GN9.3: Embedding sustainability within waste management services

Guidance Note purpose 

The purpose of this Guidance Note is to provide asset managers, property managers and facilities managers with guidance for incorporating sustainability into the procurement, implementation and on-going management of waste management services. 

Context 

Incorporating sustainability within waste management contracts involves the identification of environmental and social issues relating to waste management activities and ensuring that they are adequately considered during the procurement of human resources and materials at all stages of the waste management cycle. 

Environmental issues could involve, for example, the end-life treatment of the waste. 

Social issues could involve, for example, ensuring that waste management contractors have taken relevant precautions beyond merely checking Right to Work documents to ensure modern slavery risk is reduced as far as possible.  

The “waste hierarchy”, as recommended by the UK government, ranks waste management options in terms of what is best for the environment. 

Waste management hierarchy 

Importance 

The procurement of waste management services without adequate due diligence, or with poor management of the waste management contractor or service provider, has the potential to: 

  • Lead to significant environmental damage. 
  • Present a serious risk to human health and wellbeing. 

As waste management services are subject to a range of regulations, alongside potentially damaging the reputational of both the property managers and the asset manager, non-compliance also introduces operational and financial risk through exposure to penalties and fines. 

Relevant environmental legislation relating to the incorporation of sustainability within waste management contracts includes: 

  • Control of Pollution (Amendment) Act 1989. 
  • Hazardous Waste (England and Wales) Regulations SI 2005/894. 
  • Part 2 of the Environmental Protection Act 1990. 
  • The Controlled Waste (England and Wales) Regulations 2012. 

Relevant social legislation to consider in in relation to the incorporation of sustainability within waste management contracts includes: 

  • The Modern Slavery Act 2015 

Responsibilities & Interests

The table below summarises the key activities associated with embedding sustainability within waste management contracts, and highlights where asset managers, property managers and facilities managers are likely to have a responsibility or specific interest. 

  • AM - Asset Manager
  • PM - Property Manager
  • FM - Facilities Manager

1. Procurement practice  

Stakeholder:

2. General provisions 

Stakeholder:

3. Training 

Stakeholder:

4. Waste and environmental performance 

Stakeholder:

5. Ongoing monitoring 

Stakeholder:

6. Supply chain management 

Stakeholder:

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How to

Intro

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Property managers play a key role in embedding sustainability requirements within waste management contracts, and, alongside facilities managers, checking that contractors are operating as intended.  Asset managers have an ongoing interest in ensuring that waste management services comply with regulations alongside any additional requirements they may specify. 

The way in which sustainability is incorporated within waste management contracts must be stringent, fair and comprehensive to enable the intended interpreted by waste management contractors and service providers. However, there must also be flexibility for a property manager to take into account any additional requirements, guidance or best practice specified by asset managers. 

Embedding sustainability requirements within waste management services involves the consideration of the following elements:  

1: Procurement practice

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The procurement stage provides the primary opportunity to influence the sustainability impacts of waste management contracts. 

When agreeing the lease, sustainability issues and priority areas should have been documented between the asset manager and its occupiers.  Relevant sustainability requirements can then cascade within waste management services contracts to define and confirm acceptance of responsibilities, alongside lines of reporting and accountability. 

Due diligence and pre-screening questionnaires should include consideration of the requirements of the Modern Slavery Act.  As this Act acknowledges waste management as a high-risk service in relation to modern slavery, it is important that full checks have been undertaken in all contractor selection processes prior to instruction. 

A waste management contractor should also support the right to collective bargaining and freedom of association and encourage ways of maintaining open dialogue with employees, for example, through employee forum meetings, employee ombudsmen, and channels for reporting concerns, with the option to do so anonymously.  Appropriate whistleblowing channels should be available for waste management personnel to report and ensure any issues raised are dealt with fairly, clearly, efficiently and appropriately, without fear of retaliation. 

Pre-screening should include a check whether waste contractors have been convicted or had a notice served upon them for infringement of environmental legislation, with further investigation into the circumstances, accompanied by subsequent action, where necessary. 

Ideally, waste management sub-contractors should be required to operate a certified Environmental Management System, or at least have a documented process for identifying and managing significant environmental and/or social sustainability aspects and impacts. 

It is important that property managers consider the inclusion of specific clauses relating to sustainability for inclusion within waste management contracts.  The Better Building Partnership’s Improving Waste Management Practices Procurement Specifications Guide provides a series of sample contract clauses for improving environmental performance through waste management contracts. 

