman Sent: 26 November 2012 15:07 To: [log in to unmask] Subject: New NHBC coversytstem / topsoil validation guidance. Afternoon all, A local consultant has made me aware that the NHBC have just published revised guidance on validating cover systems / topsoil in issue 8 of Technical Extras: http://www.nhbc.co.uk/Builders/ProductsandServices/TechnicalExtra/ I had a brief discussion with the consultant about the guidance and we shared the same concerns. Consequently I wondered whether list members were aware of the guidance and whether others had similar concerns. My concerns include: 1. I can't agree that soils raised from agricultural land would not need testing (pesticides, herbicides, fungicides, fertilisers, PAHs (stubble burning) etc etc); 2. I would also need convincing that any topsoil manufactured from a waste stream, green or not, would not require any testing at all (although in reality I guess it would probably be subjected to a certain degree of testing as part of manufacturer QA/QC?); and 3. I cannot agree that imported topsoil which is, "...not being used as a cover system as part of a contamination remediation strategy..." will not require testing. There is no logic to that statement at all. If you place contaminated top soil over clean or contaminated subsoil the result is the same: a viable pollutant linkage. In my opinion a developer must be able to PROVE that ANY topsoil / subsoil imported onto site is suitable for the intended end use. If that use is residential then the chemical composition must be judged against current SGVs / GACs etc etc. Maybe I’m being overly conservative so I would be very interested in other opinions. I’m not convinced that this document is very helpful and I expect that it will be cited in many validation reports to justify no / low level testing. I am curious as to how the HNBC formulate such guidance and whether any regulators etc are consulted during the process so if any NHBC list members could comment I would be very grateful. Thanks, Mark. Mark Seaman Waveney District Council Environment Protection Officer 01502 523153 [log in to unmask] website: www.waveney.gov.uk ( http://www.waveney.gov.uk/ ) twitter: www.twitter.com/waveneydc Information in this message may be confidential and may be legally privileged. If you have received this message by mistake, please notify the sender immediately, delete it and do not copy it to anyone else. We have checked this email and its attachments for viruses. But you should still check any attachment before opening it. We may have to make this message and any reply to it public if asked to under the Freedom of Information Act, Data Protection Act or for litigation. Email messages and attachments sent to or from any Environment Agency address may also be accessed by someone other than the sender or recipient, for business purposes. If we have sent you information and you wish to use it please read our terms and conditions which you can get by calling us on 08708 506 506. Find out more about the Environment Agency at www.environment-agency.gov.uk