Submissions
ASBG prepared its submission on the draft Guidelines: Pollution Incident Response Management Plans (PIRMP). Overall the Guidelines are an improvement over the current version with a much clearer set of what is expected from PIRMPs well explained. However, a major issue was raised with the literal interpretation that any pollution incident should result in retesting and updating of the site's PIRMP within 30 days. ASBG considers the Guidelines are an opportunity to interpret the meaning of s98E(2)(b) POEO (General) Regulation to mean incidents that are Material Harm. Another related issue is interpretation of what should be involved in a PIRMP update. ASBG argues the PIRMP is primarily an incident response plan and should only deal with upstream risk issues limited to management practices and not engineering and process changes.
 ASBG\'s Submission on the Draft PIRMP Guidelines 2019 | 822 kB |
ASBG supported many of the strategy's positions, especially its support for Energy-from-Waste with some reservation on the ability to achieve these. For example, there are ambitious targets for C&D waste and other recycling streams. However, there is little to tackle minimisation of contamination especially from waste generators including residential and kerbside. Business are considered for contamination attention, but no other generators are directly considered. The targets expressed are vague, but are set to 2050 which is well into the future.
| ASBG’s Submission On Queensland’s Draft Waste Management And Resource Recovery | 1005 kB |
ASBG's submission calls for NSW Fire and Rescue's document Fire Safety in Waste Facilities (FSWF) to firstly recommend the use of a fire study and provide area topics in which such a study can be made. There are many issues and recommendations on FSWS, but the most glaring is the excessive separation distances required for combustible waste. It is around 3 times larger than used for diesel storage. These distances were taken out of context from a UK document which based its distances on the premise there were no other fire controls used.
Application of FSWF can also apply to existing sites, but there is no consideration of issues affecting existing sites such as land surface available. Retrospective application of new standards to old sites is also poorly addressed and requires a reassessment of how new fire controls can in part be applied to existing sites, like with older buildings. EPA has also included its own requirement for a minimum of 4 hours of fire water storage in worst case scenario. This again is excessive and requires reconsideration and justification based on evidence this will provide a cost effective solution.
| ASBG's Submission on Fire Safety in Waste Facilities 2019 | 1028 kB |
ASBG supported many of the policy statement’s positions, with some reservation on the ability to achieve these. For example support Organics, referring to the removal of food and green waste from landfill is supported in concept, but there are many issues to deal with such as finding new and expanding existing markets, contamination issues where toxicants can collapse a biological system and contaminant finds such as asbestos.
ASBG also pointed out the contradictory policies of the EPA which will result in a forecast 1.5 MT being diverted to NSW landfills in 2019-20. This is largely due to recent legislation which reduces the capacity and increased the liabilities of C&D recycling and other recycling sectors, impact of the introduction of the Queensland levy in mid 2019 and the sudden closure of AWTs.
| ASBG's Submission on the Circular Economy - 2018 | 854 kB |
ASBG supports most of the initiatives that are outlined in the strategy with the exception of the presence based approach to asbestos and recommending guidance documents on how the EPA will enforce its asbestos waste laws clarifying what is the wrong thing and what are the right things as identified. ASBG reserves most of its comment on the potential material impacts that a heavy handed strategy can cause the C&D recycling sector. A list of considerations are provided that would be beneficial inclusions to the strategy. Also raised is the lack of consideration to the supply and lowering of costs for commercial quantities of asbestos wastes.
| ASBG's Submission on the EPA's Asbestos Strategy - 2018 | 842 kB |
