SiLC perspective on publication of Environment Agency guidance Land Contamination Risk Management (LCRM)
Dr. Tom Henman, Deputy Chair, Professional & Technical Panel, PTP
After a delay due to Covid-19, Land Contamination Risk Management (LCRM) was finally published by the Environment Agency in October 2020. LCRM replaces CLR11 Model Procedures for the Management of Land Contamination as guidance and the framework for all who are involved in or responsible for managing risks from land contamination in England.
The overall approach to risk management and remediation in LCRM is the same as the withdrawn Model Procedures for the Management of Contaminated Land (CLR11). However, two key elements are prominent in LCRM –which are particularly relevant to SiLC – relating to competence and the National Quality Mark Scheme for Land Contamination Management (NQMS).
LCRM makes prominent reference to the NQMS, which is a voluntary scheme set up by the National Brownfield Forum, and designed to improve confidence in the quality of land contamination reports. Suitably Qualified Persons (SQPs) who sign-off NQMS reports are accredited through the SiLC examination process and the SiLC Professional and Technical Panel is a strong advocate of the NQMS.
As well as highlighting the value of applying the NQMS to reports, LCRM also stresses the importance of identifying any uncertainties and limitations of data and any possible consequences. This is a mandatory requirement for sign-off of reports registered under the NQMS.
LCRM also states the expectation that those undertaking land contamination assessment and remediation will be competent at all stages. This means having the appropriate knowledge, skills, experience and qualifications in each specific area of LCRM and the type of contamination being dealt with. For planning related assessments, LCRM also refers to the National Planning Policy Framework definition of a competent person, i.e. ‘with a recognised relevant qualification, sufficient experience in dealing with the type(s) of pollution or land instability, and membership of a relevant professional organisation’. The SiLC Register was developed precisely with these considerations in mind, so this emphasis on competence is welcomed. Both SiLC and SQPs registered under the NQMS are referenced specifically in LCRM as appropriate qualifications to demonstrate competence.
Overall, SiLC welcomes the new guidance and its emphasis on high quality assessments by competent professionals as well as the application of the NQMS. For more information about the SiLC Register, please visit www.silc.org.uk.
Notes on SiLC:
The Specialist in Land Condition (SiLC) Register scheme was designed to support the recommendations of the Urban Task Force in 1999 and to recognise the skills of those working in the broader land condition sector.
A registered SiLC is a senior practitioner who has a broad awareness, knowledge and understanding of land condition issues, providing impartial and professional advice in their field of expertise. Entry to SiLC is gained through examination, which is held bi-annually. The SiLC Register brings together professionals from a broad range of backgrounds who advise on land condition matters.
The SiLC Register is run and administered by a Professional and Technical Panel (PTP), which comprises representatives from the supporting professional bodies and senior professionals. The PTP develops and implements the registration process and is the ruling committee for individual registrations.