The submission supports the general thrust of the National Standard process, but warns of the need to use high precision in setting risk levels, but not overly cautious resulting from incomplete assessment.  ASBG raises concerns with the overlap with other environmental standards and documents.  As the National Standard will be setting Australia wide standards, these will be by their nature more conservative than site or use specific assessments.  Case in point is the application of Contaminated Land NEPM investigation levels which are very site specific in their risk assessment processes. Hence, ASBG recommended that that if more surgical such as site and use specific risk assessments are used they can replace the more conservative unilateral limits provided for in the National Standard. ASBG also argued that the benefits of difficult to substitute chemicals be considered and balanced with the environmental risks.  The example of fluoridated compounds for fire fighting foam has far superior performance over fluorine free foams.  However, the risk assessment process targets poly fluoridated compounds regardless of their benefits.  

Attachments:

ASBG's Submisson on National Standard for Environmental Risk Management of In

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