Submissions
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 |
ASBG prepared this submission on the POEO Amendment (Asbestos) Waste Bill 2018 which was not publically made available. It contains a single change which is of concern, proposing the new s241(f) the presence of the asbestos in the environment, under the POEO Act. ASBG is concerned this sets a precedence for the use of the unscientific application of the mere presence of asbestos in waste, rather than the use of a risk-based approach as applies to all other environmental contaminants and pollutants. ASBG recommended its removal and the use of a due diligence defence against asbestos waste offences given their maximum fines the same as Tier 1 offences for negligence. Other recommendations include developing other risk based approaches to asbestos waste where the measurement method AS4964 cannot be applied and provide waste levy to victims of illegal asbestos dumping and illegal contamination from illegal asbestos management.
| Ministers Response | 923 kB |
| ASBG's Submission on Asbestos Waste Bill 2018 | 944 kB |
ASBG strongly recommended the rebate for recyclers be proportionally paid on the quantities of recycled product sold, rather than claim the discount at landfill gates. Other positions were on the heavy administrative burden on landfill gates and related issues to fraud which accompanies waste levies.
| ASBG Queensland Waste Levy Submission 2018.pdf | 856 kB |
