Due to concerns regarding contaminated recycled concrete being reused as fill, the New Jersey Department of Environmental Protection (NJDEP) recently issued guidelines that require the characterization, via sampling and analysis, of concrete at all demolition and construction sites overseen by NJDEP’s Site Remediation and Waste Management Program (SRWMP). Concrete sampling and analysis is required when concrete is designated for either recycling or beneficial use. This characterization requirement applies to demolished buildings, concrete roadways and related structures such as sidewalks and curbing, and will have a significant impact on the cost and feasibility of a developer’s concrete reuse and recycling practices.

The NJDEP developed the concrete sampling and analysis guidelines to ensure that concrete which is reused or recycled is free of contamination and will not contaminate otherwise clean properties. A number of recent high-profile incidents in which contaminated recycled concrete was reused as fill and contaminated previously clean properties has prompted the NJDEP to require sampling and analysis of all concrete that is intended to be reused or recycled. Failure to follow the new concrete sampling and analysis requirement could result in enforcement actions by the NJDEP, and leaves a developer open to potential future environmental liabilities associated with concrete that is reused or recycled from their property. Contact an environmental professional to ensure that concrete intended for reuse or recycling is sampled and categorized in accordance with NJDEP guidelines.