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
28 July 2015Department of Environment Regulation Email: end_of_waste@der.wa.gov.au
To whom it may concern
Submission on Manufactured fill: Addendum to the draft Guideline: Submitting an application for the use of waste-derived materials (case by case determination)
The Associations welcomes the opportunity to comment on the Addendum. Due to the timeline for consultation this Submission has not yet been formally endorsed by the WMAA WA Branch Executive
Committee – however this will occur at the next meeting and the Department informed of any changes to this Submission.
General Comments
The Association understands, from discussion with the Department, that the Manufactured fill addendum could apply to a process for generating manufactured fill, rather than requiring an application for every project. This approach is supported by the Association, as it would allow systems of producing fill to be approved.
The Association is however concerned about the number of ‘Standards’ which products need to meet – including both technical and environmental standards and would prefer that just one ‘Standard’ was in place for the various products which met both requirements. For example, the Asbestos Guideline met the Department of Environment Regulation and Health requirements and Main Roads were involved in the process.
Characteristics of each waste input
The section of the document ‘Characteristics of each waste input’ provides background on the type of issues which could affect the waste inputs for manufactured fill. However, these issues are not always going to be relevant and for some of the issues – for example the presence of organochlorine – guidance is not provided on when it is likely these substances are likely to be present, therefore when testing would be needed. The Department of Environment Regulation Regulatory Principles identify that a risk based approach will be taken
“with consideration of the costs and benefits associated with different levels of risk to public health and the environment”. Therefore in order for an Applicant to understand what testing is required, an understanding of the likely risk is needed.
Waste Treatment and Proposed product specification
There appears to be a difference between what is required in the Waste Treatment section and in the Proposed product specification section. For Waste Treatment, the Applicant “must provide details as to how unsuitable materials…have been segregated or removed” in the Proposed product specification it requires information on “the amount of physical contamination” that is in the manufactured fill. The Association request that consistent terminology is used and clarity provided on whether manufactured fill can contain the materials identified.
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
As highlighted in previous submissions the Association understands the need to protect the environment through a rigorous approach to understanding risks associated with the use of waste derived materials.
However, there are concerns that the level of requirements, in the absence of incentives and support for the industry, will discourage the development of markets for materials, as they may require a high level of investment to meet the requirements of the Guidelines. Recycling material is frequently a marginal activity and if the State is committed to diverting waste from landfill, it is likely that support for the industry will be needed.
Yours sincerely
WMAA (WA) Branch
