NHBC’s Technical Guidance for 2024 adds quality standards for Engineered Fill

27 Mar 2024

The National House Building Council (NHBC) recently launched its Technical Standards for 2024 and, new to this latest edition, is a quality benchmark for earthworks which must be met by all new developments registered under its scheme.

NHBC’s Technical Guidance for 2024 - Enabling works

Focused on Engineered Fill, chapter 4.6 of the new guidance continues the advancement of build quality and standards in housebuilding and development, bringing the industry in line with a benchmark routinely met by McAuliffe in our brownfield services.

In this guide, McAuliffe’s Managing Director John McAuliffe takes a look at the new quality standards and what they mean for the industry.

Everything You Need To Know About The NHBC Chapter 4.6 – Engineered Fill

The National House Building Council (NHBC) has recently launched its 2024 edition of Technical Standards, which includes a brand new chapter of guidance that provides a quality benchmark that all new developments must meet for earthworks.

Specifically focusing on Engineered Fill, Chapter 4.6 of the new guidance has been launched to continue the advancement of build quality and standards in housebuilding and development.

They say you can't build on weak foundations, and as a leading expert in remediation and enabling works for brownfield development, it’s a philosophy we live by.

John McAuliffe, Managing Director of McAuliffe Group - which has been providing a complete brownfield service and supporting the country’s largest housebuilders, developers and contractors on new housing developments, major infrastructure projects and legacy clean-ups for more than 50 years - takes a look at the new standards and what it means for the industry.

Why have the new standards been introduced?

When new legislation or guidance is unveiled by organisations responsible for monitoring industry standards, there’s a tendency to think the worst, as concerns grow over ever-more hoops to jump through, additional costs, hassle and headaches.

But for those who have already been working to the highest possible standards of brownfield site preparation with Engineered Fill, the guidance set out by NHBC in its brand new Chapter 4.6 is really business as usual.

The chapter lays out the NHBC’s Technical Requirements for Engineered Fill along with recommendations for developments where buildings are founded in Engineered Fill, or where Engineered Fill is used to support external works and roads or pavements.

For some companies, the rigid standards set out in the document will mean the initial investigation, testing, design costs and timescales of site development are higher. But these moves are being made for the wider good of the industry and its reputation, as well as future occupants - while leaving companies far less susceptible to any future comebacks from ill-prepared land that would cost far more in the long run and not allow the NHBC to issue a compliant CML for each relevant property. It is helpful to consider the benefits of the thorough strategic planning outlined in the document alongside the alternate options and their costs to realise why they are so important.

On construction sites, cut and fill or earthworks are often required for a number of reasons, including the formation of development platforms or below-raft foundations on sites with shrinkable clays and trees in lieu of deep trench foundations. But before the NHBC’s new guidance announced in January 2024, there had been little or no official standards on achieving performance standards for Engineered Filling or suitable foundations bearing onto Engineered Fill for housing other than application of the Specification for highway works.

There’s a number of considerations when implementing Engineered Fill on residential projects and without detailed design and preparation, developers can find themselves with land that is unsuitable for the intended use.

Ahead of releasing this new guidance, NHBC revealed that there had been numerous occasions where companies had failed to adequately identify, address or mitigate geotechnical risks while site specifications frequently lacked sufficient detail or neglected residual geopolitical hazards.

This new chapter aims to provide guidance and consistency to the industry. And as a company that has built a formidable reputation founded on attention to detail in all aspects of the pre-acquisition, preparation, sale and development of brownfield sites this can only be a welcome thing.

Striving for a best practice approach, earlier contractor involvement and aligned strategic thinking.

Without any official national standards in place with regards to front-end remedial strategies, it is not surprising that documentation submitted to NHBC for land development ranged from the brilliant to the downright dreadful.

In some cases there has been little or no understanding of geotechnics, with risks either dismissed or not properly mitigated against, while similarly some back-end verification reports have been incomplete or over brief.

It is only right, then, that NHBC has taken the lead to ensure a standard best practice is agreed upon and adhered to. In short, companies must display a clear alignment and understanding of proposed sites, the required improvement measures and the efforts taking place in the intended building foundations. It is joining the dots from inception to concept with a clear strategy running through the work.

The new guidance gives a benchmark of what is expected with the aim of improving standards of earthworks in the housebuilding industry and therefore reducing the chances of future claims or disruption for the homeowner.

The key guidance to ensure industry best practice.

