Background

The C4SL research project (Phase 1) provided technical guidance to support Defra's revised Statutory Guidance (SG) for Part 2A of the Environmental Protection Act 1990 (Part 2A). Part 2A was originally introduced to ensure that the risks from land contamination to human health, property and the environment are managed appropriately, with the revised SG being designed to address concerns regarding its real-world application. The revised SG presents a new four category system for classifying land under Part 2A, ranging from Category 4, where the level of risk posed is acceptably low, to Category 1, where the level of risk is clearly unacceptable.

Phase 1 Project

The Phase 1 project produced, demonstrated and communicated a methodology for developing C4SLs which represents as wide a consensus as possible in the field of land contamination risk assessment. The C4SLs represent a new set of generic screening levels for 6 contaminants which are more pragmatic (but still strongly precautionary) compared to the existing soil guideline values (SGVs) and other similarly derived numbers. The C4SLs consist of cautious estimates of contaminant concentrations in soil that are still considered to present an acceptable level of risk, within the context of Part 2A, by combining information on human health toxicology, exposure assessment and normal ambient levels of contaminants in the environment. Within the Phase 1 Defra publication, it was emphasised that further work to expand C4SLs for other contaminants would need to be led by industry.

Phase 2 Project

The Soil and Groundwater Technology Association (SAGTA) is leading a collaborative industry initiative which started formulating and developing a project framework in 2015.  Funding for this phase has been secured from SAGTA members, with in kind contribution from a number of consultants and a financial grant from the Society of Brownfield Risk Assessment (SOBRA) www.sobra.org.uk. The project officially started in 2018. Phase 2 will develop 19 C4SLs for a range of contaminants which have been selected following a consultative process choosing the contaminants which would be most useful to industry. Subsequent funding has been received from Environment Agency in 2023 to develop the 20th substance for PFAS. 

The full list of contaminants that C4SLs are being derived are as follows and those in green are now available to download (as pdf):

The project is being delivered by a consortium of partners which include the following:

Project Manager: CL:AIRE supported by Simon Firth (Firth Consultants Ltd) and Naomi Earl (Freelance Consultant)

Tier 1 Toxicologists: Sarah Bull (TARA Consulting); Camilla Alexander-White (MK Tox & Co Ltd) and George Kowalczyk (GK Toxicology Consulting).

Tier 2 Toxicologists: Natasha Glynn (Atkins); Gareth Wills (WSP); Jo Wilding (Independent); Laura Aspinall and Andrew Fellows (RSK); Melinda Evans (Soilfix); Adam Symonds, Duncan Grew & Peter Sheppard (Worley) and Kate Baker.

Exposure Modellers: Dave Brooks (Sirius); Gareth Barns (Geosyntec); Robert Reuter (Wardell Armstrong LLP); Catherine Cussell (RSK); Lucy Burn (Advisian) and James Lymer

Steering Group

The project is being overseen by a Project Steering Group, led by Hannah White on behalf of SAGTA and consists of representatives from the following organisations:

SAGTA, Defra, Welsh Government, UKHSA, Public Health Wales, Foods Standards Agency, Environment Agency, Natural Resources Wales, Homes England, Lancaster City Council, YALPAG, Wiltshire Council, Welsh Contaminated Land group, Mole Valley District Council, SoBRA, NHBC, AGS, EPUK, EIC and HBF.

Programme

The project will endeavour to deliver the C4SLs in a timely manner.  However as this project is relying on a lot of industry goodwill and until we know the exact hurdles that we may face, we will provide updates to industry as to how the project is progressing through the National Brownfield Forum minutes (www.claire.co.uk/brownfieldforum) and CL:AIRE News (https://www.claire.co.uk/home/news).