Is the NQMS Mark for Contaminated Land Management stuck in the starting blocks?
The National Quality Mark Scheme for Land Contamination Management (NQMS) was launched on 9th January 2017.
The scheme was designed by the industry led Land Forum to ensure that land contamination management work meets the necessary standards. Administered by CL:AIRE, the scheme came about following concerns from regulators about the variable standards of reporting and it is supported by the Environment Agency (EA). It says it welcomes its collaborative approach, but currently the scheme is not mandatory.
It applies to the presentation of environmental information to regulators in the form of reports setting out both factual and interpretative information. Reports are prepared in line with good practice and signed off by a suitably qualified and experienced person (SQP) registered under the scheme who ensures that:
- The work has been planned, undertaken and written up by competent people who have relevant experience and/or qualifications in their respective disciplines
- The underlying data has been collected in line with established good practice procedures and its collection has been subject to control via established quality management systems
- The data has been processed, analysed and interpreted in line with established good practice and any specific advice provided by the relevant regulatory authorities or regulatory bodies
- The reports set out recommendations or conclusions that are substantiated by the underlying data and are based upon reasonable interpretations
- Any limitations in the data or uncertainties in the analysis are clearly identified along with the possible consequences of such limitations.
So far only six reports have gone through the NQMS and the reaction to the scheme from local authorities on the scheme is mixed. The NHBC says it welcomes any initiatives aimed at raising standards. But it does not currently propose to rely solely on this route to demonstrate compliance on sites where NHBC is providing building control and warranty services.
The main issue seems to be: “it’s all about competency of the people producing the reports and those who review”. Concerns have also been raised within the industry that SQPs must undertake a lot of work to become accredited and must put their neck on the block in signing off reports or making declarations. Any complaint made against them could be career compromising. And currently they do all this only for the regulator to choose to ignore them.
So the NQMS seems to be a stalling and there are further issues around whether the SQP should be in house or independent? Another question is once a report is signed off by the SQP, should the reviewer (the local authority) be competent enough to review their decision?
At Ground & Water we are preparing for full implementation of NQMS despite the doubt and teething problems that currently surround it. We will be able to offer it should it be required.