NQMS for Land Contamination Management

The NQMS is a system designed by the National Brownfield Forum to ensure that the assessment and management of land contamination meets the necessary technical and regulatory standards. It applies in particular to the presentation of environmental information to the regulators in the form of reports, setting out both factual and interpretative information.

Reports are prepared in line with good practice and follow the Land Contamination Risk Management (LCRM) framework and are reviewed and signed off by a suitably qualified and experienced person registered under the NQMS who ensures:

· The work has been planned, undertaken, written up and reviewed by competent people who have relevant experience and/or qualifications in their respective disciplines.

· The underlying data has been collected in line with established good practice procedures and its collection has been subject to control via established quality management systems.

· The data has been processed, analysed and interpreted in line with established good practice, having due regard for any specific advice provided by the relevant regulatory authorities.

· The reports set out risk based recommendations or conclusions that are substantiated by the underlying data and are based upon reasonable interpretations.

· Any limitations in the data or uncertainties in the analysis are clearly identified along with the possible consequences of such limitations.

The scheme is voluntary and the procedure is simple. It has been designed to minimise costs and maximise benefits by operating alongside and within existing quality management systems. The scheme is being administered and supported on behalf of the National Brownfield Forum by CL:AIRE as secretariat and SiLC as SQP assessors. 

NQMS links directly to the Brownfield Skills Framework. This framework has been developed to provide guidance on the skills required from graduate, through chartership to SQP/SiLC accreditation. With a skills gap quickly developing in the land contamination sector, having a clear career and CPD framework in place for both industry and regulator practitioners promotes and encourages skills to be retained, confirming the importance of land contamination professionals.

The scheme was initially designed to support Local Planning Authorities and Local Authority Contaminated Land Officers and other Government funded planning consultees (statutory and non-statutory) prioritise and maximise the deployment of scarce public resources. Since its launch the scheme has been expanded for use across multiple legislative regimes beyond planning and redevelopment and now also supports quality data submissions to the Environment Agency, Natural Resources Wales and Scottish Environmental Protection Agency.

Prolonged and protracted consultations over poorly executed land quality investigations, with conceptual models that miss critical receptors or reports that do not follow the LCRM guidance are unacceptable.

The NQMS is designed to support regulators have confidence in the quality of reports carrying a NQMS declaration, aiming to reduce the time for review by providing good quality reports that are right first time.

And, if there are concerns over a report carrying a NQMS declaration, there is an audit process which can investigate.

The NQMS is not about avoiding scrutiny or regulatory review; a well-developed investigation, that follows good practice and land contamination guidance will hold up to that scrutiny and be clear and transparent about the uncertainties.

The National Planning Policy Framework states that land contamination assessments must be completed by a ‘competent person’. LCRM states that land contamination reports should be reviewed by a suitably qualified person. Adoption of the NQMS process demonstrates that your company complies with both these obligations.

The NQMS is not about changing the way consultants and contractors are working, it aligns with the guidance and frameworks already in place that should be adopted by all parties acting in the capacity of competent person (as defined in the NPPF) undertaking land contamination assessments.

Adopting the NQMS demonstrates to Clients that your company is supporting good practice and the ‘right first time’ approach for each and every report.

If your company does not have a SQP in-house, check the requirements for working at this level in the Brownfield Skills Framework and consider attending a SiLC introductory session to find out what is involved; SiLC also offers a mentor scheme to support SQP/SiLC development.

There are also independent SQPs who may be willing to support with peer review and project advice who are not direct competitors, providing that your company has a clear technical development scheme in place. Check the SQP register.

Significant economic benefits are achieved by getting assessments ‘right first time’ without the need for lengthy negotiations and detailed auditing by the regulators. In particular, planning applications submitted under the Town and Country Planning regime should benefit significantly from speedier resolution if NQMS is involved. Use of the NQMS will also assist in the prompt discharge of subsequent planning conditions.

Projects and developments that meet the standards for regulatory compliance incur less costly delays and are not subject to enforcement action.

The scheme has been designed around current good practice and guidance that should be followed by all land quality consultants. Asking consultants to adopt the scheme should not incur any additional costs as experienced and reputable consultants will be following this guidance anyway; adoption of the scheme will ensure that only competent individuals work on your project, as required in the NPPF. This also means you can have confidence that advice and recommendations are balanced, supported by the data and clearly summarise uncertainties.

To find out which consultants have an in-house SQP, a person meeting the required standard of ‘competent’ in land contamination assessments, check the SQP register.

If your preferred consultants do not have a SQP on the register, let them know your intention to ensure compliance with the scheme. The SQP registration is open twice a year and any experienced land contamination professional can apply.

National Quality Mark Scheme- Getting it right first time Webinar