Title: A Risk-Based Approach to Utilities Excavation Waste Classification
Author: Philippa Sherrell, Recycle it Global Ltd (RIG)
Date: May 2025
Executive Summary
This white paper presents an overview of the newly approved Street Works UK (SWUK) Material Classification Protocol. Developed in response to limitations with RPS 211 and WM3 methodologies, this protocol introduces a standardised, risk-based approach to classify waste from utility excavations. Officially endorsed by the Environment Agency, the SWUK Protocol ensures regulatory compliance while enabling more efficient handling and disposal of excavation waste from unplanned works.
1. Introduction
The classification of excavated waste is a legal requirement under UK waste regulations. Until recently, utilities relied on:
- RPS 211 for unplanned works
- WM3 Technical Guidance for planned works
However, these methods posed logistical challenges, especially for rapid-response excavation. Recognising the need for a more practical solution, Street Works UK (SWUK) collaborated with the Environment Agency to develop a new protocol focused on risk assessment.
2. Protocol Development and Approval
In January 2025, the Environment Agency officially approved the SWUK Protocol following successful trials and the submission of the SWUK Phase 3 report. This approval allows for the withdrawal of RPS 298 and RPS 299 by 30th September 2025, with a six-month review period to monitor implementation.
3. Protocol Overview
The SWUK Material Classification Protocol follows a structured process:
3.1 Desktop Risk Assessment
Conducted pre-excavation, this step checks for:
- Historic sampling data within 50m
- Proximity to risk sites (e.g. gasworks, petrol stations)
3.2 Site Assessment
Performed post-excavation, it involves visual and sensory inspections:
- Asbestos presence
- PAK spray on asphalt (positive = Band 1 or 2)
- Litmus pH test on soil (positive = pH 1-4 or 10-14)
- Odours, discolouration, oil sheen indicators
3.3 Classification
Materials are rated:
- Green (Non-hazardous)
- Red (Hazardous)
Separate assessments are made for:
- Bituminous layer
- Sub-base layer
4. Sampling and Testing Requirements
To validate the accuracy of assessments:
- 1% of 2023-equivalent qualifying excavations must be sampled in 2025
- Sampling must follow strict guidance, using UKAS-accredited laboratories
- Sampling frequency may increase based on performance
Sampling Guidelines:
- 1 sample per 10m3 mobilised material
- Bituminous and sub-base sampled separately
- Sampled within 24 hours of mobilisation
5. Regulatory Compliance and Waste Management
Waste Segregation
Waste must be segregated during:
- Excavation
- Storage
- Transportation
Documentation
- Waste Transfer Notes must include:
- Work permit number
- Excavation reference
- Hazardous loads (Red) require Consignment Notes
Record Keeping
- Records (including RAs and test results) must be retained for 3 years
- Classification results must be uploaded to Street Manager
6. Monitoring, Performance & Enforcement
SWUK and the EA require:
- A quarterly submission of a performance dashboard
- Monitoring of site assessment accuracy via lab-confirmed samples
Organisations with two consecutive ‘Red’ quarters must pause protocol use until compliance improves.
7. Transition Timeline
| Milestone | Date |
| EA Approval | January 2025 |
| RPS 298/299 Expiry | 30 September 2025 |
| Full Protocol Compliance | From October 2025 |
8. Conclusion
The SWUK Material Classification Protocol represents a significant evolution in excavation waste management, aligning with environmental regulations while streamlining operations. By integrating risk assessment, visual testing, and a structured classification approach, utilities can now classify waste accurately and efficiently in both planned and unplanned scenarios.
At Recycle it Global (RIG), we are actively designing in-house processes that integrate these changes into our operations. Using modernised digital technologies, we are embedding this protocol into our workflows, enhancing both operational efficiency and customer experience.
References
- Desktop Risk Assessment Template
- Site Assessment Checklist
- PAK Spray and Litmus Test Guidelines
- Sampling Requirements Summary
- Quarterly Results Log Template