Site Waste Management Plans (SWMPs) aim to reduce the amount of waste produced on construction sites by setting out how building materials, and any resulting waste, will be managed during a project. The plan is then updated during the construction process to record and confirm how materials are reused, recycled or disposed of. SWMPs are often now called Resource Management Plans.
There is no legal requirement for an SWMP but implementing one will help manage materials more effectively and help reduce waste and costs. Regardless of whether an SWMP is used, all construction companies have a duty of care towards managing their waste under s.34 of the Environmental Protection Act and an SWMP can help by raising the profile of waste planning, improving the environmental awareness of a workforce. It can also help ensure compliance with the regulations.
There is no legal requirement for a Site Waste Management Plan (SWMP).
SWMP guidance is available for those who find it useful.
Regardless of whether an SWMP is adopted, all construction companies have a duty of care towards managing their waste under s.34 of the Environmental Protection Act.
Where a Site Waste Management Plan (SWMP) is put in place, all employees involved in the construction project are responsible for implementing it and adopting the practices required by the plan.
In all instances, employees are required to follow company waste procedures and comply with relevant aspects of the duty of care for waste.
A Site Waste Management Plan (SWMP) is a plan that details the amount and type of waste that will be produced on a construction site and how it will be reused, recycled or disposed of. The plan is updated during the construction process to record how waste is being managed and to demonstrate that any materials which cannot be reused or recycled are disposed of at a legitimate site.
The Site Waste Management Plans Regulations 2008 were revoked in 2013 following a consultation by Defra as part of the Government’s Red Tape Challenge. The consultation concluded that repealing the SWMP Regulations would have minimal effect on the effort to reduce construction waste and keep it out of landfill. Consequently, the regulations were revoked by the Environmental Noise, Site Waste Management Plans and Spreadable Fats, etc (Revocations and Amendments) Regulations 2013. Since 1 October 2013, SWMPs have not been a legal requirement. The regulations applied to England only.
SWMPs were a mandatory requirement in the 2006 Code for Sustainable Homes. However, this requirement was removed in the 2010 version and replaced with voluntary credits. The Code for Sustainable Homes has since been withdrawn in all but legacy cases.
Some projects may require SWMPs in order to comply with certification by the Building Research Establishment Environmental Assessment Method (BREEAM). Although an SWMP is not a specific requirement of planning applications, as part of their duty to uphold the Waste Management Plan for England and National Planning Policy for Waste, planning authorities can set out conditions that require a developer to outline how they plan on dealing with waste arising from the development.
Northern Ireland and Wales consulted on making SWMPs a legal requirement but following consultation opted to keep SWMPs voluntary. Similarly, SWMPs are considered good practice in Scotland, but are not mandatory. The Scottish Government’s Zero Waste Plan includes actions to drive waste prevention in the construction and demolition sector. The Waste (Scotland) Regulations 2012 set out statutory measures to support the Zero Waste Plan.
Regardless of whether an SWMP is used, the reduction of waste is an important part of any construction process, and there are legal, economic and environmental reasons for reducing waste wherever feasible.
In its 2018 waste and resources strategy, Our Waste, Our Resources: A Strategy for England, the Government stated its ambition “to eliminate avoidable waste of all kinds by 2050” including in the construction sector. In the strategy, the Government has stated that it planned to work with the Green Construction Board to establish a definition of zero avoidable waste in the sector and by 2020 develop a route map of how this can be achieved.
In February 2020, Zero Avoidable Waste in Construction: What Do We Mean By It and How Best to Interpret It. A Recommendation from the Green Construction Board was published providing a working definition of zero avoidable waste in construction. The definition is:
Zero Avoidable Waste (ZAW) in construction means preventing waste being generated at every stage of a project’s lifecycle, from the manufacture of materials and products, the design, specification, procurement and assembly of buildings and infrastructure through to deconstruction. At the end of life, products, components and materials should be recovered at the highest possible level of the waste hierarchy, ie reused before being recycled, while ensuring minimal environmental impact.
