AUSTRALIA: COMMENTS ON THE DRAFT GENERAL TECHNICAL
GUIDELINE FOR ENVIRONMENTALLY SOUND MANAGEMENT OF
WASTES CONSISTING OF, CONTAINING OR CONTAMINATED WITH
PERSISTENT ORGANIC POLLUTANTS
Section 3.3 Options for developing low POPs content concentrations
This section presents options for developing low POPs content concentrations (LPCC) which is
the crucial section of the guidelines:
Option 1. use OECD country legislation.
Option 2. a single LPCC of 50 mg/kg for all POPs.
Option 3. destruction capability.
Australia prefers Option 1 as this recognizes the different levels of toxicity for various POPs.
Setting one level, as proposed in Option 2, does not allow for this variation. Australia has
adopted this variable approach in the National Environment Protection (Assessment of Site
Contamination) Measure 1999 (NEPM). For example, this sets levels in soils for residential areas
at 10mg/kg for Aldrin, dieldrin and PCB, 50mg/kg for chlordane and 200 mg/kg for DDT.
NEPMs outline agreed national objectives for protecting or managing particular aspects of the
environment. They are implemented through State and Territory legislation, policy or
administrative arrangements under the framework of the Commonwealth National Environment
Protection Measures (Implementation) Act 1998.
Section 3.2.5 Dioxin and furans
Annex C of the Stockholm Convention includes unintentionally produced dioxin-like PCBs. It is,
therefore, recommended that the guidance document recognise this classification and include the
very toxic dioxin-like PCBs when discussing dioxins and furans. Actions to handle these sorts of
wastes should be discussed throughout the document in more detail since an LPCC, if developed
for dioxins, furans and dioxin-like PCBs, would need to be of a completely different order than
those for wastes derived from intentionally produced PCBs. For example, the level of
remediation for a site contaminated with intentionally produced PCBs could be 50mg/kg, where
as the level for D/F/PCBs, as outlined by the WHO, could be 1 nanogram/kg.
References
Throughout the guidelines, references are made to a number of Australian documents. In some
cases these reference are incomplete or incorrect. Please make the following amendments:
Page 14, 2nd paragraph, section 3.2.1
The sentence refers as follows:
“Using these types of factors, and incorporating a safety factor, Australia’s environmental
ministry ANZECC and NHMRC in 1992, by way of one example, established a health
investigation value of 10 mg/kg for a standard residential exposure scenario.1
This should be reworded as follows
Using these types of factors, and incorporating a safety factor, Australia’s National
Environment Protection Council and National Health and Medical Research
Council in 1999, by way of one example, established a health investigation value of 10
mg/kg for a standard residential exposure scenario.
1
Schedule B (7A), Guideline on Health based Investigation Levels.
The reference to appear in the footnote for this should read as follows:
“National Environment Protection Council Service Corporation (1999), National
Environment Protection (Assessment of Site Contamination) Measure 1999, Schedule B
(7a), Guidelines on Health-Based Investigation Levels,
http://www.ephc.gov.au/pdf/cs/cs_07a_health_based_inv.pdf “
Page 15, last paragraph section 3.2.3.
The sentence refers as follows:
“Australia and New Zealand’s Hexachlorobenzene Waste Management Plan specifies
that any non-aqueous liquid or solid waste for disposal from the destruction of scheduled
HCB waste…”
Reference to New Zealand should be removed as it is applicable only to Australia. This sentence
should be reworded as follows:
“The Australian Hexachlorobenzene Waste Management Plan specifies that any nonaqueous liquid or solid waste for disposal from the destruction of scheduled HCB
waste…”
“The reference to appear in the footnote for this should read as follows:
Australian and New Zealand Environment and Conservation Council (1996)
Hexachlorobenzene Waste Management Plan,
http://www.deh.gov.au/industry/chemicals/scheduled-waste/hcbplan.html”
Page 16, Contaminated soils, section 3.2.3.
The last sentence refers as follows:
“Australia requires remediation of soils contaminated above 400 mg/kg.”
While this is correct, it needs to be clarified as follows:
“Australia requires remediation of soils contaminated above 400 mg/kg for recreational
areas and parks, and above 200mg/kg for residential areas and primary schools.”
Section 4.2.10 Public participation
Australia welcomes the inclusion of public participation in the guidelines but believes that this
section could be expanded to show examples of consultation. Australia can demonstrate good
examples of public consultation through the work undertaken in developing the management
plans for OPCs, HCB and PCBs. A report on this consultation has been prepared and would be a
worthwhile addition to the references in the guidelines:
National Advisory Body and Scheduled Wastes Management Group (2000), A Case
Study of Problem Solving Through Effective Community Consultation,
http://www.deh.gov.au/industry/chemicals/scheduled-waste/communityconsultation.html