WMAA supports members in achieving sustainable waste and resource management across Australia.
We do this through leadership, collaboration, and knowledge sharing.
Professional Proactive Collaborative Informative
31 August 2015Department of Environment Regulation Email: info@der.wa.gov.au
To whom it may concern
Submission on Environmental Standard Guidance Statement
The Associations welcomes the opportunity to comment on the Guidance Statement and the clarity it provides on the role of Environmental Standards and is keen to work with the Department to assist in the development of future Standards which will affect the industry.
Industry Impact and Support
New regulations, or consolidation of existing regulations, are likely to have an impact on industry. The waste and recycling industry is particularly concerned that there can be a significant financial impact of regulation, without a commensurate and demonstrable environmental impact. As such the industry considers that the Guidance Statement on Environmental Standards needs to include a commitment to make publically available the assessment the Department has made regarding the financial impact and environmental benefits of a new regulation.
The waste and recycling industry provides many positive environmental outcomes through good management of landfill sites and through diverting waste from these sites to more beneficial uses. However, the diversion of waste from landfill is not always lucrative and as such the industry may need support to adapt to new regulatory requirements. For example, for the support provided by the Waste Authority for the Construction
& Demolition processing facilities when the new requirements for Asbestos testing were introduced.
Consistent Format and Approach for Standards
Many of those operating in the waste and recycling industry will have numerous activities (licensed by the Department) occurring at a particular site, for example a landfill may also be composting material and sorting recycling. As more Environmental Standards are developed it is vital that these documents, as much as possible, have a consistent and structure. This will assist those operating facilities to interpret and implement the Standards.
Members have raised that it is important for any Standard to be endorsed by the Department prior to its implementation. Currently the perception is that some officers are applying elements of a draft Standard before final Department approval.
Consultation with Industry – Prior to Release of Draft Standards
DER recently met with Stakeholders to discuss the Regulatory Reform process and the Association appreciates the opportunity to attend. The Association suggests that for future Standards, the Department should always consider engagement with Industry Associations prior to releasing of draft documents. This would allow the
WMAA supports members in achieving sustainable waste and resource management across Australia.
We do this through leadership, collaboration, and knowledge sharing.
Professional Proactive Collaborative Informative
industry Association to flag potential issues with the Department and reduce the impact and concern expressed by industry when a new Environmental Standard is released.
Again, the Association is keen to work with the Department and sees the benefits of developing more open and transparent approaches to regulating the industry.
For more information please contact me on or email
Yours sincerely
Rebecca Brown
President
WMAA (WA) Branch