The geographical scope for the definition is England, although the report stresses that there are synergies with the rest of the UK and that a consistent approach would be beneficial. “Construction” includes both buildings and infrastructure, and the scope of ZAW that has been adopted includes the entire construction lifecycle, including the manufacture of construction products.
Avoidable waste are those products that can be prevented from becoming waste; unavoidable waste are those materials, such as asbestos, which are unsuitable for further use.
A route map identifying how ZAW can be delivered was published in summer 2021. The route map sets out ways of generating less material waste across the building lifecycle — including during the construction phase. For new build, it makes the following recommendations for the 2020s:
- That targets for the reuse and recycling of key products and waste materials are set out in contracts.
- That more training takes place with the workforce to separate materials onsite.
- That a Resource Management Plan — or plan for managing waste — is in place that includes targets for reuse and recycling.
- That Extended Producer Requirements are in place for suitable materials by the mid-2020s.
- That new businesses that reuse and recycle construction waste are helped through start-up schemes.
The Government is currently analysing feedback from its consultation on aWaste Prevention Programme for England. It included a chapter on construction, which outlined the Government’s ambitions to require products to use more recycled materials and to use the planning process to promote sustainable resource use.
Site Waste Management Plans (SWMPs) are now voluntary in England, Wales and Northern Ireland. The information below is based on the requirements set out in the Site Waste Management Plans Regulations 2008 (now repealed) to provide guidance on how an SWMP can be drawn up.
The SWMP should be written at the construction design stage, but maintained during the entire project.
An SWMP should identify the:
- principal contractor
- person who is responsible for dealing with waste
- person who drafted the SWMP.
It should describe the construction work proposed, including the:
- location of the site
- estimated cost of the project.
It should record any decision taken before the SWMP was drafted on the nature of the project, its design, construction method or materials employed in order to minimise the quantity of waste produced on site.
The SWMP should include the following.
- A description of each waste type expected to be produced over the course of the project.
- An estimation of the quantity of each different waste type expected to be produced.
- Information about how the waste will be measured during the course of the project.
- The waste management action proposed for each different waste type, including reusing, recycling, recovery and disposal.
- A record of the quantities of waste produced.
The principal contractor and the client should state that all reasonable steps will be taken to ensure:
- all waste from the site is dealt with in accordance with the waste duty of care
- contractors are supported in meeting their duty of care
- materials will be handled efficiently and waste managed appropriately.
The SWMP Regulations required that projects between £300,000 and £500,000 needed a basic SWMP; projects above £500,000 were required to have an advanced plan.
SWMPs for projects of an estimated cost of less than £500,000 should be updated by recording the:
- identity of the person removing the waste
- types of waste removed using European Waste Catalogue Codes and keeping a record of transfer and consignment notes
- site that the waste is being taken to.
In addition, within three months of the work being completed, the principal contractor should add to the plan a confirmation that the plan has been monitored on a regular basis to ensure that work has progressed according to the plan, and that the plan had been updated with an explanation of any deviation from it.
For projects with an estimated cost of greater than £500,000, the principal contractor should do everything required by the basic SWMP but also make sure that all relevant data is collected for auditing the plan.
Keeping information about where waste is disposed of is a legal requirement under the construction company’s duty of care. However, it does not necessarily need to be recorded on an SWMP.
As often as necessary, and no less than every six months, under an advanced SWMP, the principal contractor should do the following to ensure that the plan accurately reflects the progress of the project.
- Review the plan.
- Record the types and quantities of waste produced.
- Record the types and quantities of waste that have been:
- reused (and whether this was on or off site)
- recycled (and whether this was on or off site)
- sent for another form of recovery (and whether this was on or off site)
- sent to landfill
- otherwise disposed of.
- Update the plan to reflect the progress of the project.
