Submissions
ASBG comments focused on the generic definitions of class 3 flammable liquids, class 8 corrosives and class 9 miscellaneous. ASBG called for simpler means in which to assign a UN NOS number to a waste. Under current ADG Code requirements any substance must have the tests undertaken before a UN NOS number can be assigned. This is extremely difficult when managing wastes, especially hazardous wastes. A number of minor changes were also recommended largely dealing with hot liquids such as bitumen.
 Submission On the 7th Edition Australian Dangerous Goods Code | 72 kB |
ASBG generally supports the thrust of this regulation but wishes a number of areas to be clarified. These include the use of new land pollution provision (s142A) under the POEO Amendment Act and the way in which licenced sites will be covered by the regulation. ASBG was also cautioned the DEC that many smaller sites have underground tanks and may not be aware of the require provisions to mandate ground water monitoring wells and integrity checks on such tanks.
ASBG supports some the main issues identified in the discussion paper on the use and abuse of the NEPM. Too often jurisdictions have used the investigation criteria for clean up levels, which in most cases is too conservative. ASBG supported the thrust to introduce remediation levels across the NEPM to provide better guidance to its users. ASBG also considers the NEPM is an evolving document that will grow with more research on new and existing substances.
| Submission On the Assessment of Site Contamination NEPM | 62 kB |
ASBG Submission On the Productivity Commission's Draft Waste Review Report
ASBG largely supports the Productivity Commission's views on the way in which waste is handled by government policy. However, there is too much momentum behind the current poor waste strategies, which will cost Australian's more and may also lead to perverse outcomes where environmental harm is increased. We strongly support the need for better data on all types of wastes and where they go. An example, of the lack of data on waste is the work ASBG has done on contaminated soils sent to landfill and the counter waste minimisation policy regulations, which encourage it. The NSW waste levy is especially criticized as well as the extremely low proportion of revenue that is returned to waste research and evaluation.
| Submission On the Productivity Commission's Draft Waste Review Report | 140 kB |
ASBG supported the proposed name change for the National Pollutant Inventory (NPI) to the National Emissions Inventory. The main issue addressed was the proposed inclusion of transfers. Transfers include the NPI substances that appear in waste and wastewater streams set to another party who usually treat or dispose of the materials. ASBG considers there are 2 types of approaches to generate NPI data for transfers, both of which are undesirable. As wastes a notoriously variable the use of estimation techniques, based on a handful of analysis will provide meaningless data. If on the other hand NPI data was collected to a meaningful level, this would be very costly and lead to the export of Australian jobs.
