DEPARTMENT OF DEFENCE · Defence infrastructure has the potential to contain hazardous building...
30
UNCLASSIFIED DEPARTMENT OF DEFENCE ENVIRONMENT AND ENGINEERING BRANCH DIRECTORATE OF CONTAMINATION ASSESSMENT, REMEDIATION AND MANAGEMENT Contamination Management Manual Annex J Demolition March 2018, Amended August 2019
Transcript of DEPARTMENT OF DEFENCE · Defence infrastructure has the potential to contain hazardous building...
UNCLASSIFIED
DEPARTMENT OF DEFENCEENVIRONMENT AND ENGINEERING BRANCH
DIRECTORATE OF CONTAMINATION ASSESSMENT, REMEDIATION ANDMANAGEMENT
Contamination Management Manual
Annex JDemolition
March 2018, Amended August 2019
UNCLASSIFIED
UNCLASSIFIED
© Commonwealth of Australia 2018This work is copyright. Apart from any use as permitted under the Copyright Act1968, no part may be reproduced by any process without prior written permissionfrom the Australian Government Department of Defence.Announcement statement—may be announced to the public.Secondary release—may be released to the Australian Government Department ofDefence, its contractors and their equivalents in United States of America, Canada,New Zealand and Great Britain.All Defence information, whether classified or not, is protected from unauthoriseddisclosure under the Crimes Act 1914. Defence information may only be released inaccordance with the Defence Security Manual as appropriate.First edition 2018
SponsorDirectorate of Contamination Assessment, Remediation and Management
DeveloperEnvironment and Engineering Branch
Issued byAlison Clifton with the authority of Assistant Secretary Environment and EngineeringBranch
Effective DateMarch 2018
Amendment DateAugust 2019
Review DateAugust 2020 or when changes to processes require an update
Amendments to the document can be proposed as required. Proposals foramendment of this document are to be forwarded to:
Director of Contamination Assessment, Remediation and ManagementEmail: [email protected]
UNCLASSIFIED
UNCLASSIFIED
Quick Reference GuidesWhy is this an issue for Defence?
Mandatory requirementsThe following requirements are mandatory when undertaking project work on or in the vicinity ofcurrent or former demolition areas:
Review the Garrison Estate Management System Environmental Factor Management –Contaminated Site Records (GEMS EFM – CSR), Asbestos Records and any AsbestosManagement Plans to obtain historical data about the age and function of thebuilding/structure/plant and to assess the potential for hazardous building materials to bepresent. The presence of hazardous building materials needs to be considered in the projectpre-demolition and demolition/waste management activities.
Assess hazardous materials in line with the requirements of the Commonwealth Work Healthand Safety Act 2011 (Cth) (WHS Act), and Regulations and the associated Codes of Practice(COP) relevant to hazardous materials.
Include project specific risk management measures in procedures for management ofhazardous building materials and waste (e.g. waste segregation). Measures may include use oflicenced asbestos removal contractors and decontamination protocols (to avoid contaminationof regular demolition waste).
Obtain an Environmental Clearance Certificate (ECC) - this is a Defence approval that imposesconditions and safeguards on an action to ensure environmental impacts are avoided,minimised or remedied.
Assess the suitability of materials for reuse in accordance with the Smart InfrastructureHandbook and Defence Waste Minimisation Policy.
Environmental Risk
Inappropriate managementand monitoring of hazardousbuilding materials duringdemolition may present a riskto the surroundingenvironment throughmigration and dispersal intosoil, air and waterbodies.
Defence Capability
Project delays and costs tomanage unexpectedcontamination from hazardousbuilding materials duringdemolition works, can have asignificant impact on Defencecapability and operations.
Projects can may also havematerial or commodity valuethat can be realised by reuseand recycling of demolitionmaterial.
Health Risk
Hazardous building materialsand contaminants withinbuildings/structures or plant thatare to be demolished canpresent a health and safety riskto site workers and people ofadjacent sites depending on thenature, extent and concentrationof the contaminant and theexposure pathway.
UNCLASSIFIED
UNCLASSIFIED
Implement site-specific best-practice management and monitoring measures in accordance withthe WHS Act and the Defence Health and Safety Manual (SafetyMan) (Volume 2 Part 3AChapter 5) (e.g. air monitoring for asbestos removal) to reduce the risks to sensitive receptors(site users, nearby residents, structures/infrastructure and waterways).
Complete health and environmental monitoring as detailed in Commonwealth, State or TerritoryCodes of Practice (COP)/Compliance Codes (CC)1 (where relevant). Report to Defence anyissues or exceedances of health/environmental limits as specified in the Act or COP/CCs, andconsult with Defence Environment and Sustainability Managers (ESM) or Regional SafetyOfficers to establish further management measures, where necessary.
All notifiable incidents must be reported to Comcare. The definition of a notifiable incident isdescribed in the Defence WHS Manual but would include, for example, an exceedance of thecontrol limit for asbestos fibres in air concentrations.
Further information Defence Environmental Strategy, Defence Contamination Management Manual
Regional and/or Base Asbestos Management Plans and Registers
Environment and Sustainability Manager (ESM)
Defence Workplace Health and Safety Guidance, including the Departmental AsbestosManagement Plan
WHS Codes of Practice (Commonwealth)
Smart Infrastructure Handbook
1 A Code of Practice applies to anyone who has a duty of care in the circumstances described in the Code. In most cases,following an approved COP would achieve compliance with the health and safety duties in the Act, in relation to the subjectmatter of the Code.