Within three months of the work being completed, the principal contractor should add to the plan:
- confirmation that the plan has been monitored on a regular basis to ensure that work has progressed according to the plan
- a comparison of the estimated quantities of each waste type against the actual quantities of each waste type
- an explanation of any deviation from the plan
- an estimate of the cost savings that have been achieved by completing and implementing the plan.
Every contractor should know where the SWMP is kept, and it must be available to any contractor carrying out work described in the plan. Making sure that the plan is available is the responsibility of the principal contractor.
Everyone working on a site, delivering materials to a site, or removing waste materials will be part of the SWMP and so it should be clearly communicated to everyone. This could be done during inductions or toolbox talks and by incorporating the SWMP into the project at the concept and design stages.
A Site Waste Management Plan (SWMP) provides a structure for waste delivery and disposal at all stages during a construction project. The step-by-step methodology outlined below is based on advice provided by the Environment Agency. The steps suggested are as follows.
- Appoint a responsible person.
- Identify types and quantities of waste that will be produced.
- Identify waste management options.
- Identify where and how to dispose of waste.
- Communicate the plan and carry out training.
- Ensure on-site materials and waste handling is well organised.
- Measure the amount of waste produced.
- Monitor the implementation of the SWMP.
- Review the success of the SWMP.
Appoint someone to take overall responsibility for the site’s SWMP.
Any number of individuals can be involved in the delivery of the plan, but it is good practice for one person to be in charge and responsible for updating the plan throughout the life of the project. That person needs to be clear of their responsibilities and also have enough authority to ensure that everyone co-operates with the requirements of the SWMP.
Identify the types (such as “controlled waste”, “hazardous waste” and “directive waste”) and quantities of waste that will be produced during the project.
This requires thinking through every stage of the project and working out in advance what materials will be used. It also requires estimating how much waste will be able to be reused, recycled or disposed of.
Work out the best options available for recycling and disposal, and ensure that:
- all waste is stored and disposed of responsibly in accordance with the duty of care
- waste is transferred to an authorised person or for authorised transport
- a record is kept of all waste disposed of or transferred. Under the duty of care, this record needs to be a waste transfer note or a document that contains the same information.
Under the Waste (England and Wales) Regulations 2011, as amended, plans for waste must take into consideration the waste hierarchy (eliminate, reduce, reuse, recycle and dispose). Specific arrangements also need to be made for any hazardous wastes produced.
Ensure that it is known how and where waste will be disposed of. When using contractors for waste disposal, it is necessary to ensure they comply with all legal responsibilities.
Ensure that everyone on site knows about the SWMP. Hold meetings with staff and contractors to explain why the SWMP is important. Include information about the SWMP in inductions for everyone working on site and in toolbox talks.
It may also be necessary to develop a training programme to ensure that everyone is aware of the importance of asking for and recording the correct paperwork and information.
Careful planning of the materials needed for the project is required, but this also brings benefits, eg pre-ordering materials to specification at the design stage could create time savings later on. An SWMP might also help to avoid over-ordering and therefore reducing any costs associated with disposal. Make sure all targets set at the beginning of the project are clearly stated and written down.
Once the plan is being used:
- measure how well it is working by assessing how much and what type of waste is being produced
- consider setting up measurements, eg:
- volume (number of skips)
- value (cost of disposal)
- weight (weighbridge tickets)
- use data to provide a comparison with other projects, eg:
- proportion of materials reused/recycled
- savings made
- record costs and measurements
- update the SWMP as necessary.
Make sure everything runs to plan, but be prepared to make changes. Learn lessons and adapt the plan throughout the project. This information can also be used for future projects.
By the end of the project, the SWMP should provide an accurate record of how effectively the materials on site were managed and how well targets for waste management were met.
Zero Waste Scotland have produced a SWMP tool to assist with the preparation, implementation and review of a Site Waste Management Plan (SWMP).
WRAP had previously carried out a significant body of work looking at resource efficiency in construction. The main knowledge base created by WRAP, including information on waste minimisation, has been transferred to Construction Industry Research and Information Association’s (CIRIA) Resource Efficiency Knowledgebase.
