Common sense is needed in managing chemical contaminants, says CCF QLD CEO Damian Long
CCF Queensland and civil contractors more broadly understand and embrace the need for practical environmental stewardship.
There is nothing worse for businesses, or society, than environmental vandalism. Despite this, all too often a narrative forms that suggests we are faced with a binary choice between business and the environment. This couldn’t be further from the truth. Unfortunately, this narrative often forms the basis of environmental regulation and legislation, having the effect of significantly curtailing the ability of business to deliver efficient and practical environmental outcomes.
Per- and polyfluoroalkyl substances (PFAS) remain one of the most pressing environmental and sustainability issues facing the civil construction sector in Queensland. Often called ‘forever chemicals’ these substances have been described as an ‘emerging’ contaminant for many decades now.
Whilst most contractors are aware of these chemicals and the risks they may cause, managing this problem in a pragmatic fashion is another issue. Current regulatory approaches disproportionately burden contractors without addressing the source of contamination. Firefighting foams, airports and other industrial uses of PFAS means that there is a high prevalence of these chemicals across the environment, particularly in populated and industrialised areas.
At present, when it comes to PFAS Queensland has a clear threshold for waste disposal, however there is insufficient and opaque guidance on what is to occur with the enormous volume of material that is contaminated to levels greater than zero but less than the waste limits prescribed in the environmental protection regulations.
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It is also important to understand how confusion around testing obligations, responsibility for ambient PFAS in the environment and jurisdictional differences overlay this complex problem. PFAS contamination at a given site does not necessarily mean that the site is the source of the contamination. This means any money spent remediating the site to remove all PFAS in no way guarantees that the site won’t soon be contaminated once again. To most people, this seem illogical, however this is the current state of PFAS regulation in Queensland.
Obligations to remediate in this fashion are costing hundreds of millions of dollars and delivering no real environmental benefits. CCF QLD is advocating for a risk-based and practical management framework that fairly and reasonably spreads risk to ensure that the delivery of important civil infrastructure projects is secure and cost effective. The appropriate balance of sensible environmental regulation and economic efficiency must be struck to ensure Queensland’s surging infrastructure needs are met in a cost effective and timely manner.
CCF Queensland is hoping for a better path forward and is actively working with the Department of Transport and Main Roads (TMR) and the Department of Environment, Science, Tourism and Innovation (DETSI) around workable solutions that protect both the environment and taxpayers. CCF QLD is calling for the following pillars form part of a new PFAS strategy for civil construction.
1. Risk-based PFAS management that targets sources and acknowledges ambient levels of PFAS in the environment.
2. Clear, timely reuse and decision-making pathways to enable fit-for-purpose reuse.
3. Government to invest in the management of environmental sources of PFAS, while acknowledging ambient levels are not the responsibility of individual contractors.
4. Recognition of industry challenges and collaboration with government to develop workable solutions.
CCF QLD will have more to say on these matters soon. If all stakeholders are able to get the balance right on this issue, it will be a win for business, the environment and taxpayers. It’s hard to argue against that.