7 July 2026
MATERIAL MANAGEMENT PLANS: WHAT DO YOU NEED TO KNOW?
A comprehensive Material Management Plan (MMP) will ensure the correct disposal of excavated soil and other materials from construction projects. But how should they be prepared, when are they required and what actually constitutes waste? Chris Wall, our Geo-Environmental Associate, shares his insight…
“There is increasing regulatory pressure around waste generation in our industry. Contractors are facing rising disposal costs and must demonstrate strict compliance with NHBC and Environment Agency regulations as well as following the voluntary CL:AIRE Definition of Waste: Development Industry Code of Practice.
“A MMP will set out sources and types of excavated materials; their intended reuse locations and volumes; required chemical or physical quality testing; and roles, responsibilities, tracking and verification procedures. Essentially, it’s a package of evidence to demonstrate that a material is suitable for reuse and is not a waste.
“The main source of confusion we see from housebuilders regarding MMPs is a lack of understanding as to when they are actually required.
“When there is a proposal to re-use excavated soil materials which have been, or intend to be, discarded, a MMP should be in place. Without one, any ‘Made Ground’ (i.e. artificial or man-made) excavated from a site would be viewed as a waste, and therefore subject to a potential hefty fine. This also includes any soils imported from a donor site (as it is often surplus to requirements for the donor site and could be viewed as a waste).
“So, where to start?
“My recommendation is that housebuilders ensure waste classification is undertaken as part of their initial ground investigation assessment. This will provide an early understanding of likely disposal costs as well as an indication of waste management strategies.
“Earthworks strategies and MMPs can then be established from the very start of development, allowing for a clear audit trail that will support the end goal of discharging NHBC conditions and complying with the Environment Agency waste regulations.
“Working with an experienced and qualified geo-environmental consultant, housebuilders can ensure all the necessary criteria are met and the final completion reports can be prepared as smoothly as possible.”
Made Ground & What Constitutes Waste?
“Where there is a proposal to re-use Made Ground or import soils from a donor site, housebuilders need to demonstrate the following criteria when preparing a MMP:
· Suitability for use;
· Certainty of use;
· Quantity of use;
· Protection of Human Health and the Environment
“Any soil that the holder discards, intends to discard or is required to discard is considered waste, and is therefore subject to the Waste Framework Directive. This usually follows excavation or movement from its original location and applies particularly to Made Ground. This classification is essential for determining the appropriate management and disposal methods for soil waste, ensuring compliance with environmental regulations.
“The most common misconception is around when soil is classed as hazardous waste. There is quite often an assumption that any Made Ground being removed from site is automatically classed as hazardous waste. But without the correct sampling, testing, and full assessment, this can result in inaccurate classification and expensive disposal costs.
“Waste soil classification follows the Environment Agency’s Technical Guidance WM3 and requires a two-stage process to determine for hazardous or non-hazardous properties. Waste Acceptance testing is also required to determine landfill acceptance options. Sampling and testing is typically undertaken as part of a ground investigation, or later from stockpiles of excavated materials and areas of earthworks. This assessment determines whether Made Ground can be classified as non-hazardous or inert waste and can result in less expensive disposal costs, so we recommend commissioning as easily as possible.”
Compliance:
“A lack of planning prior to undertaking any earthworks is the biggest barrier to compliance. Incorrect waste classifications, inaccurate use of EA U1 waste exemptions, and applying for the wrong permits, are all common scenarios and could be avoided if a MMP is commissioned from the outset.
“Quite often we find that earthworks are intended to, or worst case, have been completed by groundworkers who do not fully understand the requirements of the earthworks specification, which is tailored specifically to each site. This can result in minimal or no supervision and performance testing, poor record keeping, and makes completing the subsequent phased or overall validation report to discharge the NHBC completion conditions extremely difficult. It’s therefore advisable to appoint a qualified geotechnical engineer at the start of development, to ensure frequent supervision, materials sampling and performance testing that meets the criteria set out in the earthworks specification and the MMP.”
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