UNCLASSIFIED
UNCLASSIFIED
Table of contentsQuick Reference Guides ............................................................................................. ii
Table of contents........................................................................................................ ivAbbreviations............................................................................................................... v
1. Introduction .........................................................................................................11.1 Background..........................................................................................................................1
1.2 Purpose................................................................................................................................1
1.3 Defence Documentation ......................................................................................................2
2. Regulatory Overview...........................................................................................42.1 Commonwealth Legislation..................................................................................................4
2.2 State and Territory Regulatory Compliance ........................................................................8
2.3 Defence Requirements ........................................................................................................9
3. Contamination Risk........................................................................................... 103.1 Background........................................................................................................................10
3.2 Conceptual Site Model.......................................................................................................10
3.3 Contaminants of Potential Concern and Hazardous Materials..........................................11
4. Projects and Contamination Management ........................................................ 174.1 Background........................................................................................................................17
4.2 Case Studies......................................................................................................................17
4.3 Case Study 1: Demolition of 1960s vehicle maintenance building....................................18
4.4 Case Study 2: Storm damage of an asbestos clad building..............................................19
4.5 Management ......................................................................................................................20
5. Data and Reporting........................................................................................... 225.1 GEMS EFM – CSR ............................................................................................................22
5.2 Geographic Information Systems ......................................................................................22
6. References........................................................................................................23
Figure indexFigure 1-1 Overview of Defence Environmental Documentation and Annex J.....................................3
Figure 3-1 Contamination Risks Associated with Demolition Activities ..............................................16
UNCLASSIFIED
UNCLASSIFIED
AbbreviationsAbbreviation Meaning
ACM Asbestos Containing Materials
ACQ Alkaline Copper Quaternary
ADES Assistant Director, Environmental and Sustainability
ANZECC Australian and New Zealand Environment and Conservation Council
AS Australian Standard
ASBINS Asbestos in soils
ASC NEPM National Environment Protection (Assessment of Site Contamination) Measure1999 (Cth) (NEPC 2013)
BCM Bromochloromethane
CC Compliance Code
CCAs Copper Chrome Arsenate
CFCs Chlorofluorocarbons
CFLs Compact Fluorescent Lamps
COP Code of Practice
CSM Conceptual Site Model
CSR Contaminated Sites Record
DEPAC Directorate of Environmental Planning, Assessment and Compliance
DRN Defence Restricted Network
DCARM Directorate of Contamination Assessment, Remediation and Management
DEQMS Defence Estate Quality Management System
DMP Demolition Management Plan
ECC Environmental Clearance Certificate
EPA Environment Protection Authority or Agency
EPBC Act Environment Protection Biodiversity Conservation Act 1999 (Cth)
ESM Environment and Sustainability Manager
GEMS EFM –CSR
Garrison Estate Management System Environmental Factor Management –Contaminated Site Record
GIS Geographic Information System
HBFCs Hydrobromofluorocarbons
HCB Hexachlorobenzene
HCFCs Hydrochlorofluorocarbons
UNCLASSIFIED
UNCLASSIFIED
Abbreviation Meaning
HID High Intensity Discharge
LOCR Defence Legal Obligations and Compliance Register
NEPC National Environment Protection Council
NEPM National Environment Protection Measure
NMP National Management Plan
NSIMS National Spatial Information Management System
OCP Organochlorine Pesticides
ODSs Ozone Depleting Substances
OPPs Organophosphate Pesticides
PCB Polychlorinated Biphenyls
PFAS Per- and Poly-Fluoroalkyl Substances
PPE Personal Protective Equipment
SGGs Synthetic Greenhouse Gases
Stage 1 PSI Stage 1 Preliminary Site Investigation
Stage 2 DSI Stage 2 Detailed Site Investigation
WHS Work Health and Safety
WHS Act Work Health and Safety Act 2011 (Cth)
UNCLASSIFIED
1. Introduction1.1 Background
Defence infrastructure has the potential to contain hazardous building materials and in particularasbestos containing materials due to the historical use of hazardous materials in constructionactivities. The uncontrolled disturbance of these hazardous building materials during demolitionactivities can cause the release of contaminants.
Contaminants released during demolition activities at Defence sites have the potential tointroduce hazards and risks within the immediate vicinity of the demolition site, and in thesurrounding base or off-site community and the environment, including:
Physical harm to persons involved with the demolition activities.
Environmental harm through release of hazardous building materials to the atmosphere(e.g. dusts containing heavy metals, synthetic mineral fibres, organic compounds etc.).
Contamination of soil, groundwater, air and surface water that may cause ongoing risks tohuman health and future redevelopment.
Contaminants of potential concern (discussed in Section 3.2) commonly encountered withinbuildings/structures/plant on Defence land typically include lead paint, Asbestos ContainingMaterial (ACM) and poly-chlorinated biphenyls (PCB).
Appropriate management of demolition and associated waste management activities is requiredto minimise risks and to avoid impacts on Defence operations and capabilities.
When considering waste management options for materials associated with demolition, thewaste management hierarchy of management options must be used. This prioritises theavoidance and minimisation of waste, reuse, recycling and recovery over landfill disposal.Materials may only be disposed of to landfill only where no practical alternative exists (SmartInfrastructure). Use of the Base Services Waste Contractor is encouraged and the datacollection requirements in Smart Infrastructure must be followed.
Management or segregation of waste shall aim as far as is possible, to minimise landfill disposaland maximise waste resource recovery by, e.g.:
Separating inert demolition waste from metal recyclable waste.
Identifying and removing contamination in demolition waste.
Early engagement with the waste contractor to ensure appropriate waste segregationfacilities are available.
The management measures used to address both historical and recent contamination arecommon however, the timeframe by which the measures are implemented may differ dependingon the degree of risk posed by the contamination to human health and the environment.
1.2 Purpose
This purpose of this document is to provide guidance to Defence personnel and contractorssupervising Defence works that may encounter contamination (soil, sediment and water) as aresult of demolition activities or when working in an area of historic demolition across theDefence Estate.
It is noted that this guide does not address the following:
UNCLASSIFIED
Heritage requirements for demolition and/or refurbishment of buildings or structures (referDirectorate of Environment, Heritage and Policy Development).
Contaminated soil present beneath buildings or structures that is associated with legacycontamination (refer Defence Contamination Management Manual).
WHS requirements for asbestos which are captured under the Defence WHS Manual.
1.3 Defence Documentation
This guidance document is an Annex to the Defence Contamination Management Manual andsupports compliance with site contamination management policy as detailed in the DefenceEnvironment and Heritage Manual. An overview of where this Annex fits into the Manual ispresented in Figure 1-1.
UNCLASSIFIED
Figure 1-1 Overview of Defence Environmental Documentation and Annex J
UNCLASSIFIED
2. Regulatory OverviewDefence and its contractors must operate to comply with all Commonwealth legislation,including the Work Health and Safety Act (WHS Act), Environmental Protection and BiodiversityConservation Act (EPBC Act) and the National Environmental Protection (Assessment of SiteContamination) Measures (NEPM). Reference can be made to the Defence Legal Obligationsand Compliance Register (LOCR) found on Defence Estate Quality Management System(DEQMS).
Defence may not be subject to State and Territory law in all situations. Whether or not Defenceis bound by State and Territory law is a complex issue and legal advice must be obtained toconfirm whether a particular State or Territory law is applicable to Defence. Defencecontractors must comply with relevant State or Territory laws.
Guidance relating to the assessment of site contamination is outlined in the NationalEnvironment Protection Council (NEPC) 1999 (Cth), National Environment Protection(Assessment of Site Contamination) Measure (NEPM) as amended in May 2013.
