ASBG’s Submission on EPA’s Regulatory Strategy, covers three issues:
- Clarification on the extent of the EPA’s regulation of health issues and minimisation of overlap with Safework NSW, especially where s127 POEO Act defence is not included in EPLs.
- Improved reference to the EPA’s Principles, especially Ecologically Sustainable Development (ESD) and the Precautionary Principle. Here the draft ignores economic considerations and does not use or reference the full definition of ESD under s6 POEA Act.
- Application of the risk-based approach and use of a science-based approach, especially to help overcome the contrary presence-based approach for contaminants currently used for asbestos waste.
 ASBG’s Submission on NSW EPA’s Draft Regulatory Strategy 2021 | 799 kB |
