ASBG made two points, with the first being by far the main one:
In the Position Statement the term onsite was used often. However, the submission ASBG's Submission on the On-Site / Off-Site Rule - 2019 was prepared due to the differing meanings, positions and enforcement by the waste branch and the enforcement or inspector branch of the EPA. As the Position Statement relied very heavily on the interpretation of what is an onsite ‘waste’ material vs and offsite waste material. Putting it simply the onsite material is covered under the Contaminated Land Management and legislation, whereas offsite waste is covered under waste legislation which is far more stringent. ASBG again recommended that, as promised in 2019 and was promised that Guidelines would be produced by the EPA to clarify what is considered onsite and offsite, called the onsite/offsite rule.
The other issue was the level of expertise on asbestos risk management by certified contaminated land consultants. Most have if but a few don’t and may require additional expertise
 ASBG Submission on Asbestos Contaminated Soils | 845 kB |