2.1 Commonwealth Legislation
2.1.1 Workplace Health and Safety Act 2011
The Work Health and Safety Act 2011 (Cth) (WHS Act) commenced in 2012 and is regulated byComcare, a Commonwealth Government agency that works in partnership with the Safety,Rehabilitation and Compensation Commission. The WHS Act provides for a nationallyconsistent framework to protect workers and other persons against harm to their health andsafety through the elimination or minimisation of the risks so far as reasonably practicable.
Under the WHS Act, employers must take all reasonably practicable steps to ensure the healthand safety of its employees and those who are at or near a workplace under the employer'scontrol. This means that Defence and its contractors have obligations to protect the health andsafety of workers and others operating within the vicinity of contaminated land that is on or nearto a workplace under Defence control.
Model Codes of Practice administered by Safe Work Australia provide practical guides toeliminate and minimise the risks to health and safety as required under the WHS Act.
Any controls outlined in the Defence Health and Safety Manual (SafetyMan) must beimplemented when managing contaminated materials.
2.1.2 Work Health and Safety Regulations 2011
The WHS Regulations 2011 provides specific obligations and prohibitions for different types ofwork, such as hazardous work and construction work. The WHS Regulations also set out thedetailed requirements for obtaining authorisations, such as licences and registrations, whereapplicable. The requirement to obtain a licence or registration depends on the class of workbeing completed and should be considered on a case by case basis.
2.1.3 Environment and Heritage Manual
The Environment and Heritage Manual (EHM) (2019) describes the agreed approach toenabling Defence capability through long-term sustainable management of the environment.The EHM provides instruction and policy guidance for all Defence personnel and contractors onDefence’s legislative obligations and stewardship goals in line with the Defence EnvironmentalPolicy and Environmental Strategy 2016-2036.
The Defence Environment and Heritage Manual is an administrative policy framework documentthat applies to all Defence personnel.
UNCLASSIFIED
The EHM is divided into 13 chapters addressing:
Chapter 1 – Environment and heritage management in Defence
Chapter 2 – Environmental assessment and approval
Chapter 3 – Heritage management
Chapter 4 – Domestic biosecurity
Chapter 5 – Native species and communities
Chapter 6 – Soil management;
Chapter 7 – Bushfire management
Chapter 8 – Pollution prevention
Chapter 9 – Site contamination management
Chapter 10 – Estate water management
Chapter 11 – Estate energy management
Chapter 12 – Waste minimisation and management
Chapter 13 – Estate climate adaptation
Each chapter links back to a Strategic Aim of the Defence Environmental Policy and providessupporting documentation to support the implementation of the policy. Chapter 9 addresses sitecontamination management.
2.1.4 Work Health and Safety (Demolition Work) Code of Practice (COP)2015
The Commonwealth Work Health and Safety (Demolition Work) Code of Practice 2015 (theDemolition Code)2 is specific to identifying and addressing risks involving demolition work (suchas hazardous materials, structural considerations, safety of workers etc.). The Demolition Codeoutlines a process to identify, assess and manage risks associated with demolition and providesinformation on the required notifications and licenses.
The Demolition Code, specifically Appendix B of the code, provides for the development of aDemolition Management Plan (DMP) to manage the risks that may be present when conductingthe demolition works. The DMP is required to be present on site during the demolition processto demonstrate active management of the demolition process.
In certain circumstances notification of the demolition works to Comcare is required (forexample, if explosives are planned to be used as part of the demolition). A written notice to theregulator at least 5 days prior to commencement is required for the following activities:
Demolition of a structure, or a part of a structure that is load bearing or otherwise relatedto the physical integrity of the structure, that is at least six metres high.
Demolition work involving load shifting machinery on a suspended floor.
Demolition work involving explosives.
The Demolition Code details the information to be included within the notification. Notificationrequirements may also fall under other applicable codes and standards detailed below.
2 Work Safe Australia also have prepared a Model Code of Practice: Demolition work, February 2016,https://safeworkaustralia.gov.au/doc/model-code-practice-demolition-work
UNCLASSIFIED
Other applicable codes and standards
Additional codes and standards that should be considered when planning and undertakingdemolition activities include:
Work Health and Safety (Construction Work) Code of Practice 2015.
Work Health and Safety (How to Manage Work Health and Safety Risks) Code ofPractice 2015.
Safe Work Australia, Model Code of Practice: Managing Electrical Risks in theWorkplace, February 2016.
Safe Work Australia, Model Code of Practice: Managing the Work Environment andFacilities, December 2011.
Safe Work Australia, Model Code of Practice: How To Safely Remove Asbestos, April2016 (Section 3.2.1 of this document provides further details).
For further codes and guidance documents, consult the Comcare web page on managing risksin the workplace.
2.1.5 Comcare
Comcare’s functions as regulator under the WHS Act and WHS Regulations include:
Monitoring and enforcing compliance with relevant legislation.
Providing advice and information on work health and safety to duty holders and to thecommunity.
Promoting and supporting education and training on matters relating to work, health andsafety.
WorkSafe Authorities undertakes these functions in the State or Territory and operateWorkCover, the State workers compensation schemes.
2.1.6 Environment Protection and Biodiversity Conservation Act 1999 (Cth)
The Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act) is theAustralian Government’s central piece of environmental legislation. It provides a legalframework to protect and manage matters of national environmental significance.
The EPBC Act protects:
The environment, where actions proposed are on, or will affect Commonwealth landand the environment; and
The environment, anywhere globally on land and water, where a Commonwealthagency – including the Department of Defence – are proposing to take an action.
The EBPC Act also protects nine matters of national environmental significance:
World heritage properties
National heritage places
Wetlands of international importance (Ramsar wetlands)
Listed threatened species and communities
Listed migratory species
Commonwealth marine areas
The Great Barrier Reef Marine Park
UNCLASSIFIED
Nuclear actions (including uranium mining)
A water resource in relation to coal seam gas development and large coal miningdevelopment.
Defence uses a comprehensive environmental impact assessment and approval program tounderstand and manage the impacts of its activities on the environment and heritage, and toensure compliance with the EPBC Act.
Under the Defence Environment and Heritage Manual, the Director of Environmental Planning,Assessment and Compliance (DEPAC) is the Defence technical authority for determiningcompliance with the EPBC Act. All matters that may trigger the EPBC Act are to be referred toDEPAC.
