ASBG prepared this submission on the POEO Amendment (Asbestos) Waste Bill 2018 which was not publically made available.  It contains a single change which is of concern, proposing the new s241(f) the presence of the asbestos in the environment, under the POEO Act.  ASBG is concerned this sets a precedence for the use of the unscientific application of the mere presence of asbestos in waste, rather than the use of a risk-based approach as applies to all other environmental contaminants and pollutants.  ASBG recommended its removal and the use of a due diligence defence against asbestos waste offences given their maximum fines the same as Tier 1 offences for negligence.  Other recommendations include developing other risk based approaches to asbestos waste where the measurement method AS4964 cannot be applied and provide waste levy to victims of illegal asbestos dumping and illegal contamination from illegal asbestos management.

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