MAN 03 - Responsible Construction Practices

BREEAM Accredited Professional (AP) – Retrospectively applying AP status - KBCN0308

The AP status cannot be applied retrospectively. The purpose of using an AP on a project is that they can advise and steer the development from the outset to maximise its BREEAM and sustainability performance for the least cost/risk. If early AP appointment and involvement does not occur then the aims and criteria of this BREEAM issue are not being met.

BREEAM AP – Change of BREEAM APs/Sustainability champions during project - KBCN0295

Whilst it would generally be preferable to retain the same individual in the role of BREEAM AP/Sustainability champion throughout the design and construction of a particular project for the purposes of continuity, we appreciate that this may not always be feasible. It is therefore entirely appropriate that the three credits available for using BREEAM APs/Sustainability champions can still be awarded where the individual performing the role changes (provided the ongoing involvement of an AP/SC is maintained in accordance with the criteria).

BREEAM AP and BREEAM assessor – conflict of interest - KBCN0196

An individual can be appointed as a BREEAM/HQM Assessor and BREEAM AP/Sustainability Champion for the same project, where the Assessor also holds current and applicable AP/Sustainability Champion credentials. If this route is chosen, it must be made clear when submitting the assessment that both roles are being carried out by the same person and confirmed how potential conflicts of interest are identified and managed. This will mean, when appropriate, that the assessment can be escalated to a more detailed level of quality assurance checking.

Certificate validity – EMS - KBCN1401

The requirement for the principal contractor to operate an EMS relates to the duration of operations on site. Certification against ISO 14001/EMAS must be valid at the Design Stage and Post Construction Stage submissions and cannot be expired, pending or applied retrospectively.

07/05/2021: Clarification on Design and Post Construction Stage added

Change in main contractor - KBCN0645

In situations where the main contractor changes mid-project, for example where the original contractor goes into administration and is replaced by another main contractor, it is acceptable for the post-construction credits to be awarded based on the new contractor providing information on their activities. This is providing the project is yet to start on site. This is in effect assessing the issue using the Post Construction Assessment route instead of a Post Construction Review. However, if the project has already started on site and information about the site activities of the previous contractor is not available it would not be appropriate to award the credit solely based on the new contractor activities.

Changes to CCS – January 2022 - KBCN1500

UKNC2011, UKNC2014, RFO2014 and Domestic Refurbishment 2014 schemes: In response to the 2022 changes to the structure and scoring in the CCS, the adjusted points for credits are as follows for each of the three new sections (Community, Environment, and Workforce): One credit requires a minimum of 9 points per section and 27 overall. Two credits require a minimum of 11 points per section and 35 overall. Exemplary credit requires a minimum of 13 points per section and 39 overall. UKNC2018, UKNCV6 and HQM ONE schemes: No changes have been made to the criteria or the requirement to demonstrate compliance with items g, p and q for the exemplary credit. GN33 has been updated to demonstrate the mapping of the updated CCS to these schemes, see KBCN1215. For assessments not following CSS, the criteria remain unchanged. More information on the changes to the CCS scheme are outlined on the CCS website.

12-Apr-2023 - Updated to clarify the applicability of the new guidance.
28-Feb-2023 - Note updated to refer to the updated version of GN33.
29-Apr-2022 - Note added to clarify that this information supersedes the requirements in the technical manuals.
25-Mar-2022 - Updated to provide the new scoring requirements for BREEAM standards.

Changes to CCS scoring system – January 2019 - KBCN1271

In January 2019, the Considerate Constructors' Scheme (CCS) modified its scoring system, so that innovations are more easily recognised and rewarded. This change does not impact on the established score thresholds, for awarding credits in relevant BREEAM Schemes. For further information on CCS, please follow this link

08/10/21 CCS guidance on changes no longer available. Substituted for a link to main CCS website.

Considerate construction – corporate registration - KBCN0905

Where credits are awarded for the assessment of the site against a compliant scheme, corporate registration, which assesses the contractor's overall operations and performance across multiple sites, is not in itself recognised. To award considerate construction credits, BREEAM requires the assessment of the specific assessed development, in line with the criteria.

Considerate Constructors Scheme – Phased developments - KBCN0328

The Considerate Constructors Scheme does make provision for phased developments within the registration process, allowing each phase to be registered separately. They make this provision to allow for very large developments that may go on over several years. It should therefore be possible for the developer to register the site in phases, so that CCS certificates can be submitted for BREEAM assessed buildings, without having to wait for the completion of the final phase.

Dedicated off-site manufacturing and fabrication - KBCN0795

Energy use, water consumption and materials' transport data from 'dedicated off-site manufacturing or fabrication' should only be accounted for if the manufacturing process has been specifically developed for the project under assessment, excluding data from manufacturing 'off the shelf' products. The construction impact monitoring should only consider the data that has been specifically generated by the activities of the project under assessment.

Definition – Project value - KBCN0552

The term ‘project value’ represents the total project cost, which includes all costs such as construction, design, land acquisition, etc.