DEPAC undertakes a self-assessment against the Significant Impact Guidelines 1.1 and 1.2published by the Department of the Environment and Energy to determine if a ‘significantimpact’ EPBC Act protected matter is likely. The self-assessment process considers the natureand extent of contamination and if the presence, disturbance, removal or remediation of existingcontamination is likely to have a significant impact on EPBC Act protected matters. Where asignificant impact to the environment is ‘likely’ the action must be referred to the Minister for theEnvironment and Energy to make a determination on whether a proposed action is a ‘controlledaction’.
For more information with regard to the EPBC Act refer to http://www.environment.gov.au/epbc/.
The following documents are the basis by which other relevant codes around wastemanagement have been developed:
The National Waste Policy (2018) outlines roles and responsibilities for collective actionby businesses, governments, communities and individuals. It is an enabler forcollaboration, legislation and regulation on waste minimisation and management issues.The Defence Waste Minimisation and Management Policy is aligned with the fiveoverarching principles of the policy, which include:
Avoid waste
Improve resource recovery
Increase use of recycled material and build demand and markets for recycledproducts
Better manage material flows to benefit human health, the environment and theeconomy
Improve information to support innovation, guide investment and enable informedconsumer decisions
The policy supports decision making whereby governments, businesses andindustries collaborate to implement tailored waste management solutions in responseto local and regional circumstances.
The Hazardous Waste (Regulation of Exports and Imports) Act 1989 regulates the importto and export from Australia and transit of hazardous waste. The HW Act does notregulate movements of hazardous waste within Australia. Hazardous waste, for thepurposes of the HW Act, include wastes that are mentioned in Annex III of the BaselConvention. An application for an authorisation to import or export of hazardous waste isrequired to be made to the Minister.
National Strategy for the Management of Scheduled Waste, 1993 the National Strategywas endorsed by Australian and New Zealand Environment and Conservation Council(ANZECC) in 1993 and provides for the safe management and disposal of scheduled
UNCLASSIFIED
wastes. An outcome of the National Strategy was the development of the three nationalplans for Scheduled Waste:
– Organochlorine Pesticides (OCPs) Waste Management Plan (1999)
– Polychlorinated Biphenyls (PCBs) Management Plan (2003)
– Hexachlorobenzene (HCB) Waste Management Plan (1996)
2.1.7 NEPM
The National Environment Protection (Assessment of Site Contamination) Measures 1999 (Cth)(the ASC NEPM) was made under the National Environment Protection Council Act 1994 (Cth).The ASC NEPM is the national guidance document for the assessment of site contamination inAustralia. It is given effect by the National Environment Protection Measures (Implementation)Act 1998 (Cth) for the Commonwealth and individual legislation and guidelines in each Stateand Territory.
The National Environment Protection Council (NEPC) agreed to vary the NEPM by approvingan amending instrument to the ASC NEPM in 2013.
All assessments of site contamination on the Defence Estate are to be undertaken inaccordance with the recommended process and guidance provided in the ASC NEPM.
The purpose of the ASC NEPM is to establish a nationally consistent approach for theassessment of site contamination; to ensure sound environmental management practices by thecommunity, including regulators, site assessors, site contamination consultants, environmentalauditors, landowners, developers and industry parties.
The desired outcome of the ASC NEPM is to provide adequate protection of human health andthe environment, where contamination has occurred, through the development of an efficientand effective national approach to the assessment of site contamination.
The ASC NEPM and schedules are available for download through the NEPC website. TheASC NEPM Toolbox contains additional information including calculators, spreadsheets andother supporting documents to assist with application of the amended ASC NEPM.
NEPM (Movement of Controlled Waste between States and Territories) Measure (MCWNEPM)
The MCW NEPM regulates the movement of controlled waste between States and Territories.Schedule A provides an overview of all waste categories and the characteristics of controlledwastes listed under the MCW NEPM. Schedule B provides an overview of the reportingrequirements for movement of controlled wastes listed under the MCW NEPM. Where Defenceis transporting controlled waste between States or Territories, a consignment authorisationwould need to be obtained from the State or Territory where the waste is being moved to.
2.2 State and Territory Regulatory Compliance
Defence may not be subject to State and Territory law in all situations. Whether or not Defenceis bound by State and Territory law is a complex issue and legal advice must be obtained toconfirm whether a particular State or Territory law is applicable to Defence. Defencecontractors must comply with relevant State or Territory laws.
2.2.1 State and Territory waste disposal requirements
Local and state/territory legislative requirements should be considered during demolitionplanning and prior to commencement of works, where off-site disposal options are beingconsidered. If demolition material is to be processed as fill for either reuse onsite or for offsite
UNCLASSIFIED
reuse/disposal reference should be made to the Annex C – Stockpiles and Reuse ofContaminated Material.
2.2.2 Off-site migration
The Defence Project Manager should obtain professional advice to inform the reporting andmanagement of any contamination that is found to have migrated off-site into a State/Territoryjurisdiction. Delineating the nature and extent of the off-site contamination will assist Defence toimplement appropriate mitigation measures and to manage any legal implications. A link to thevarious State and Territory environmental agencies can be found in the Defence ContaminationManagement Manual]. Any interaction with State or Territory environmental regulators must onlyoccur after first consulting the Directorate of Contamination Assessment, Remediation andManagement (DCARM) and if applicable the Environment and Sustainability Manager (ESM).
2.3 Defence Requirements
2.3.1 Defence Legal Obligations and Compliance Register
Defence and its contractors must operate to comply with all Commonwealth legislation,including the WHS Act, EPBC Act and the NEPM. In addition, Defence and its contractorsshould be generally familiar with the legislative and other regulatory requirements associatedwith the site activities undertaken relevant to the State or Territory in which the site is located.Contractors must comply with State and Territory laws where applicable. Reference can bemade to the Defence Legal Obligations and Compliance Register (LOCR) found on DEQMS.
2.3.2 Defence Waste Minimisation and Management Policy
The Defence Waste Minimisation and Management Policy contained in the DefenceEnvironment and Heritage Manual, is aligned with the principles of the National Waste Policy.Specifically in relation to demolition activities, the policy commits to the following:
Ensure the whole-of-life costs of product stewardship including waste and disposal areconsidered in decision making;
Reuse, recycle or recover materials and goods where available;
Reduce the amount of waste sent to landfill;
Avoid problematic and unnecessary single use plastic items where viable alternativesexist;
Increase the amount of recycled content in goods and infrastructure procurement wherefit for purpose products are available;
Improve data management, with a focus on governance and compliance;
Influence positive behaviour and improve education around waste avoidance andmanagement; and
Pursue opportunities in waste and resource management that retain the value ofmaterials in the economy for as long as possible, reduce the depletion of naturalresources and impacts of waste generation on the environment.
