Organisation name
Upload a document
Obj Ref: A7892707
Department of Climate Change, Energy, Environment and Water
Industrial Chemicals Environmental Management Section (IChEM Section)
Via email: ichems.enquiry@dcceew.gov.au
31 August 2023
To whom it may concern
Public comment on Industrial Chemicals Environmental Management Standard
(IChEMS) proposed decision: Adding Pentachlorobenzene and the three per-and
polyfluoroalkyl substances to Schedule 7, the Industrial Chemicals Environmental
Management Standard (Register) Principles 2022.
Pentachlorobenzene (PeCB) and the three per-and polyfluoroalkyl substances (PFAS)
have been identified by Unitywater as contaminants of concern that can have an impact on
the delivery of water distribution and wastewater treatment services, including our service
area across the Moreton Bay, Sunshine Coast and Noosa local government areas in the
South East Queensland region.
Based on literature, case law and available data, PeCB and the PFAS:
a. are persistent with some PeCB and the PFAS known to be toxic to the environment
and to humans.
b. pass through treatment plants untreated or partially treated and may affect the
receiving environment and contaminate wastewater products.
Unitywater therefore supports the inclusion of Perfluorooctanioic Acid (PFOA),
Perfluorooctane sulfonic acid (PFOS), Perfluorohexane sulfonate and (PFHxS), PeCB to
be added to the Industrial Chemicals Environmental Management (Register) Principles
2022, under the Schedule 7 classification, to help Australian governments and businesses
manage the environmental risks of these chemicals.
Unitywater has adopted a PeCB and the PFAS approach that considers the evolving
nature of the regulatory and civil environment and recognises the responsibility for PeCB
and the PFAS pollution prevention lies with the ‘polluter’ and not with the ‘receiver’.
In the provision of water and wastewater services, Unitywater is primarily considered the
‘receiver’ as we have no choice but to receive all flows arriving through wastewater
networks from upstream ‘polluters’ in the catchment. Unitywater does not utilise these
products in wastewater treatment.
This places increased responsibility for us to consider the environmental fate of PeCB and
the PFAS contaminants as part of our general environmental duty in the:
Page 1 of 3
Unitywater ISO certifications:
OH&S ISO 45001 | Environmental ISO 14001 | Quality ISO 9001 | Food Safety ISO 22000 | NATA Laboratory ISO 17025
a. operation of wastewater treatment plants
b. construction, operation and maintenance of the water and wastewater networks
(and ancillary activities)
c. reuse of treated wastewater and biosolids for beneficial purposes.
The Unitywater PeCB and PFAS approach entails:
a. Working collaboratively with the Environment Regulator (Department of
Environment and Science) on the requirements for PeCB and the PFAS
management as the ‘receiver’ contaminated source water.
b. Understanding PeCB and PFAS contamination in wastewater treatment
catchments and by-products through strategic and targeted environmental
monitoring programs.
c. Adopting source management as the primary solution to PeCB and PFAS
contamination of wastewater by-products.
d. Investigating and implementing practical measures for management of PeCB and
PFAS in recycled water and biosolid reuse schemes based on human health and
ecological risk.
e. Assessing transmission risks associated with construction and operational
(disturbance) activities where there is potential for PeCB and PFAS to be present
within the existing environment to avoid new exposure pathways to sensitive
receptors.
Unitywater’s approach assumes:
a. Seqwater will address PeCB and PFAS related issues within their catchments and
operations, in accordance with their public statement.
b. The community acknowledges that primary PeCB and PFAS source management
lies with the National Industrial Chemicals Notification and Assessment Scheme
that regulates imports of PeCB and PFAS contaminated products to Australia.
c. Expecting Unitywater to implement treatment for PeCB and PFAS at the receiving
plant places a significant cost burden on our customers and community.
Source control and the scheduling of certain groups of PeCB and PFAS as Schedule 7 in the IChEMS framework and moving to ban the import and manufacture of products containing these chemicals is the only viable way to effectively and efficiently reduce the potential impact of these substances on the environment.
Page 2 of 3
Should you wish to discuss this further, please contact [redacted]
Regards
[redacted]
Page 3 of 3
