ASBG's submission focused on the extremely broad application of the EPA's Proposed Minimum Environmental Standards in the Scrap Metal Industry (MSSMF). It is designed to capture any site, licensed or not it could capture service stations to steel refineries.  MSSMF will also set a precedent when it is published for many other industrial sites, both large and small, consequently, its design has considerable implications.  It is also considered too prescriptive, whereas ASBG recommends a performance  and risk based approach in managing environmental issues.  The need for roofing, hardstands and prescriptive bunding should be removed as they are contrary to Australian Standards covering dangerous goods.  There are many other issues and details raised.

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