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Contaminated Land Women’s Network Survey

The Contaminated Land Women's Network are a small group of liked minded senior female consulting professionals with a vision to promote and support other women within our Industry.

We are seeking feedback on whether establishing a female CLM Group would be of benefit to you and one that you would be interested in being part of.

The following are the Group’s key objectives:

·         to help/encourage more women to achieve their full potential in senior and/or leadership roles

·         to assess why women leave the contaminated land management industry and to support them to stay within it

·         to provide support to women in regional areas

·         to assist men in the industry understand the potential barriers faced by women and how they can assist in bridging the gap(s)

·         not to overlap with the various other groups promoting women in industry

We’d appreciate if you could please take some time to complete this short (10 question) survey.  Please feel free to pass this link onto others that may be interested.



National Remediation Framework Review

The NRF is a lengthy document, and covers many topics that are relevant to the remediation of contaminated land and groundwater. In considering the matters raised in the document, it can be appreciated that the matter is complex, and many considerations apply. Overall, the approach outlined in the document is to provide general guidance on the overall process and matters to be considered. The guidance is not prescriptive, and is more in the nature of outlining the process to be adopted and the considerations rather than providing particular endpoints that must be achieved. This allows a flexible approach to the problem. ALGA considers that this is appropriate. ALGA notes that some in the industry may be disappointed that the NRF does not provide more certainty regarding the requirements for remediation. However, ALGA considers that the nature and complexity of the problem is such that seeking to provide certainty is not practical and may well force inappropriate outcomes.

ALGA considers that the NRF is a valuable document in providing guidance on the requirements for remediating contaminated land and groundwater in Australia. It will assist in achieving a more consistent approach to remediation of contaminated land and groundwater across the various Australian jurisdictions. As such, ALGA sees that the preparation of the document is to be applauded, and ALGA looks forward to its issue in final form in the near future.

Notwithstanding the above general comments, in terms of defining the requirements and outcomes that should be achieved, ALGA considers that the document does fall short in providing guidance on the risk that should be achieved, or how such risk should be determined. The guidance has not been accompanied by a Regulatory Impact Statement that would inform and provide confidence that the implications of the guidance (in terms of cost and benefit) have been properly considered. The guidance on setting site-specific remediation objectives (ie clean up levels) describes considerations, but does not define the risk level – effectively leaving this to be a point of discussion and consideration. This can potentially undermine the whole intent of the guidance – to provide a consistent approach across jurisdictions. The default, but not enunciated, would seem to be to achieve the risk levels that underlie the setting of investigation and screening levels in the NEPM. This is highly conservative and has very significant cost and sustainability implications, and to not be consistent with some other international jurisdictions, such as the USA and Holland. ALGA considers that it is essential that there be further consideration of the cost implications of the guidance and benefits (such as lives saved), and the setting of remediation criteria be based accordingly on policies adopted by Australian Governments more generally across Australia. In recommending this, ALGA is very aware of the emotive issues that attach to “hazardous waste”, but considers that this is an opportunity to adopt a more science and evidence based approach to the area.

The NRF includes a series of modules that have the intention of assisting in the preliminary assessment of remediation technologies. In addition to 13 modules considering specific soil and groundwater technologies, there is a module that outlines the overall decision process for screening feasible options, and a supporting module that considers cost benefit and sustainability. Initial review of the technology modules suggest that they provide an excellent resource, and they are useful in drawing out the key matters that are likely to lead to one technology being applied over another.

It can be expected that, as the NRF is applied, that requirements for revision will become apparent. ALGA considers that it is  important that consideration be given to setting up, and making a funding provision, for the regular revision of the document.

ALGA looks forward to further contributions from its members as to issues that need to be addressed, and where improvement is needed. Please feel free forwarding comments on to Rosalind Vrettas igs@landandgroundwater.com

How to submit feedback


Click here to access any NRF documents for which you would like to provide feedback. 

To submit feedback, please download and complete the NRF final consultation submission form.  You are welcome to provide submissions for as many or as few documents as you wish.