As a general principle, if waste from demolition activities is proven to chemically suitable, andwhere relevant, structurally and geotechnical suitable, it can and should be reused rather thanstockpiled indefinitely or sent for landfill disposal.
The Defence Smart Infrastructure Handbook provides specific guidance on waste managementmeasures and requirements for demolition and should be adhered to.
GHD | Report for Department of Defence - Annex J, | 10
3. Contamination RiskThe demolition of buildings and structures has the potential to result in significant work, healthand safety and environmental impacts. This section identifies common hazardous buildingmaterials that could exist in buildings and structures, and provides a guide to the managementof associated risks to human health and the environment where demolition is not adequatelycontrolled.
3.1 Background
Buildings and structures can contain a variety of substances that have the potential to behazardous to humans and the environment. If building materials remain in a good condition andare left undisturbed, most hazardous materials will remain benign and will not present a risk tohumans or the environment. However, during demolition potentially hazardous substancespresent in the building fabric have the potential to interact with persons undertaking demolitionactivities, or could have a negative impact on the environment if not managed appropriately.
3.2 Conceptual Site Model
As described in the ASC NEPM, a Conceptual Site Model (CSM) describes the contaminationsources, pathways and receptors and the potential linkages between these.
The initial CSM is constructed from the results of a Stage 1 Preliminary Site Investigation(Stage 1 PSI) and is the basis for defining where potential source-pathway-receptor linkagesmay exist, which require further investigation. The CSM must be continually reviewed andupdated throughout the assessment process to inform subsequent decisions on whether furtherinvestigation or contamination management actions are required.
The CSM should identify complete and potential pathways between known or potentialcontamination sources and receptors. Where the pathway between a source and a receptor isincomplete, the exposure to chemical substances via that pathway cannot occur, but thepotential for that pathway to be completed (for example, by abstraction of groundwater or achange in land use) should be considered in all stages of assessment. The CSM can also beused to consider where management measures would reduce the likelihood of an exposurepathway becoming complete.
The essential elements of a CSM are:
Known and potential sources of contamination and contaminants of concern including themechanism(s) of contamination (e.g. ‘top down’ spill or sub-surface release from corrodedtank or pipe).
Potentially affected media (e.g. soil, sediment, groundwater, indoor and ambient air).
Human and ecological receptors.
Potential and complete exposure pathways.
For contaminated land site investigation reports (e.g. Stage 2 Detailed Site Investigation(Stage 2 DSI)) the CSM is to be presented as a graphic, a table or flow chart and adequatelydescribed in written text.
UNCLASSIFIED
3.3 Contaminants of Potential Concern and Hazardous Materials
3.3.1 Asbestos Containing Materials (ACM)
The WHS Regulations prescribe specific requirements in relation to asbestos containingmaterials that must be met by any person managing or controlling a workplace. Requirementswith respect to asbestos are addressed under Chapter 8 of the WHS Regulations.
Compliance with the asbestos obligations in the WHS Act is regulated by Comcare.
A person conducting a business or undertaking a workplace must ensure that:
exposure of a person at the workplace to airborne asbestos is eliminated so far asreasonably practicable; and
if it is not reasonably practicable to eliminate exposure to airborne asbestos – exposure isminimised so far as reasonably practicable.
A person with management or control of the workplace, or of a structure or plant, must ensure:
that all asbestos that is likely to be disturbed by the demolition is identified; and
so far as is reasonably practicable, that the asbestos is removed before the demolition iscommenced.
Where the quantity of non-friable asbestos exceeds 10 m2, a Class B Licenced asbestosremoval contractor (as a minimum) must be engaged to remove ACM so far as reasonablypracticable ahead of demolition. If friable asbestos is present, a Class A licenced asbestosremoval contractor must be engaged. An exemption from licenced removal requirements existsfor “asbestos-contaminated dust or debris” that is associated with removal of < 10 m2 of non-friable asbestos, or is not associated with removal of friable or non-friable asbestos and is “onlya minor contamination”. All works to remove ACM must be undertaken in accordance withSafeWork Australia, How To Safely Remove Asbestos Code Of Practice, April 2016.
Examples of asbestos containing materials
Asbestos is present in a wide range of building materials that were historically used inconstruction of infrastructure. Where materials suspected of containing asbestos areencountered, the material should be assumed to contain asbestos until confirmation is madethrough analysis in accordance with Australian Standard AS 4964-2004: Method for thequalitative identification of asbestos in bulk samples. The following is a list of commonlyencountered ACM:
Asbestos cement products – wall cladding (e.g. Asbestolux, roofing sheet, rainwaterproducts, water pipes and communications pit linings).
Fibrous asbestos products – lagging applied to pipes, textiles (e.g. fire blankets), sprayfire proofing on structural beams, medium density fibre board acoustic panels, loftinsulation and rope/compressed gaskets.
Mastic and resin asbestos products – caulking of joints/penetrations, adhesives, toiletcisterns and jointing compounds on ductwork.
Bitumastic asbestos products – mounting board in electrical cabinets, roofing membraneand expansion joint compounds in concrete.
Thermoplastic asbestos products – vinyl floor tiles and linoleum.
UNCLASSIFIED
3.3.2 Asbestos in Soils
Asbestos in soil (ASBINS) can largely be attributed to either legacy issues (historically poormanagement of ACM, illegal disposal and landfilling activities) or demolition practices.Demolition projects that have identified asbestos or other hazardous materials present instructures for removal are to operate under the Defence WHS Manual procedures.
There are other mechanisms that may also contribute to asbestos in soils:
Emergency situations – natural disasters, fires.
Naturally occurring asbestos.
Derelict mining sites.
Waste or recycled materials that contain ACM.
Asbestos only poses a risk to human health when elevated levels of asbestos fibres are inhaled.The likelihood of exposure occurring depends upon the potential for the asbestos material torelease fibres, whether the asbestos material is contained or covered, and any operationalcontrol measures or personal protective equipment which have been applied to limit thegeneration and/or inhalation of airborne fibres.
Non-friable asbestos, previously referred to as ‘bonded asbestos’, in sound condition representsa low human health risk. However, friable asbestos materials or damaged, crumbling bondedasbestos, have the potential to generate, or be associated with, free asbestos fibres andtherefore must be carefully managed to minimise the release of asbestos fibres into the air.
3.3.3 Legislative requirements and guidelines for Asbestos
Primary legislative requirements and guidance detailing Defence’s obligations regarding thepresence of asbestos on the site are listed as follows:
WHS Act 2011.
WHS Regulation 2011.
Code of Practice – How to Manage and Control Asbestos in the Workplace, 2014.SafeWork Australia.