2: General approach to waste management

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General provisions 

In the context of building-related waste, there are a number of areas that a property manager should consider in relation to contracts for waste management services. Examples include: 

  • Ensuring that waste transfer notes for all non-hazardous waste streams are held and counter signed. 
  • Ensuring that hazardous waste onsite, for example, fluorescent tubes and some Waste Electrical and Electronic Equipment, are segregated, dealt with appropriately and in a timely manner and are accompanied by waste consignment note records. 
  • Acquiring exemptions or permits to cover waste treatment on site. 
  • Providing reasonable and appropriate facilities for waste collection and segregation, with accompanying clear and up-to-date signage.  Consideration should be given as to whether other languages, in addition to English, are necessary to align with user demographics) 
  • Ensuring that waste management contractors have knowledge of the property’s waste collection and segregation mechanisms. 

Best practice – zero waste to landfill 

Best practice involves an emphasis on circular economy principles, aiming for no waste to be sent to landfill and setting ambitious targets for prevention, reuse and recycling. 

Asset and property managers should consider including zero to landfill as a standard requirement across waste management contracts. 

Appropriate provision for such a strategy and corresponding targets should be made available on site, considering each waste stream and appropriate training. 

3: Training

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Waste management provides a meaningful contribution to a property’s overall sustainability performance.  

It is important that early and ongoing engagement with waste management contractors is undertaken to raise awareness sustainability objectives and targets, and to confirm that employees receive appropriate training.   

Key aspects of awareness raising and training for waste management personnel relates to:  

  • Understanding industry-specific waste management requirements, as well as asset and property managers’ waste management objectives and targets. 
  • Safe and appropriate onsite waste handling procedures, particularly relating to COVID-19 protocols. 
  • The efficient and effective use of waste management equipment. 
  • Keeping of appropriate records, for example relating to waste transfer or waste consignment notes. 

Training and sustainability performance targets should be reviewed periodically to support maintenance of high standards.  Property and facilities managers should consider providing training material in languages other than English to align with the demographics of the waste contractor’s personnel. 

4: Waste and environmental performance

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General arrangements 

It is important that property managers engage waste contractors on an ongoing basis to ensure that: 

The Building User Guide includes accurate and up-to-date information about waste management arrangements. 

Waste management schedules can be arranged to accommodate periods when the building, carpark and access routes are likely to be busiest (NB: where possible unused materials and packaging will have already been returned to manufacturers for re-use or recycling by the returning delivery vehicles) 

The contractor is aware of and adheres to any Site Waste Management Plan 

COVID-19 

As part of arrangements to control COVID-19, more frequent cleaning along with increased use of single-use face coverings and personal protective equipment (PPE) will generate extra non-recyclable waste.  This waste type must be disposed of promptly and appropriately, and in line with the latest government guidelines.  Cloth face coverings can be washed and re-used to prevent and reduce waste. 

5: Ongoing monitoring

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It is important that waste management contracts include a requirement to provide data that can support the monitoring and review of a property’s waste management plan and the achievement of its waste objectives and targets. 

This could involve, for example, the provision of information relating to the types and quantities of waste generated and how this waste has been managed. 

Performance standards 

In order to ensure that high sustainability performance standards are achieved and maintained, it is important to review both the services provided and products used on a regular basis. This review should be against a clear set of output-based KPIs, and undertaken as part of annual contract reviews.  

For waste, this could include, for example, targeted increases in re-use and recycling rates for recyclable items and a reduction in total landfill waste and non-recyclable items, particularly in relation to construction and fit-out waste. 

Where standards are found to be lacking, property managers should work collaboratively with the service provider to establish the reason for under-performance.  This may relate to, for example, insufficient resourcing, training or communication.  Following the review, an improvement plan should be mutually agreed. 

Regulatory requirements 

Facilities Management should ensure there is a formal process in place to review changes in legislation and to ensure any applicable changes in legislations are included in contract renewals. 

6: Supply chain management

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As waste management falls into a high-risk service category in respect of employment processes, checks should be undertaken routinely on the service provider. 

This should include ensuring that directly employed staff and, as far as possible, any other staff in the supply chain are offered a safe place to work where there is no bullying, harassment, discrimination or unreasonable working conditions of any kind, for example, unpaid work, excessive working hours. The Property Manager has responsibility for ensuring that there are demonstrable policies and processes in place to ensure this. 

Related Guidance Notes

The following Guidance Notes contain related information: 

Additional Resources