ASBG welcomes the replacement of the zero level for PFAS Cat 1 Regulated Waste, with concentration limits in the consultation paper. The
proposed classifications of certain contaminated soils as non-regulated wastes are also welcomed.  While the main thrust of the proposed
changes are supported, but there are some issues requiring consideration:

1.    What is meant by Other PFAS – needs a definition, otherwise can relate to millions of compounds.  
       ASBG calls for PFASs of concern to be published by DES, suggesting these would likely be liquid not solid or gaseous and generally
       immobile.
2.    The thresholds levels given for Category 1 Regulated Waste as they are lower than some EoWs – issues for recycling future wastes.
       ASBG recommends the DES review its PFAS limits given that Biosolids and Coal Combustion Products EoWs permit higher or similar PFAS
       levels which can be applied in or on land anywhere in Queensland.  A Cat 1 and Cat 2 Regulated Waste classification would also impact such
       EoW material at its end of life, for reuse
       or recycling purposes.
3.    Implications of removal of PFAS from the Regulation’s dictionary.  
       ASBG recommends not only removing PFASs listed but all Persistent Organic Pollutants (POPs) listed in Schedule 19, Part 1 Item 5, to be
       replaced with reference to the POPs list in the Stockholm Convention.  Where new POPs including PFASs of concern are identified by DES,
       these should be published in a guideline type document, with explanation and scientific justification, for easier change than a regulation
       permits.

Attachments:

ASBG Submission on QLD PFAS as Regulated Waste 2024

994 kB