Code of Practice – How to Safely Remove Asbestos, 2014. SafeWork Australia.
SafetyMan.
National Environmental Protection (Assessment of Site Contamination) Measure 1999(Cth) (as amended 2013) (NEPC, 2013).
Defence Asbestos Management Plan
3.3.4 Lead based Paint
Lead paint is defined by AS 4361.2 – 1998, Guide to Lead Paint Management, Part 2 –Residential and Commercial buildings) as:
“…a paint film or a component coat of a paint system containing lead or lead compounds, inwhich the lead content (calculated as lead metal) is in excess of 1% by weight of the dry film asdetermined by laboratory testing”.
Chapter 7, Part 7.2 of the WHS Regulation, identifies processes associated with lead that areregulated. The following sub-sections are applicable to demolition activities:
Machine sanding or buffing of surfaces coated with paint containing greater than 1% bydry weight of lead metal.
UNCLASSIFIED
A process in which electric arc, oxy-acetylene, oxy gas, plasma arc, or a flame is appliedfor the purposes of welding, cutting, or cleaning, to the surface of metal that is coated withlead or paint containing greater than 1% by dry weight of lead metal.
Use of a power tool, including abrasive blasting and high pressure water jets, to removeany surface coated with paint containing greater than 1% by dry weight of lead metal, andthe handling of waste containing lead resulting from that removal.
The WHS Regulation sets out the requirements for employers to provide:
Information to workers on the hazards and risks associated with lead.
Provisions for medical examination and biological monitoring.
Advice about identifying the presence of lead paint in structure during planning for ademolition.
3.3.5 Polychlorinated biphenyls contaminated equipment
Polychlorinated Biphenyls (PCBs) are primarily managed under the Polychlorinated BiphenylsManagement Plan (the National Management Plan), 2003, published by the ANZECC, which isincorporated in to jurisdictional environment acts and regulations.
The disposal of materials or wastes containing PCBs at a concentration of more than 2 mg/kg isregulated.
The aim of the PCB management framework is to:
Protect human health and the environment.
Manage and phase out all remaining equipment and materials containing PCBs, in linewith the objectives of the National Management Plan (NMP).
Ensure that PCBs are stored, handled, transported, treated and disposed of in a safe andproper manner.
Minimise contamination of other materials with PCBs.
Maintain a public register that lists the location, quantity and concentration of PCBs atpremises where material, equipment and waste is greater than 10 kg or in excess of thethreshold concentration and quantity of 50 mg/kg and 50 g.
The Plan also identifies the requirements for interstate movements for disposal of PCBs thatexceed 50 mg/kg.
The NEPM 1999 (Cth) (as amended 2013), specifies that PCB limits for sensitive land use mustnot exceed the criteria of 2 mg/kg.
Examples of PCB containing products
Products that may potentially contain PCBs include:
Old fluorescent light capacitors, street lamp capacitors and lighting ballasts.
Electrical transformers and electrical capacitors in plant and equipment.
Caulking to window frames.
PCB contaminated soils (where PCBs have been associated with underground cabling).
Until the late 1970s and early 1980s, PCBs were used as a dielectric oil in transformers andcapacitors. In some instances, PCBs were also used in hydraulic oil and caulking materials, fortheir high dielectric strength and inflammable properties. As PCBs are toxic to humans wheningested, through absorption of the skin/mucus membranes/eyes etc. or inhaled as absorbed on
UNCLASSIFIED
dust particles or fumes. PCBs are bio-accumulative and non-biodegradable, their safe disposalis difficult due to their stable nature and toxicity even at low concentrations. During combustion,PCBs may form even more toxic compounds including chlorinated dibenzofurans.
3.3.6 Mercury containing wastes
Mercury containing wastes are regulated. Where elemental mercury is present within items orequipment (e.g. mercury containing lamps), the waste producer is required to follow the federalrequirements detailed within the National Waste Policy: Less Waste, More Resources,November 2009. This policy provides specific guidance regarding disposal of mercurycontaining lamps, and includes the following details:
Generally, the higher the power usage, the more mercury that is required to operate thelamp. Mercury containing lamps include:
– High Intensity Discharge (HID) lamps, such as mercury vapour lamps used for streetlighting, which contain between 50 and 1000 milligrams (mg) of mercury per lamp.
– Linear fluorescent tubes, as used in most commercial and public buildings, which arerequired by an AS to contain less than 15 mg of mercury per tube.
– Compact Fluorescent Lamps (CFLs), used mostly in homes, which are required by anAS to have a maximum of 5 mg of mercury per bulb.
– Some neon tubes, such as those used in signs.
Where these items are encountered (offices, warehouses garages, any building/structurerequiring internal lighting), they must be handled carefully to prevent damage that could lead tothe release of mercury vapour. They must be transported by a licensed waste contractor to aspecialist recycler for recovery of the mercury.
Examples of mercury containing products
Mercury containing apparatus may include, but is not limited to:
Electrical switches and thermostats
Thermometers
Fluorescent tubes
Pressure gauges
3.3.7 Ozone Depleting Substances (ODSs)
ODSs are substances that deplete the ozone layer. ODSs include chlorofluorocarbons (CFCs),halon, carbon tetrachloride, methyl chloroform, hydrobromofluorocarbons (HBFCs),hydrochlorofluorocarbons (HCFCs), methyl bromide and bromochloromethane (BCM). Thesematerials are recognised as being significant greenhouse gases, and require managementthrough the Ozone Protection and Synthetic Greenhouse Gas Management Act 1989 (Cth).
Examples of where ODSs are present
ODSs indirectly impact humans by reducing the ozone layer in the atmosphere; however, theyare not necessarily directly harmful to humans. ODSs can be found in the following items withinbuildings, and must be removed prior to demolition:
Refrigerators
Air conditioners
Fire extinguishers
Dry cleaning (as solvents for cleaning)
UNCLASSIFIED
Electronic equipment
Agricultural fumigants (potentially stored in old drums in remote sites that are unaccountedfor).
It is understood that Defence over the years has phased out or replaced ODS. However, prior tocommencement of demolition activities, any equipment that has the potential to contain ODSshould be inspected and any refrigerant is to be removed by a licenced air conditioningengineer.
3.3.8 Other waste materials
Other wastes may be present in structures, including oils, sludge, soil and liquid wastes, whichare all subject to environmental waste disposal regulations. Defence should undertake anassessment of the demolition site to determine if any of the material is of a type that requiresspecial handling in that jurisdiction, noting that definition or classification of a waste ashazardous, controlled, regulated or prescribed waste differs between each state/territoryjurisdiction. As a result the management requirements will be specific to the location where thewaste is generated. Other waste materials associated with the demolition process may include,but are not limited to:
Ceramic/synthetic mineral fibres (e.g. fibrous insulation and woven textiles).