Definition of NHS Sites - KBCN0946

'NHS sites' refers to projects which are primarily funded in the long term by the National Health Service. CN4 applies to any facilities which are owned and managed privately but which source the majority of their income from the NHS.

Design team meetings via conference call - KBCN0201

Design team meetings can be conducted via conference calls.

It can be difficult for design team members to be in the same place at the same time. Conference calls are a more sustainable way to conduct meetings.

Environmental management – no principal contractor - KBCN1213

In order to achieve compliance where there is no principal contractor, the criteria must be met by the party which fulfills an equivalent role in managing the construction. The intent of the criteria is to ensure that the site is managed in accordance with demonstrably sustainable principles by the party having overall control of site management and operations.

Environmental management – Timing of obtaining ISO 14001/EMAS certification - KBCN0229

The contractor must be in possession of the ISO 14001/EMAS certification prior to starting works on the development under assessment. This is to ensure that the aim of the issue, to ‘encourage construction sites managed in an environmentally sound manner’, can be achieved. To uphold the robustness of BREEAM, the date of certification to ISO 14001/EMAS must be prior to initial works starting on the site.

Evidence requirements – responsible sourcing of materials at post-construction - KBCN1599

Whilst the UK BREEAM manuals are less prescriptive in the evidential requirements to allow flexibility, to ensure consistency across the schemes, it is expected that robust evidence should be provided to verify the source of any certified materials and how the assessor has confirmed the products and manufacturers used. Evidence supplied at post construction stage must reflect the completed building and confirm the responsibly sourced materials that have been procured and installed on the project. Supporting documentation is required to validate letters of confirmation or schedules of materials. Evidence provided could include proof of purchase, for example, invoices, delivery tickets, purchase orders or correspondence from suppliers. This may be an example for each material sourced, rather than every delivery ticket for instance. Alternatively, evidence of the use of the responsibly sourced materials may include as-built drawings, O&M documentation or site photographs.

FSC and PEFC Mixed Sources certified timber - KBCN00091

Products labelled:

FSC Mix or
PEFC Mixed Sources

Meet the BREEAM responsible sourcing requirements. This means any such products:

In HQM, and in BREEAM NC 2016 or older schemes: meet the prerequisite for legally harvested and traded timber.
In BREEAM NC 2018 or newer schemes: meet the prerequisite for legal and sustainable timber.
In all schemes: can be used to demonstrate responsible sourcing.

Products carrying the FSC Mix label contain at least 70% FSC certified and recycled material. These products may contain a small proportion of FSC Controlled Wood (KBCN00054). However for BREEAM compliance, the FSC Mix label is sufficient to meet our requirements.

14-Mar-2024 - Wording clarified and expanded. Relevant prerequisites and requirements clarified. Scheme applicability updated.

FSC Controlled Wood - KBCN00054

The FSC Controlled Wood label minimises the risk that wood comes from illegal or controversial sources, however it does not eliminate this risk. Therefore, products which are:

Labelled as FSC Controlled Wood or,
Where the majority of material in a product is comprised of FSC Controlled Wood,

Do not meet the BREEAM definition of responsibly sourced. Where FSC Mix labelled products contain FSC Controlled Wood, see KBCN00091. This means that any such products:

In HQM, and in BREEAM NC 2016 or older schemes: do not meet the prerequisite for legally harvested and traded timber.
In BREEAM NC 2018 or newer schemes: do not meet the prerequisite for legal and sustainable timber.
In all schemes: cannot be used to demonstrate responsible sourcing.

14-Mar-2024 - Wording clarified and expanded. Relevant prerequisites and requirements clarified. Scheme applicability updated.

Legally harvested and traded timber – Examples - KBCN0956

The following examples are considered compliant for BREEAM purposes. Legally harvested:

Evidence of compliance with the CPET (see here, timber bought inside the UK only)
FSC, PEFC or SFI certification
Evidence of compliance with the EUTR (timber bought inside the EU only)
Risk assessment/due diligence documentation demonstrating a low risk of non-compliance with the ‘legally harvested’ requirements given in the manual.

Legally traded:

Evidence of compliance with the CPET (see here, timber bought inside the UK only)
FSC, PEFC or SFI certification
Risk assessment/due diligence documentation demonstrating a low risk of non-compliance with the ‘legally traded’ requirements given in the manual.

Legally harvested and traded/Legal and sustainable timber – Reclaimed/recycled timber - KBCN0654

Timber should, wherever possible, be sourced in accordance with the UK Government’s Timber Procurement Policy. However, if for reclaimed timber the original procurement details are unobtainable, robust evidence to demonstrate it has been reclaimed can be acceptable. The government UK Government Timber Procurement Policy Timber Procurement Advice Note (6th edition) states: As an alternative to demanding timber and wood-derived products from a Legal and Sustainable source, Contracting Authorities can demand ‘recycled timber’. Documentary evidence and independent verification will also apply to recycled timber and recycled wood-derived products but will focus on the use to which the timber was previously put rather than the forest source. And defines ‘recycled timber’ as: “…recovered wood that prior to being supplied to the Contracting Authority had an end use as a standalone object or as part of a structure and which has completed its lifecycle and would otherwise be disposed of as waste. The term ‘recycled’ is used to cover the following categories: pre-consumer recycled wood and wood fibre or industrial by products but excluding sawmill co-products (sawmill co-products are deemed to fall within the category of virgin timber), post-consumer recycled wood and wood fibre, and drift wood. It also covers reclaimed timber which was abandoned or confiscated at least ten years previously.” As per the above policy, BREEAM requires “Documentary evidence and independent verification” that all reclaimed/recycled timber products meet the definition of ‘recycled timber’ given above.

