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Koolfoam Pty Ltd

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Koolfoam Pty Ltd

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HBCDD

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00 ACN 010 236 263 [redacted] www.koolfoam.com.au

[redacted]

23 October 2023

[redacted]

Chemicals and Atmosphere

DCCEEW

Dear [redacted]

IChEMS Consultations – HBCD

Koolfoam Pty Ltd welcomes the opportunity to make this submission on the draft IChEMS scheduling decision for HBCDD.

Koolfoam Pty Ltd is a moulder and manufacturer of EPS foam products in Australia. We are Australian owned and operated and have been trading since 1981.

Koolfoam Pty Ltd supports those elements of the draft decision that give effect to the Stockholm Convention listing of HBCDD, including prohibiting the import and manufacture of HBCDD and articles containing HBCDD subject to the listed exceptions.

Koolfoam Pty Ltd has concerns about the potential consequences of the proposed waste management elements of the draft decision.

HBCDD will may be present in some building demolition materials, where EPS foam insulation has been installed prior to Dec 2020. The current practice is that this material (Demolition waste) is generally reprocessed to produce aggregates for other construction. The waste management measure would prevent this or require segregating any foam material. Separating foam materials during the demolition process will be difficult and costly. When confronted with significantly higher costs, we are concerned that demolition companies will choose to treat all demolition materials as contaminated and send them to landfills. If this happens, our circular economy objectives will be undermined, and valuable resources will be lost.

This issue is further complicated by the lack of high-temperature incineration or chemical recycling options for the disposal of HBCDD. Neither is likely to be a viable option in Australia.

Koolfoam Pty Ltd believes that the Department should work with the industry to develop more suitable waste management measures that prioritise the beneficial reuse of foam products and do not risk impacting the reuse of other demolition materials.

Koolfoam Pty Ltd would be willing to work with the department and other stakeholders to develop better waste management rules.

While the waste management provisions of the draft decision require further work, Koolfoam Pty Ltd supports moving forward with the decision to prohibit the import or manufacture of HBCDD.

If you have any questions regarding this submission, please contact the under signed.

Yours sincerely

[redacted]

Koolfoam Pty Ltd

[redacted]

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