Biological/medical wastes (e.g. legionella in wastewater and waste contaminated withblood).
Treated timber products (copper chrome arsenate (CCA), alkaline copper quaternary(ACQ) and copper azole).
Non-recyclable building materials.
Concrete and brick impacted by other contaminants, such as oils and/or heavy metalsand/or Per- and Poly-Fluoroalkyl Substances (PFAS), organophosphate pesticides(OPPs) and organochlorine pesticides (OCPs), explosive residues associated with pastmanufacturing/storage/handling.
Underground storage systems including tanks, pits, pipework, etc. Also refer to Annex E –Fuel Facilities.
Industrial wastes are not regulated as prescribed industrial wastes. However, when disposed ofto landfill, industrial wastes continue to be controlled by the EPA. These wastes can beaccepted at solid inert landfills (non-putrescible) or municipal solid waste landfills (putrescible)that are licensed by a State or Territory EPA to accept this type of waste.
Prescribed industrial and controlled wastes are wastes that require control and/or ongoingmanagement due to their potential to pose a risk to human health and the environment. Solidprescribed industrial wastes must be disposed of at appropriately licensed waste disposal ortreatment facilities.
Wastewater and effluent discharges into the environment are subject to works approvals andlicensing. An exemption from these statutory processes may be applicable where an effluentreuse scheme meets the relevant EPA specifications.
3.3.9 Graphical Conceptual Site Model
A visual representation of a Conceptual Site Model (CSM) relating to demolition, and thepotential contamination sources, pathways and receptors is presented in Figure 3-1.
UNCLASSIFIED
Figure 3-1 Contamination Risks Associated with Demolition Activities
UNCLASSIFIED
4. Projects and ContaminationManagementDemolition can be a hazardous and high-risk activity if it is not managed appropriately. Theappropriate and safe management of demolition activity requires careful planning andpreparation.
4.1 Background
The demolition of buildings, structures and plant containing hazardous materials may pose apotential risk to human health and the environment or it can result in an ongoing sitecontamination legacy if not managed appropriately. Construction delays related to inadequateplanning and management of hazardous building materials has the potential to increase risk,costs and to impact Defence capability.
Demolition planning includes conducting a hazardous materials survey to identify materials thatmust be safely removed and segregated prior to full building demolition. Demolition (pre-demolition and during demolition) planning and management will minimise potential risks to thehealth and safety of persons conducting the activities, as well as the risk of contamination of thesurrounding environment.
4.2 Case Studies
The following case studies highlight the contamination risks related to demolition activities andidentify management measures and sources of further information to address thesecontamination issues. These case studies are hypothetical examples only and are not based onactual events.
UNCLASSIFIED
4.3 Case Study 1: Demolition of 1960s vehicle maintenance building
4.3.1 ScenarioA small vehicle maintenance facility is to be demolished ahead of theconstruction of a larger vehicle maintenance facility. While undertakingsoft strip out of the buildings prior to demolition, the following risks areidentified:
Bonded asbestos cement sheeting >10 m2 in office areas andceiling voids.
Live services within the building. A waste oil tank below the vehicle workshop floor.
All works are placed on hold while health and safety risks areassessed. During the investigation, it is discovered that a notification ofdemolition works to Comcare has not been submitted. In consultationwith the Defence ESMs and/or Regional Safety/OH&S Officer and thedemolition contractor, it is determined that a licensed asbestos removalcontractor must be engaged, the building must be isolated andservices disconnected, and the controlled removal of waste oil must beundertaken. These actions subsequently result in project delays by fiveweeks, affecting Defence operations and capability.
4.3.2 RisksHSE Risk – Hazardous building materials may expose constructionworkers and surrounding site users to a human health risk through theinhalation of contaminants such as asbestos fibres. Contaminants maymigrate into the surrounding environment and structures, causingfurther health risks.
Defence Capability – Stopping work to make the site safe ahead ofdemolition causes project delays and additional management actionsand costs. This can have a significant impact to Defence capability.
4.3.3 Key considerations and management measures Has notification to the regulator for the demolition of the building
been issued or reviewed? Have preliminary investigations (review of asbestos register/asbestos clearance
certificates/site assessment report/etc.) on the building/structure/plant been undertaken toenable safe demolition and to characterise the full extent of any hazardous building materialsthat may be present?
Is an assessment under the EPBC Act required to determine if the demolition has thepotential to significantly impact on a Matter of National Environmental Significance or theenvironment?
Has sufficient time and budget been included within the project to allow for removal ofhazardous materials and the segregation of recoverable/recyclable waste materials?
Is offsite disposal of contaminated waste required; have the appropriate disposalpermits/licenses been obtained through the relevant state or territory regulatory framework,where relevant?
4.3.4 More information Defence Guidance on Demolition ESM Regional Safety/OH&S Officer Defence Workplace Health and Safety Guidance Defence Asbestos Management Plan
Why is this an issue?Asbestos, othercontaminants and liveservices pose a health andsafety risk to workers andthe surroundingenvironment.Investigations/removalworks create additionalcosts that effect Defencecapability by delayingproject work.
How can I manage it?Undertake preliminary siteinvestigations to confirmthe condition and status ofthe building ahead ofdemolition so that activitiesaround removal and makesafe can be planned,budgeted and incorporatedinto the works programme.
Further information? Regional Safety/OH&S
Officer Defence ESM Defence WHS Guidance
Documents
UNCLASSIFIED
4.4 Case Study 2: Storm damage of an asbestos clad building
4.4.1 Scenario
During a heavy storm event, a storage building clad in asbestos cementsheeting is damaged. Because of the damage, an asbestos removalcontractor is engaged under a 24 hour asbestos removal notification toremove the remaining asbestos (<10 m2). A separate contractor isengaged to re-clad the building with corrugated iron cladding.
During removal works, the cladding contractor inappropriately removesthe asbestos materials using power tools. The poor management of theasbestos removal impacts the workers and causes the contamination ofnon-hazardous waste with asbestos, increasing the costs for handlingand disposal.
All works are placed on hold while a regulator assesses health andsafety risks. Investigations find that the cladding contractor was notadvised that the building was still partially clad with asbestos. Thedelays impact the project timeline, create health and safety concernsand increase costs for disposal of contaminated waste.
4.4.2 Risks
HSE – Utilising contractors that are unfamiliar with hazardous buildingmaterials or managing contamination risks may expose workers andsurrounding site users to human health risks through the inhalation ofcontaminants and impact the surrounding environment.