Viewing comments from earlier rounds of consultation: If you would like to view previously submitted comments, please email a request to Dr Joytishna Jit, Research Fellow, CRC CARE Best Practice Policy Program, at joytishna.jit@crccare.com. 

The deadline, after which no submissions will be accepted, is 31 March 2019.



ALGA Training & Education – Position Paper

1. Introduction

The Contaminated Land Industry in Australia & New Zealand is diverse and consists of contaminated land consultants, remediation and earthworks contractors, researchers and academia as well as local, state and/or federal regulators, legal practitioners and other service industry people.  ALGA is uniquely positioned within the industry to provide training and education as its members represent each industry sector either as individual members and/or corporate partners.

ALGA has identified a need for further education and training beyond what is currently offered.  In the first instance, this training need is to be directed towards the consulting industry, in line with the new accreditation schemes and personnel with consulting backgrounds or skills in other industry sectors such as contractor and legal practitioners.  It is envisaged that the training needs of the other sectors of the contaminated land industry will be identified in the future.

This Position Paper outlines the ALGA vision for Training & Education for the contaminated land industry.  It gives an outline of why training is required, what ALGA sees as the way forward, and a plan to achieve the vision.  The purpose of the Position Paper is to allow for further stakeholder engagement with a view to implement a wider training offering in 2019.

2. Background

The contaminated land industry in both Australia & New Zealand has grown exponentially over the last 20 years as has regulatory control, the number of consultancies and sophistication of assessment and remedial strategies and technologies.  There are now two accreditation schemes (CEnvP SCS recognised in ANZ, and CPSS recognised in Australia), developed and endorsed. For Australia this is a direct result of recommendations made in the ASC NEPM April 2013 amendment.

Over the last 10 years there has been a trend of amalgamation and growth of large multi-disciplinary consulting companies, some employing over 10,000 employees.  At the other end of the scale, downsizing and restructuring has led to an increase in smaller consultancies (many less than 20 employees) who have quickly filled a void in the market place for more cost effective assessment and remedial solutions. There has also been a corresponding growth in other sectors of the industry, including in government and industrial organisations, regulatory agencies, contractors, researchers, legal practitioners and laboratories.

What has not kept pace with these industry changes is the training and education necessary for the industry to maintain and improve standards into the future.  Accreditation has arrived but the benchmarks against which an applicant are judged to be competent currently rely on experience and on the candidate demonstrating competency through verbal and written responses, verified by referees.

In addition, that there is a process of continuous renewal in the contaminated land industry as new persons enter, and others retire. There will be an ongoing need for persons entering the industry to learn and gain competency; while training on the job has been a well established approach by many organisations, a well developed training and education program can be more cost effective and has the potential to provide improved competencies.

3. External Factors Impacting on Current Training Models

ALGA does not believe that there is an issue with the quality of existing training modules available to the contaminated land industry through industry associations or educational institutions.  On the contrary some have been developed and run by industry experts and are high quality and up to date.  The identified limitations are mainly external and affect the way the training is offered and taken up by the industry.

Some of these external factors include:
  • Irregularity of training offerings and lack of consistency on topics
  • Location format, cost and timing of courses offered
  • Training is not specifically linked to the competencies as set down by the accreditation schemes
  • The accreditation schemes and the ASC NEPM do not deal with or assess competence in the application of remediation methods   
  • Lack of provision of foundational skills in the physical and earth sciences.

In addition to programs that are set up with the specific objective of providing general training in the field, there are also many ad hoc topic-specific events that occur from time to time. These include for example: in house seminars by legal practitioners (no cost), seminars on particular topics offered by ASBG / AEBN (low fee); conferences by professional conference organisers (high fee), and short courses by universities (high fee) eg UTS CSARM course and the CRC CARE Summer School.

The question arises as to whether training programs need to be certified. Because industry practitioner and auditor accreditation schemes rely on their own evaluation of competency, it appears that training programs, conferences and specialist seminars are provided on the basis of general education and information rather than as proof of competency, and do not require certification as such. In the situation where there is a serious error made by an accredited practitioner, it would seem that the need for investigation to respond to the situation (and any liability) would pass to the accrediting body rather than a training or seminar provider.

