No litter inspections carried out by the Highways Agency
Slip roads cleaned, on average, only once every 10 months!
Verges only once every 4 months!
In January 2014 Andrew Edgington wrote to the then roads minister, Robert Goodwill MP to inform him that J1 of the M32 near Bristol had not been cleaned for over 2 years.
By the Summer things had not got any better and Andrew’s MP, Steve Webb, wrote to Graham Dalton, the Chief Executive of the Highways Agency.
He received a reply from the Agency’s Executive Director Network Delivery and Development, David Brewer. Mr Brewer said they were getting increased reports from the public about litter in the South West.
However he also assured Mr Webb that “The M32 is litter picked at least every month“. But what does that mean? Andrew decided to write to Mr Brewer with some follow up questions. The answers he received are most revealing.
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Question
Do Highways Agency staff, as opposed to your contractors, carry out any formal routine litter inspections? If so, can you let me have a copy of the document specifying the procedures adopted in carrying out this task as well as sample copies of the resultant reports.
Answer
The Service Provider Skanska is responsible for carrying out litter inspections on our behalf.
Observation
One must conclude from this brief response that the Agency do not carry out any such inspections. In which case how can they tell whether Skanska are doing what they are being paid for?
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Question
When you say the M32 is litter picked at least every month do you mean every section of every verge (including slipways and the roundabout at the junction with the M4) is litter picked or just that some cleaning takes place every month?
Answer
The litter is picked on sections of the M32 where litter has accumulated, to bring the verges up to grade B, following the Environmental Protection Act 1990 Code of Practice on Litter and Refuse.
Observations
How does Mr Brewer know that litter picking takes place in this manner if the Agency do not carry out routine inspections?
He has not answered Andrew’s question. One must therefore conclude that the M32 is not cleaned from end to end every month, just that some cleaning takes place.
The Agency are fond of saying that things are done in accordance with the Litter Code of Practice. The Code however is a guide for Duty Bodies – not their contractors. Section 9.0 says that “Duty bodies are expected to set their cleansing schedules so that they meet the duty to keep their relevant land clear of litter and refuse”. The Agency have not done this.
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Question
Could you please let me have copies of the reports recording which sections were cleaned covering the period January 1st to June 30th this year.
Answer
I also enclose a copy of a spreadsheet showing the litter picking records covering the period 1 January to 30 June 2014
Observations
An analysis of these records show:
- Of the 14 slip roads only 7 were cleaned (or partially cleaned) in the 6 months although one was cleaned twice. At this rate each slip road would on average only be cleaned only once every 10 months.
- The main carriageway verges were cleaned at an average rate of only once every 4 months
- The verge of the large roundabout at the junction with the M4 was cleaned only in January and March. Its central reservation was only cleaned in March and June.
- The central reservation of the main carriage way was cleaned once with one section cleaned twice.
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Question
Can you please let me have a copy of the procedures your contractors employ for inspecting and litter picking the verges, slip roads and central reservations.
Answer
Please find enclosed a copy of the Area 2 Maintenance Requirement Plan Part B11 Sweeping and Cleaning.
Observations
This document is prepared by Skanska and states how they will meet their contractual cleansing requirements.
It says “No detailed inspections relating to sweeping and cleaning will be undertaken” (4.1) but under “Targeted inspections” it says “The network condition in relationship to cleanliness will be assessed through driven inspections of applicable routes on a monthly basis.” and that “Cleanliness will be assessed in accordance with the requirements detailed in the Code of Practice on Litter and Refuse “(4.2)
This is all a bit vague. Does it mean the service provider will inspect every section every month or just do some inspecting every month in ares they target? What are applicable routes? How can they assess the cleanliness of downward sloping embankments in a drive by inspection? How will they grade the land between two 100 meter marker posts if only a small section is defaced by litter? Will it be graded according to the worst section or given an average grading?
Under Defect Management it says “Restoration to the standard detailed within AMOR Part 15 deliverables will then follow.” The AMOR document says that they should restore to Grade B from Grade C within 28 days. Even if this procedure was carried out scrupulously it would simply not be sufficient to comply with the Agency’s statutory duty under EPA S89(1).
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Also see: Area 2 – M5 – James Miller exposes substandard performance
Peter Silverman
12th September 2014