Failing to prepare is failing to prepare, as they say - and details found in the guidance are nothing new for companies like ours. They do, however, confirm the understanding of what we already know about site preparation and builds on this to provide a performance standard all companies must meet.

The guidance aims to ensure:

-Ground investigation is appropriate to the proposed development, site conditions and nature of the filling

-Geotechnical ground models are developed and appropriate for the proposed development and underlying ground and groundwater conditions

-Engineered Fill is placed to a suitable earthwork specification

-Appropriate geotechnical laboratory acceptability testing and in-situ compliance testing is undertaken

-Evidence is documented and verification provided

When does the new guidance come into force?

The new guidance was introduced in and becomes effective from 1st January 2024.  However  for complicated tenders or ongoing earthworks signed prior to this date , the NHBC has said that projects will initially be monitored on a site-by-site basis. All new earthworks from January 2025 should meet the new standards set out by NHBC.

If nothing else, the guidance highlights the importance of working with experts who understand the rules, including a suitably qualified engineer responsible for the design and specification of earthworks taking into account the future of the development and type of building foundations.

Earthworks are a critical component of residential development, and the NHBC is rightly requesting that design and specifications shall be produced in a clearly understandable format, including all relevant information, to be distributed to all relevant parties.    

Under the new guidance, this detailed strategy documentation, including relevant drawings, is required eight weeks ahead of any filling or associated works so potential issues can be overcome well in advance of any machine touching the ground, while retrospective reviews of already completed works will no longer be considered acceptable. All Engineered Fill material classification should be clearly stated, while the use of recycled aggregate as fill should comply with BRE Digest 433 or other suitable guidance as agreed with NHBC.

An earthworks method statement, from the Earthworks Contractor or equivalent, should be produced and issued to all relevant personnel, which describes how the requirements of the specification are to be delivered, the plant to be used and arrangements for supervision and reporting.

In addition, the following supporting information should also be provided to NHBC:

-Desk study and ground investigation report

-Materials classification (acceptability) assessment

-Geotechnical design report or geotechnical design statement (depending on which is relevant and the complexity of the earthworks project)

With the level of detail now required by the NHBC ahead of works commencing, developers should be aware of what that means for them but more importantly the additional time and preparation required to assess land and make suitable submissions to allow developments to go ahead.

For example, the geotechnical design should be prepared by a suitably qualified and experienced engineer who should assess the ground and be satisfied that it is suitable for Engineered Fill.

Prior to earthworks commencing, the formation level should be inspected and tested in accordance with the earthworks specification, while unsuitable ground conditions need to be assessed, including presence of obstructions, compressible soils, unstable ground and groundwater.

Details are required of the acceptability of materials to be re-used as Engineered Fill. In particular this includes for clays with a plasticity index of less than 40% (less than 65% in SWH 600) and undrained shear strength in excess of 40kPa, materials requiring written NHBC acceptance, such as soils with a silt content greater than 20% and unsuitable materials, such as materials with high sulphate content, where Total Potential Sulphate (TPS) is in excess of 0.25% and also structureless chalk (with grades Dm and Dc).

Where the scope of the earthworks is defined as Geotechnical Category 1 (Geo Cat 1 - simple), a Geotechnical Design Statement (GDS) must be prepared and submitted to NHBC.

Most earthworks are classified as Geotechnical Category 2 (Geo Cat 2 - conventional) in accordance with BS EN 1997- and are required to be designed by an appropriately qualified and experienced person.

Where the scope of the earthworks is defined as Geo Cat 2 or 3 (complex), a Geotechnical Design Report (GDR) needs to be prepared and submitted to NHBC.

The Earthworks Specification should clearly describe the design requirements to be satisfied, such as detail of how the Engineered Fill is to be placed and what criteria will apply to prove its compliance.

Such a specification should be practicable and capable of both measurement and enforcement and should be capable of being monitored by an

effective form of quality assurance procedure.

The three traditional types of standard Specifications for Earthworks are generally acceptable:

Method:- not acceptable to support buildings

End Product:- linked to Geotech properties, so suitable to support buildings

Performance:- must be used with End Product.

An expert knowledge is required to judge the type of specification required and should be based on industry guidance such as the Specification for Highway Works (SHW), BS EN 16907 Earthworks, ICE Publishing – Earthworks: A Guide 2nd Edition, or on trials/previous experience, that is acceptable to NHBC.

It is essential that the quality of the earthworks and building foundations are aligned.