Reducing the amount of construction waste sent for disposal can bring about many benefits, including:
- saving money as a result of buying fewer materials and reducing the amount of waste that needs to be thrown away
- improving efficiency
- helping to maintain a tidy worksite that meets health and safety legislation
- helping to meet legislative requirements under duty of care obligations and to implement the waste hierarchy and achieve zero avoidable waste ambitions
- implementing more environmentally-friendly practices that conserve resources and reduce carbon consumed
- helping to differentiate the business from other companies by offering an environmentally-responsible service and adding to corporate social responsibility objectives
- helping meet any requirements of planning.
The efficient use of materials should form part of an overall strategy for sustainable construction. When selecting materials, a company should:
- look for opportunities to reuse local construction and demolition waste
- consider how construction materials can be used when deconstructed
- use products with a high recycled content
- use products that are durable with a long life expectancy, and those which can be easily repaired and maintained
- use renewable materials from sustainable sources
- specify materials with a low environmental impact.
In its publication, Designing Out Waste: A Guide for Project Design Teams, Zero Waste Scotland identifies five basic principles of designing out waste from a construction project. These can be applied during design development and used as a prompt to investigate ways to deliver best practice for individual projects. These are highlighted below.
It may be feasible to repurpose, refurbish or change the use of the existing buildings rather than demolish them — for example changing a commercial premises into domestic. If changing use, consideration should be given to the new use to ensure that the building is still fit-for-purpose.
If old buildings are being demolished prior to the new construction, it is likely that some of the building elements can be reused — increasingly materials passports are being used to document the components of a building to help with re-use
Reused materials should meet the project’s quality criteria and technical specifications and some testing and treatment may be required. The results of tests should be incorporated into any SWMP being used.
Examples of materials and structures that can be reused and recovered include:
- tarmac and asphalt for paths, car parking, storage space
- topsoil for green roofs or landscaping
- trees that cannot be retained for compost or building outdoor furniture
- recycled concrete as a thermal heat store
- foundations — it may be possible to reuse existing foundations
- good quality timber for flooring
- lower quality timber for mulch or energy recovery
- bricks, slates, tiles, doors, etc can be directly reused
- old fittings and carpets can be donated to charity.
If the construction project is not preceded by demolition, there may still be opportunities to reuse unwanted materials or other materials from nearby projects.
Modern building techniques and materials make it possible to do much of the construction work offsite, so that the actual site is used mainly for assembly. This brings various benefits including improved site safety. From the environmental point of view, it means that there are likely to be fewer errors made on site, reducing the need for rework and hence reducing waste. Components manufactured offsite should still incorporate principles of good environmental practice and waste minimisation in their own design. Some applications of off-site construction are:
- modular classrooms
- prefabricated toilet and shower blocks
- precast concrete stairs and stair wells
- steel frame designs for warehousing
- modular buildings.
The House of Lords Science and Technology Committee’s 2018 report, Off-site Manufacture for Construction: Building for Change, outlines that off-site manufacture (OSM) can help to increase productivity in the construction sector while reducing the environmental impacts associated with traditional construction. To aid the uptake of off-site construction, CIRIA has published a free guide on quantifying the benefits of off-site construction.
The development of offsite technology is also one of the three strategic areas highlighted by the Construction Sector Deal to help the industry meet targets set out in Construction 2025 as well as those in the Government’s Industrial Strategy. Building on the mandated use of Building Information Modelling (BIM) Level 2 in government projects since 2016, several government departments have committed to a presumption in favour of off-site construction when designing major projects.
Furthermore, offsite construction and other modern methods of construction (MMC) are promoted in the Government’s Construction Playbook which outlines how Government will procure, manage and assess public work projects.
At the design stage, there will be opportunities to ensure the building uses materials efficiently and produces less waste. This can be done using the following methods.
- Minimising excavation: for example, when positioning the building on site, look at the location of existing services.
