In June 2019 the Environment Agency published on GOV.UK an update to the model procedures for the management of land contamination (CLR11).
The EA requested feedback on the technical content and structure of Land contamination: risk management (LCRM) for 6 months. it has received a lot of feedback and would like to thank everybody that took the time to provide comments. This was greatly appreciated.
Most of the comments were constructive and positive. It was generally accepted that CLR11 is out of date and needed to be updated.
The comments related to:
- the technical content
- practical matters such as the usability, printing, navigation and search
- layout and structure
The EA is currently addressing the comments. It will make changes where possible or relevant.
Some of the main points made include:
- clear language was welcomed with positivity about the new structure;
- links to the CL:AIRE WALL, NQMS and the reporting requirements section were welcomed;
- clarity is required on the definition of a suitably qualified competent professional;
- more emphasis needed on ground gases and vapours;
- a need to emphasise sustainability appraisals more - for example: using SuRF-UK;
- lack of any reference to unexploded ordnance, communicating the risk, geotechnical aspects and more, on treatability studies;
- lack of clarity over stages and tiers;
- clarity on when MCERTS must be used and the use of rapid measurement techniques;
- lack of alignment to British Standards especially for the site investigation section.
A lot of feedback was related to the GOV.UK manual format and requests for a PDF version. The EA cannot publish this as a PDF, however, it is looking at other GOV.UK formats that lend themselves to being more practical to use - for example: for navigation and search. These formats can also be printed and saved as a PDF if required.
There were a lot of comments on the lack of flow charts. The reformed content does not need all of the flow charts that were in CLR11 but the EA are looking at the options for this.
There was a lot of feedback on the OA Matrix. This will be amended and updated throughout 2020. The EA is concentrating on getting the main guidance document republished first, hopefully by the end of Jan 2020.
When the updated version of LCRM is published, CLR11 will be formally withdrawn. Following publication, LCRM is always open for feedback and improvement. The EA will make sure the document is kept up to date.