The Emphasis on Verification and Reporting

Under the new standards, a comprehensive 18-point Earthworks Verification Report for the filling works should be provided to the NHBC as soon as practicable, providing an interpretation and assessment of the factual data contained within the report, as well as a detailed summary of the works undertaken, including testing.

It should include clear tables and graphical representation on compaction data as compared to the specification, with an independent third party needed to verify any work done for reinforced strip foundations.

Under the new rules, verification testing of engineered fill must be undertaken to confirm compliance with the earthwork specification and its fitness for purpose.

Items to be considered should include:

  • Fill classification
  • End product testing
  • Performance testing
  • Settlement measurement 
  • Testing frequency

The NHBC now requires testing to be conducted at random locations throughout the entire fill depth to ensure consistency across the site, while higher risk locations where the Engineered Fill was placed in less suitable conditions must have a dataset to confirm compliance.

Developers must also file a detailed Earthworks Verification Report to the NHBC on completion of the Earthworks filling and testing, the contents of which, if appropriate, are agreed in advance of the work being done.

The Earthworks Verification Report should include:

  • The companies, specifications, methods and materials involved
  • Survey records
  • Records of progress and changes
  • Test results and certificates
  • Evidence that the works comply with the earthworks specification and are suitable for the proposed foundation types, where applicable
  • Information for the builder, such as drawings of remaining obstructions

Under the new guidance, the NHBC has said verification reporting should include some interpretation and that solely factual reporting of appended test data will not be accepted.

Key Takeaways for Housebuilders / Developers:

  • Timings – keeping you compliant without programme delays
    • In order to maintain compliance and avoid delays, it is necessary to undertake additional preparations.
    • This includes preparing a 14-point Earthworks specification and submitting it 8 weeks before commencing works. Including areas such as:
      - The defined scope of earthworks including desk studies and ground investigation reports
      - The intended use of engineered fill being clearly defined
      - Classification testing
      - The form and proposed content of an earthworks verification report
    • It is crucial to classify materials adequately for this process. Site investigations often lack sufficient material classification, so an additional 6-8 weeks should be allowed for this step. If alternative methods like rapid impaction compaction (RIC) are being used, approval should be obtained 8 weeks in advance, along with details of site trials.
  • The details – what you need and who should prepare it (the importance of working with trusted partners)
    • It is important to be aware of the requirements and who should handle them, emphasizing the importance of working with experts.
    • Depending on the complexity of the site, a geotechnical design statement or report may be required, especially if engineered fill is being used to support building foundations.
    • The type of specification needed should be determined, whether it's related to compaction methods, end products, or performance. Generally, a settlement of 25mm over 60 years is expected for foundations and threshold areas.
    • The Contractor should provide an earthworks method statement, and the modification of fill material using lime or cement is limited to a maximum of 2%.
    • The developer is responsible for ensuring suitable supervision, sampling, and testing, while also following the Specification for Highways Works. Performance testing, including plate tests with diameters of 600-900mm, is required, excluding CBR tests.
  • Verification – how to get reporting right
    • Accurate reporting and evidence is crucial.  You need to demonstrate on going testing and supervision throughout the whole earthworks.
    • Earthworks which are carried out on a piece meal basis by say groundworkers may not be able to keep the correct and accurate records required where management of uncontrolled stockpiles affects quality.
    • Better to have an overall/site-wide cut/fill strategy and delivery which leads to better quality control of earthworks, testing and supervision which can be signed off early in the scheme.
    • On going material tracking and compliance with any agreed Materials Management Plan
    • A comprehensive 18-point Earthworks Verification Report, as outlined in the specification and agreed format, needs to be prepared.
    • For reinforced strip foundations, an independent third party should conduct the verification report.  This will also allow you to rely on their advice.

NHBC’s new chapter on Engineered Fill might seem like a hefty addition to industry standards and lead to fears from developers that its inclusion will lead to soaring costs.

But founding in Engineered Fill can not only reduce project costs with regards to foundation options, but also reduce the requirement to dispose of material off-site by maximising re-use on site. As well as cost savings, this is also a more sustainable option which ensures valuable soil resources are re-used rather than disposed of, and limits the amount of truck movements to and from sites.

For companies such as McAuliffe - that has been practising the tying together of thorough ground investigation, testing, geotechnical design, material management, supervision, sign-off and verification for many years - it really should be business as usual adopting NHBC’s Chapter 4.6 for Engineered Fill to assist housebuilders and developers to deliver more sustainable projects of the highest standard. And it can only be a good thing that the others catch up to meet those standards too.

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