- Simplification and standardisation of materials and components, eg lamps and windows. Standardising the range of materials increases the opportunity to use offcuts. In addition, by standardising similar design elements of the building (for example, designing rooms with dimensions that match standard sizes of materials) it is possible to make the construction process repeatable, improve efficiency and reduce waste.
- Employ three-dimensional modelling to reduce construction errors and assess materials needed. Building Information Modelling (BIM) is increasingly used by architects, engineers and construction professionals to improve how buildings are designed, constructed and managed. Public contracts procured by central Government are required to be BIM Level 2 compliant.
- Whole life costing of the building to measure the impact of different design choices.
The prevention of waste in the first instance is the most cost-effective way of managing waste. It requires clear communication between designers, contractors and clients early on in the process to set contractual targets and expectations, and a review of any specifications that could lead to a high level of waste.
When choosing waste contractors, find one with expertise in waste reduction and liaise with suppliers and specialist subcontractors to identify opportunities for waste reduction. Waste should be considered as part of the tendering process as contracts can be written to include clear targets to cut waste, perhaps accompanied with financial incentives and penalties. WRAP has produced guidance on the wording of procurement documentation.
When specifying materials, choose responsibly sourced materials that reduce waste. Taking the example of plasterboard, the contract could specify fewer types. Once waste minimisation opportunities have been identified, they should be assessed in terms of the impact on cost, programme and building design.
The procurement stage also provides a good opportunity to select contractors with a good record for environmental sustainability and those with environmental management systems in place.
There may not be direct financial incentives to “design for disassembly”, but a truly sustainable design will consider the needs of future generations and facilitate the eventual reuse of materials. Designing for disassembly is important when considering the entire lifecycle of a structure and the circular economy. Some simple suggestions are:
- use lime mortar so bricks can be easily dismantled
- avoid gluing and composite materials, and where required select materials and methods that allow for disassembly
- use reusable materials
- keep designs simple so that buildings can be easily deconstructed or adapted
- use landscaping materials which can easily be taken up, eg grasscrete.
It is a good idea to keep records, eg in a building handbook, of the materials and components that are suitable for reuse. BIM is invaluable in helping to manage this aspect of the building’s lifecycle.
There are various steps that the contractor can take to reduce waste generation by, for example:
- producing an SWMP or Resource Management Plan that includes a site storage and logistics plan
- maximising the reuse of materials on site
- requiring “just in time” delivery
- protecting fragile materials to minimise damage, avoiding unnecessary transport around site, and not removing packaging until materials are needed
- selecting a procurement route that minimises packaging
- organising a take-back procedure for surplus materials and offcuts
- wherever possible, avoiding over-ordering materials and using standard sizes
- minimising the potential of materials getting “spoilt” by ensuring that storage areas are appropriate
- co-ordinating stages of work so that offcuts and leftover materials can be used by others
- where waste is being segregated for recycling or reuse ensuring that there is clear and consistent signage on skips, containers and other storage areas so that it is clear where things should be kept; locating general waste skips next to recycling areas can also help stop contamination of recycling containers
- clearly explaining expectations for waste management as part of any induction process and toolbox talks, and keep staff reminded by good communication on site, for example, by displaying information on Key Performance Indicators (KPIs) to promote the progress being made towards targets.
As outlined above, a key aspect of reducing waste in construction projects and over the lifecycle of a building is by creating less waste in the first instance. BS 8895: Designing for Material Efficiency in Building Projects is a series of standards developed by the British Standards Institute that helps identify how to optimise materials in construction projects and prioritise and implement viable solutions.
- Clean Neighbourhoods and Environment Act 2005
- Environmental Protection Act 1990
- Environmental Permitting (England and Wales) Regulations 2016
- Construction (Design and Management) Regulations 2015
- Environmental Noise, Site Waste Management Plans and Spreadable Fats etc. (Revocations and Amendments) Regulations 2013
- Waste (Scotland) Regulations 2012
- Waste (England and Wales) Regulations 2011
- Waste Regulations (Northern Ireland) 2011
The following is available at www.bre.co.uk.
