Overall this submission is more about non-STP biological sludges than biosolids. The term biosolids is exclusively defined and reserved for sewage treatment plant, or STP biological sludges.
Many industrial biological systems produce similar however, biosolids from non-Sewage Treatment Plants (STP) can have similar, worse or better environmental characteristics than biosolids from STPs.
ASBG calls for a more consistent method to regulating biological sludges and allow them similar outcomes to those applied to biosolids where applicable.
In particular, ASBG calls for a less stringent assessment process for these sludges than the current Specific Resource Recovery Order and Exemption application process.
Where biological sludges have similar or better properties than biosolids then they should be permitted to use the Biosolids Resource Recovery Order and Exemption based on the Biosolids Guidelines.