4. ALGA Preferred Approach to Training

ALGA believes that training should be run by the industry for the industry.  The type of training offered needs to be flexible and better aligned to the limitations that most in the industry face – time and money.  Training should be affordable, be aligned to the accreditation schemes and the listed competencies, and should extend to include specialist areas of the industry.

Industry representatives are spread throughout Australia & New Zealand and consultants, contractors, regulators, other government organisations and industry are found in all the capital cities and major regional centres.  It is a fact that most training on offer is centralised where students are asked to attend courses in the major centres (capital cities).  This adds to cost for each consulting firm with travel and accommodation and time away from the office.

Below is the current thinking by ALGA and what is proposed as the basis of ALGA’s training and education scheme, which would go a long way to address the training needs of the industry:

Key role of ALGA:

To map the requirements for training and education in the contaminated land industry, to identify existing providers and how their programs fit the industry requirements, and to fill gaps where it is cost effective to do so. ALGA does not have the objective of competing and offering alternative training and education programs where existing providers are already doing this cost effectively for the industry.  

A framework and plan for training and education:

  • Development of an overall framework and plan for training for the contaminated land industry. This will systematically consider the various topics for which training can and should occur (systematically covering areas in the NEPM, the NRF and the auditing schemes), the level of training (introductory, comprehensive (accreditation level) and specialist topics), and how these various components fit together to form an overall program for the industry.
  • Timing and availability of training, including whether face-to-face training, or on-line training.
  • Availability and competency of training providers, seeking to make known and utilise existing providers, and for ALGA to fill gaps where these exist, ALGA resources are sufficient and it is cost effective to do so.
  • Liaison with ALGA members in the industry to confirm that the framework and plan will cover the areas of interest and need.

Particular training and education components:

  • Industry-specific high quality training targeted at 0 to 5 years’ experience (Introductory Contaminated Land), and 5 to 10 years’ experience (more advanced Contaminated Land suitable for accreditation).
  • Modules that cover the topics considered in the NEPM, NRF, and the competencies outlined in the accreditation schemes.
  • Specialist area advanced training, such as, asbestos, hydrocarbons, LNAPL, chlorinated hydrocarbons, PFAS, human health risk assessment, ecological risk assessment, auditing, community engagement and remediation methods.
  • Options that provide flexibility in training methods and locations, including face-to-face training, and 20 - 30 minute on-line courses, with the objective of making available training and education to persons both in capital city and regional areas.
  • Encourage the use of subject matter experts and trained presenters (Certificate IV) from within the industry.
  • Modules for certification to be assessed by an examination with issue of a certificate.
  • Encourage the development of a regular program that is available and becomes fixed in the calendar.
  • Encourage cost effective training and education, with the primary objective being to recover costs and not to make money.
5. Where to from Here?

ALGA has been discussing the requirements for training and education in the contaminated land industry with members, and this has helped shape this Position Paper. Further consultation with the industry is required as ALGA goes forward with its development of a training and education program. The objective of this further consultation will be to better understand the needs of the industry for training and education and how a program to satisfy these needs can be most cost effectively achieved and made available to ALGA members. 

We see the further steps to be:
  • Development of an overall framework and plan for training for the contaminated land industry.
  • Identifying the availability and adequacy of existing training programs against the framework, seek reviews on these programs from members who have attended.
  • Identifying gaps in the available training programs, and determining how best these may be filled.
  • Liaison with ALGA members in the contaminated land industry to confirm that ALGA’s approach accords with what the industry identified needs.

We would appreciate your feedback, suggestions and ideas.  Please contact Rosalind Vrettas at education@landandgroundwater.com

19 February 2019



Bridging the Gap: R&D to Industry Application

What were the common points of discussion:


There is currently a big gap between academia and industry. It’s important for us to bridge this gap to drive the development of best technologies and methods, and improve outcomes for consultants and their clients.

