ASBG's submission on the draft PFAS (Per-and Polyfluoroalkyl Substances) National Environmental Management Plan recommended the need for a cost-benefit assessment of its impact, striving to optimise the environmental and health outcomes.  Of concern is the ultra conservative standards used for PFOS and PFOA, which are close to that for dioxin. As the PFAS NEMP will undertake a stocktake of PFASs it should take the next steps of assessing the infrastructure required to manage the waste soils and liquids to be generated.  ASBG is concerned there is simply not enough landfills and destruction facility capacity to manage the quantities that are likely to be generated.  A cost benefit study should consider these requirements and encourage innovation and remove planning approval road blocks.  There are issues with remaining stock of PFAs and how these should be managed especially where there is no replacement.  9 recommendations are made in this submission and quite a bit more work required obtaining a reasonable document.

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