Environmental Protection UK has asked the British Standards Institute to ensure revisions to British Standard 10175, the code of practice on potentially contaminated site investigation, to give an accurate picture of how site investigation fits into the broader risk management framework.
EPUK's response to the draft code, being revised by Arup for release next year, expresses alarm that the draft does not adequately present how site investigation fits into the CLR11 model procedure framework.
It says the present draft risks further confusion about risk management and site investigation's roles and outputs and fails to describe the relationship between risk management and data gathering activities accurately.
"The BS should concern itself solely with how to get reliable information needed to support risk assessment/ option appraisal/ remediation etc.," it says.
"The standard should not infer that site investigation leads the process, it shouldn't confuse the risk management process and site investigation activities, and it shouldn't be partially advising people (as it does by discussing conceptual model development) on how to carry out the interpretative element."
The result, it says overlooks the need to tailor site investigation works to meet the needs of specific risk assessment areas or stages of the process.
EPUK says the standard incorporates little information on new developments and practices, including the latest testing techniques.
It says it gives no guidance on sampling strategies for stockpiles, heaps, mounds or embankments and refers users seeking definitions of specific words to other publications, rather than including them.
It urges consideration of affordability as the standard could cost £250 which could prove prohibitive for councils and small consultancies and points out that, with PPS23 under review and the future of the Health Protection Agency in doubt, publication should be postponed.
Although EPUK accepts the philosophy of a step-by-step process, it believes the proposed Phase 1, Phase 2 etc. terminology is likely to cause confusion.