01/06/2020: Amended to clarify and extended applicability to Mat 03

Pollution Prevention Guidance documents - KBCN1051

On 17 December 2015, the Pollution Prevention Guidance documents (PPGs) published by the Environment Agency were withdrawn. These can be found in the National Archives or on the Scottish Environment Protection Agency website where they are still current documents. Many BREEAM schemes and the Home Quality Mark refer to these PPG documents as they are still considered to be best practice even though they have been withdrawn. Projects should continue to use the PPGs referenced in the relevant manuals. BREEAM will continue to review this situation and provide an update as and when appropriate.

26 09 2018 Made applicable to Man 03 and Pol 03 in UK NC2018 and Man 03 in UK NC 2011, UK NC2014 and UKRFO 2014

Responsible construction practices – Multiple contractors on the same project - KBCN0352

It is the site that must comply with BREEAM issues rather than any individual contractor. Several different contractors may have obligations to meet compliance criteria. One of the contractors and/or site managers may have responsibility for ensuring compliance during site operations. It is ultimately the client/project team's responsibility to determine and demonstrate compliance.

Responsible construction practices – CCS certification not possible - KBCN1505

Criterion 8 allows small scale or low value works to be assessed without independent certification for considerate construction. Criterion 9 requires projects to pursue independent certification if they fall outside the issue definition for small scale or low value. If the project is not small scale or low value, but still falls outside of the scope of independent certification, then criterion 8 can be applied, regardless of the size or value of the works. This situation may arise, for example, where a short programme of works or strict site security requirements preclude CCS certification. Robust additional evidence will be required to support this approach.

20 Apr 2023 - Updated to account for strict site security as justification.

Scope of construction works included - KBCN0642

Only the scope of works the principal contractor is responsible for needs to be considered in the assessment of this Issue. This also includes works carried out by sub-contractors that are engaged by the principal contractor.

03.11.2021 Above text added to issue 2.0 of the UK RFO technical manual. Text remains applicable to all previous issues of the manual.

Simple buildings – criteria applicability - KBCN0904

The technical manual criteria applicability is partially incorrect and should read as follows: 3. Criteria 9 to 15. 4. Criteria 16, 17a, 17b, and 18. 5. Criterion 17c. As a minimum, this must cover inert materials, metals and mixed waste groups.

Technical manuals to be updated accordingly in next reissue.

SSM replacing BREEAM AP for on-site monitoring - KBCN0601

It is acceptable for a suitably qualified Site Sustainability Manager (SSM) to take over the monitoring of site impact role (Sustainability Champion (construction)) from a BREEAM AP. In some instances it may be more appropriate for an SSM to carry out the role of the 'construction' Sustainability Champion. Therefore where a BREEAM AP has provided design input, an SSM could take over the role to complete the on-site requirements.

Sustainability Champion role – Construction - KBCN0446

The intent of the Sustainability Champion role is to monitor and report on the project’s progress towards the relevant BREEAM target(s), over the course of the stated RIBA stages, in order to minimise the risks of possible non-compliance with the agreed BREEAM targets. To do this the Sustainability Champion should:

Ideally be site-based, or visit the site regularly and be authorised to carry out inspection and monitoring of the works relevant to their role
Monitor site activities with an appropriate level of frequency
Report regularly to the principal contractor and attend relevant project team meetings, identifying potential areas of non-compliance and recommending actions to mitigate these.

03.11.2020 Issue 2.0 of the UK RFO technical manual updated with the above text. It remains applicable to previous issues of the manual.

Transport of construction materials – Data and methodology - KBCN0413

To ensure comparability across assessments, the information completed in the scoring and reporting tool should be restricted to the minimum data specified in the technical manual. For the purposes of this BREEAM Issue, the distances reported should be calculated from the point from which the products or materials were sourced, whether this be directly from a manufacturer or from a builders' merchant/distributor:

For products or materials purchased directly from a manufacturer or quarry, for example, the distance should be calculated from the ‘factory gate’, including any intermediate transport.
For products or materials, which are purchased from a merchant or distributor, only the distance from their depot should be reported.

Where products cannot be sourced locally, for example on small islands, the transport required to import the materials or products can be discounted, and only the local onward transport to the site recorded. The aim of this requirement is to encourage developers to consider the impacts of transporting products and materials to site. As such, the criteria seek to address only those impacts, which can be influenced by the developer.

27.07.2018 Wording amended to add clarity.

Refurbishment and Fit Out / UK / 2014 / 01 - Management /