- Green Guide to Specification
The following are available at www.ciria.org.
- C741 Environmental Good Practice on Site Guide (2015) (Fourth Edition), CIRIA
- C762 Environmental Good Practice on Site — Pocket Book (2016), CIRIA
Between 2000 and 2015, WRAP carried out significant work to support the construction industry to improve resource efficiency. This knowledge base has been transferred to CIRIA and can be found in CIRIA’s Resource Efficiency Knowledgebase website.
Some example publications include:
- Designing out Waste: A Design Team Guide for Buildings
- Implementing Designing out Waste in Your Company, CIRIA
- Net Waste Tool — User Guide, CIRIA
- Procurement Requirements for Reducing Waste and Using Resources Efficiently, CIRIA
- Reducing Your Construction Waste — Guidance for Small and Medium Sized Contractors, CIRIA
- Setting a Requirement for Waste Minimisation and Management, CIRIA
- The Business Case for Specifying and Sourcing Resource Efficient Products, CIRIA
- Guidance: The Construction Playbook (2020)
- National Planning Policy for Waste (2014), Ministry of Housing, Communities and Local Government
- National Planning Policy Framework (2019)
- Non-statutory Guidance for Site Waste Management Plans (2008)
- Our Waste, Our Resources: A Strategy for England (2018)
- Waste Duty of Care: Code of Practice (2016, updated 2018)
- Waste Management Plan for England (2021)
The following are available at www.zerowastescotland.org.uk.
- Best Practice Guide to Improving Waste Management on Construction Sites
- Construction Resources For a Circular Economy
- Create a Site Waste Management Plan for Construction
- Designing Out Construction Waste Guide
- Maximising Reuse of Materials on Site
- Procuring Resource Efficient Construction Projects
The following is available from the Green Construction Board at www.constructionleadershipcouncil.co.uk.
- Zero Avoidable Waste in Construction: What Do We Mean By It and How Best to Interpret It. A Recommendation from the Green Construction Board (2020), Green Construction Board
- The Routemap for Zero Avoidable Waste in Construction (2021), Green Construction Board
The following are available at the BSI Shop
- BS 8895-1:2013 Designing for Material Efficiency in Building Projects: Code of Practice for Strategic Definition and Preparation and Brief
- BS 8895-2:2015 Designing for Material Efficiency in Building Projects — Part 2: Code of Practice for Concept Design and Developed Design
- Constructing Excellence
- Constructing Excellence aims to deliver improved industry performance resulting in a demonstrably better built environment. It acts as a bridge between industry, clients, government and the research community, delivering government programmes, membership programmes and other commercial contracts.
- Construction Industry Research and Information Association (CIRIA)
- CIRIA is the construction industry research and information association. Since 1960, CIRIA has delivered support and guidance to the construction, built environment and infrastructure sectors.
- Department for Environment, Food & Rural Affairs (Defra)
- Defra is the government department that deals with waste, water and other environmental issues. It consults on new regulations and provides guidance on legislation and best practice.
- Green Construction Board
- The Green Construction Board is the sustainability arm of the Construction Leadership Council. It was established to drive forward the actions set out in the “Low Carbon Construction Action Plan”.
- Zero Waste Scotland
- This support service enables all organisations in Scotland to use resources more efficiently by providing free guidance and advice on waste, water and energy efficiency. The good practice guidance available is relevant to businesses everywhere.
- South East Centre for the Built Environment (SECBE)
- The SECBE is a consortium of business leaders that exists to inform policy and drive business-to-business learning and networking. It takes regional strategies and industry issues and develops action plans to improve business performance throughout the sector.
- Waste and Resources Action Programme (WRAP)
- WRAP works with governments, businesses and communities to deliver practical solutions to improve resource efficiency. WRAP’s mission is to accelerate the move to a sustainable, resource-efficient economy.