Submissions
The Review of the Used Packaging NEPM largely considers the performance of the Australian Packaging Covenant Organisation (APCO) and the State and Territory governments in enforcing and collecting information on packaging. While the APCO performance was considered modest this is far better than the performance of the government agencies who, virtually ignored their role in supporting the APCO. ASBG recommends the APCO continue, but be better supported in naming and shaming free-rider brand owners (those who are not signatories to the APCO), though minimal effort by the jurisdictions by simply issuing non-compliance letters. These letters can be then used legally by APCO to name the free-riders and effect market and consumer forces to press them into compliance.
The Sampling Design Guidelines contained text book approach to statistical sampling for contaminated sites, but over-ruled this flexible approach by requiring set grid separation distances. Table 2 used a one risk profile to fit all approach, over-ruling the ability to use calculated methods to determine an appropriate grid for systematic sampling. ASBG recommended that at least 4 types of default risk profiles should be used, where the user can undertake a simple risk assessment and then apply the appropriate default grid, or use a fully calculated statistical model as described in the Guidelines, justifying an alternative grid. ASBG also recommended a similar approach for stockpile sampling where table 4 has the minimum sampling criteria, but leaving no room for homogeneous stockpiles. Additionally, provision for dealing with stockpiles where sampling access is limited due to safety or other reasons should be also considered.
 ASBG’s Submission on draft NSW EPA's Sampling Design Parts 1 & 2 | 774 kB |
ASBG addressed a number of areas in the Options Paper for Victoria's Waste and Recycling Bill.
- An overall theme ASBG puts forward is that Victoria should work with the Commonwealth on Waste policy such as on the National Waste Policy and Product Stewardship. Requiring quality waste data has been a long term goal across Australia and Victoria citing this requirement is welcomed only if it is nationally consistent and adheres to nationally agreed definitions and made publically available.
- ASBG supports the formation of the Waste Authority and points to other similar bodies which have existed or currently do to help form a better legislative framework. Formation of recycling standards is also welcomed, but these need to be developed with stakeholders in mind and contamination issues are addressed at their sources. Business will be required to source separate.
- ASBG recommended that tiered approach be used that considers scale, location and type of business in enforcing separation in proportion to waste volumes and types.
- ASBG is concerned that Victoria wishes to include it own Extended Producer Responsibility and Product Stewardship schemes, when the Commonwealth is leading the way. Having different schemes for Victoria or simply a different product priority list would be quite difficult for Victorian suppliers.
- Having infrastructure planning managed by the Waste Authority is welcomed and ASBG offered advice on how to get unfavourable waste facilities through the planning process with community support.
| ASBG's Submission on Victoria's Waste and Recycling Paper 2020 | 622 kB |
ASBG submission on the Commonwealth Government’s Recycling and Waste Reduction Legislative Package is available as a download at the bottom of this page. A key part of this pack is the Recycling and Waste Reduction Bill 2020 and its subordinate legislation. ASBG recommended a number of improvements to the RWR Bill including on the:
- Definitions used for Waste was far too broad capturing all products. It should be consistent with the waste definitions in the major states waste laws
- Definitions for Relevant Courts was too restrictive only including State Supreme Courts. ASBG recommended other relevant state and territory courts be included and listed in a regulation
- Product Stewardship Liabilities: The current Product Stewardship Act lacks proper commercial law arrangements in handling debt and liabilities. ASBG recommends that legal means based commercial law be included to handle liabilities resulting from liquidations and other financial hardship issues.
- Ministerial Exemptions need to be accompanied with a set of application guidelines to prevent the process being abused
- Ministerial Priority List requires a scientific, cost-benefit and risk-based approach in selecting and removing waste types from the list
ASBG responded to the on-line questions put forward on the 20 year waste strategy, clarifying and repeating many of its prior positions on such issues. Designing waste out of products requires good recycling infrastructure first before such actions can be commenced. Given the current high turmoil in recycling such design is very difficult for many products. Also requiring change is the low tolerances set for recycled products, with the presence of asbestos cited as an example which is very difficult to demonstrate. ASBG calls for a more cooperative balance between recycling and environmental protection enforcement and clearer pathways for reuse and recycling of wastes which replace raw materials in processes. NSW also requires a new planning and operational pathway for innovative waste infrastructure as the current system works strongly against such development. Also the planning system needs to better address the NIMBY syndrome which affects all levels of waste infrastructure Need for better recycling of waste levy moneys back into the waste generation and management sector, noting businesses pay about 65% of the waste levy. NSW's Energy from Waste Policy requires to be rewritten and broadened to include a wide variety of EfW processes and to also make it more cost effective and minimise its obstructional requirements.
| ASBG's On-Line Submission NSW's 20 year Waste Strategy 2020 | 797 kB |