Academia is all about trial and error, but for industry, the choice of technologies and processes is driven by ‘outcomes’ and ‘money’, which often leaves consultants and clients ignoring innovation in favour of ‘safe options’.

Newer, less well known technologies – such as XFR – have many benefits allowing for efficiency, dynamic and rapid decision making and lower costs. While these technologies may not be as well tested, they can provide many benefits, particularly for in-situ field investigations and remediation planning.

Investing in academia will provide industry with access to more relevant scientific literature, a range of expertise and equipment, and reputational gain for thought leadership and innovation.

 

What was the "light bulb" or most radical/innovative point:


How can us (industry) convince clients that applying innovative technologies can be beneficial?

Take established technologies and slowly bridge them with new technologies. There are likely to be a lot of failures when using new or innovative technologies, but there are a lot of long term projects where incremental changes in technology and techniques can occur. While these newer technologies may not be the main remediation technique on a project, learnings can be taken forward into other projects.

We can’t just be thinking about ‘this’ project – we have to be thinking long term.

There is a lot of good knowledge being published, and not all of it gets to the commercial level – things don’t get published because it is not a priority. How do you think we can decrease the gap?

We need to engage students in real world problems, have them appointed on projects with problems to solve.

Industry needs to be engaging with the institutions where our students are training.

This is also beneficial for academia, because industry has great expertise that can be translated back to academia.

 

How can things be done better as a result of this discussion:


We need to take a long-term approach to choosing technologies and techniques that will provide good client outcomes while allowing for some innovation.

Industry needs to back academia - industry funding helps to drive the development of relevant research.

A strong relationship between academia and industry will help support a mutually beneficial feedback loop between the development of new technologies and techniques, and the learnings and improvements gained from their use. 

To help bridge the gap between academia and industry, students need to be engaged in real-world problems.  

Some examples of ways in which industry can interact with academia:

  • Research contracts
  • Technology vouchers
  • ARC linkages
  • R&D tax incentives
  • Innovation connection

Thank you to our presenters:

1. Damian Gore (How transportable analytical programs can (and can’t) help your site assessment - Macquarie University

2.  Danis O’Carrol (From the Lab to the Field: The Nanoiron Story) - UNSW

3.  Mike Manefield (Industry + Academia) - UNSW

4. David Waites (Centre for Transportational Environmental Technologies (CTET) - UNSW

 

Special Acknowledgement to Alex Francis (Nation Partners) for reporting on the event on behalf of ALGA.



PFAS NEMP 2.0: Consultation on Draft of Version 2 of the PFAS National Environmental Management Plan

The PFAS National Environmental Management Plan (NEMP) was published in February 2018 following agreement by all Australian Environment Ministers. The Heads of EPAs (HEPA) National Chemicals Working Group (NCWG) has been working since to clarify and expand on the guidance in the NEMP. This updating work is consistent with the commitment by HEPA that the NEMP will be a living document. A comprehensive review of the PFAS NEMP will be undertaken in 2023.

Material in the NEMP 2.0 for consultation includes:

  • Updates to the soil criteria included in PFAS NEMP version 1, to ensure that criteria are appropriate for Australian conditions (these include changes to the human health residential soil criterion and to the land use categories for the ecological indirect soil criterion)
  • Extensive new guidance on the reuse of soil, including a decision tree to be applied in consultation with the regulator
  • Initial guidance on management of PFAS in wastewater, including trade waste, to be further developed in consultation with the water industry. This guidance includes an example water utility PFAS management framework, and
  • New on-site storage and containment guidance for PFAS-containing products and materials.

Stakeholders are invited to consider and provide feedback on the aspects of the NEMP that are either new or significantly revised. To facilitate this, the text that has changed from version 1 of the PFAS NEMP is shown in version 2 of the draft NEMP with a coloured background. There are two categories of changes which are highlighted:

  • new or significantly amended material - feedback is invited on these changes
  • editorial revisions to more clearly communicate the original intention of the NEMP text are shown for information – these changes are not subject to consultation.

More information here.



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