The submission covers many areas on asbestos waste, but largely focuses on the un-scientific presence based threshold for asbestos waste. The OCSE is considered a good chance whereby a set of reasonable asbestos concentration thresholds for various RROE uses can be applied.
ASBG pointed out may of the perverse outcomes of the presence based approach including:
- Removing asbestos materials unnecessarily causing increased exposure and consuming limited landfill space.
- Virtually banning any type of alterative asbestos waste management option, other than landfilling, which in the Greater Sydney area will be largely exhausted by 2028 with no replacement identified.
- Increases the costs of asbestos waste management across all areas especially recycling, hence increases illegal disposal of asbestos wastes and increases recycling liabilities.
- Having a large difference between contaminated land limits and waste limits causes considerable issues.
- Preventing the use of asbestos waste and asbestos forms (e.g. serpentine) in future carbon sequestration processes, via carbonation reactions, undermining NSW’s use of technological choices in meeting NSW’s Net Zero Targets.
ASBG recommends firstly to remove, or redefine, the use of a presence based limit in the definition of asbestos waste, replacing it with a scientifically supported practical limit as used for all other environmental contaminants. Additionally, ASBG calls for a scientific based assessment on the setting of general and case specific acceptable threshold for asbestos wastes to reduce the volumes sent to landfill. This would be seen as consistent with contaminated site criteria. In addition, another limit for the deeper burial of asbestos soils, such as in infrastructural projects, for moderately low concentrations of asbestos, with overarching design, cap, land title and call before you dig requirements. Both of the above can be enshrined in Resource Recover Orders and Exemptions or by other means.
 ASBG Submission on OCSE's Asbestos Management Review 2024 | 1637 kB |