Defence Capability – Stopping work to make the site safe ahead ofdemolition causes project delays and additional management actionsand costs. This can have a significant impact on Defence capability.
4.4.3 Key considerations and management measure
The use of a licensed asbestos removal contractor must alwaysbe considered. In cases where the quantity is <10 m2, thecontractor undertaking the works must have a safe work methodstatement and risk assessment that is based upon the Code ofCompliance for asbestos removal.
Has notification to the regulator for the demolition of the buildingbeen issued or reviewed?
Have the preliminary investigations (review of asbestos register/asbestos clearancecertificates/site assessment report/etc.) on the building/structure/plant being undertakento enable safe demolition and to characterise the full extent of any hazardous buildingmaterials that may be present?
Is an assessment under the EPBC Act required to determine if the demolition has thepotential to significantly impact on a Matter of National Environmental Significance,heritage or the environment?
Has sufficient time and budget been included within the project to allow for removal ofhazardous materials and the segregation of recoverable/recyclable waste materials?
Is offsite disposal of contaminated waste is required; have the appropriate disposalpermits/licenses been obtained through the relevant state or territory regulatoryframework?
4.4.4 Further information
Defence ESM Defence Workplace Health and Safety Guidance Defence Asbestos Management Plan
Why is this an issue?Asbestos, othercontaminants and liveservices poses a healthand safety risk to workersand the surroundingenvironment.Consider the experienceand knowledge ofcontractors who haveundertaken works of asimilar nature in the past.
How can I manage it?Identify and plan toeliminate hazards andrisks by utilisingcontractors that arelicenced and trained fordealing and managinghazardous buildingmaterials/contaminationand can implementeffective wastemanagement strategies.
Further information? Regional Safety/OH&S
Officer Defence ESM Defence WHS
Guidance Documents
UNCLASSIFIED
4.5 Management
4.5.1 Project Management
The implementation of effective risk mitigation measures from the initial project-planning phasethrough to project execution is critical for projects involving demolition where hazardousmaterials present a risk. The following is mandatory:
Review GEMS EFM and Asset data. Gather historical data relating to thebuilding/structure/plant that is to be demolished. Where data gaps exist, especiallyaround regulatory compliance (WHS Regulations and EPBC Act), implementinvestigations to close any data gaps. Identify the various notifications and permitsneeded for the overall demolition process.
Engage appropriately licenced and/or competent persons to conduct assessments and toprepare plans for hazardous building materials, contamination, live utilities, whererequired.
Consider management options for the types and volumes of waste likely to be generated,noting the requirements of the Defence Waste Minimisation and Management Policy.
Complete preliminary works to remove hazardous building materials, contamination andutility hazards if present within a building/structure/plant prior to the demolition works sofar as reasonably practicable.
Use licenced contractors and comply with applicable regulations and codes of practicewhere removal works will be undertaken.
Consider the process of waste handling and management at the assessment stage,especially where the presence of contaminants could either increase the amount of wasteto landfill, and/or reduce the type and volume of materials that could be recovered/recycled. Demolition has the potential to generate a significant amount of waste that mayinclude both contaminated waste and/or non-contaminated recoverable waste.
Incorporate all risks associated with the investigation stage and demolition phase into arisk register so that contractors can develop work methods and approaches to manageeach risk so far as reasonably practicable. Throughout the lifecycle of a project, performcontinuous review of risks and management controls as the project progresses.
Obtain an Environmental Clearance Certificate (ECC) - this is a Defence approval thatimposes conditions and safeguards on an action to ensure environmental impacts areavoided, minimised or remedied.
Flag unforeseen issues that may arise with Defence and consult with RegionalSafety/OH&S Officers/ESMs for advice on further management measures that may berequired.
4.5.2 Contamination management
Successful demolition projects are achieved through planning, actively managing hazards andrisks and maximising resource recovery rather than sending materials to landfill. This can beachieved through the following:
Planning to eliminate all hazards by applying the hierarchy of control to health and safetyand environment protection. The use of Personal Protective Equipment (PPE) is not acontrol mechanism.
UNCLASSIFIED
Understanding the nature of the building/structure/plant to be demolished, and thelocation and quantity of hazardous building materials and other contamination, so thathazards can be removed prior to demolition.
Identifying building materials that are salvageable, reusable and/or recyclable so that theycan be segregated from waste materials.
Monitoring to ensure compliance with risk management and control measures todemonstrate effective control.
Flagging of any exceedances or issues with Defence, and consulting with Defence ESMsto install further management measures, where necessary.
4.5.3 Remediation Management
All efforts should be undertaken to prevent site contamination from demolition activities, and allhazardous materials resulting from demolition must be removed from site for appropriatedisposal. Where asbestos contamination is already present on site due to legacy issues orprevious poor demolition practices (Section 3.3.2), the asbestos should be managed in amanner consistent with national guidance, as outlined in the following extracts from ASC NEPM:
If visible asbestos is present and it may be disturbed during work activities, it must beremoved. This includes removing visible fragments of bonded ACM from exposed trenchfaces and those areas of the site where intrusive works may be carried out. Visibleasbestos should be removed prior to excavation/construction works commencing.
Guidance in relation to assessment and management of asbestos contamination in soilsis provided in ASC NEPM. Remediation options which minimise soil disturbance andtherefore public risk are preferred. Management of asbestos in situ is encouraged, whichmay include covering the contamination with uncontaminated fill or other protective orwarning layers. ASC NEPM notes that the common alternative of complete removal ofasbestos from a site often involves extensive and costly investigative and validationsampling and may not be effective or necessary for the protection of human health.
UNCLASSIFIED
5. Data and Reporting5.1 GEMS EFM – CSR
Data and reports generated as part of the investigation and assessment of demolition areasmust be captured in the GEMS EFM.
The GEMS EFM – CSR is the database used to capture environmental information across theDefence estate, and provides access to historical contamination investigation reports forDefence properties. Contaminated site records are geo-referenced and they can be accessedby Defence personnel or contractors with Defence Restricted Network (DRN) Access.
Contractors/Consultants working on behalf of Defence must provide reports, updated andcompleted GEMS Data Load Tool (GDL) (for new or existing CSR’s), CRAT, ESdat and(Geographic Information System) GIS files relating to contamination to their Defence point ofcontact, Project Manager or ESM who will be responsible for auditing and validatingsubmissions and ensuring the upload of information into the GEMS EFM – CSR.
Refer to the Defence Contamination Management Manual, Annex L – Data Management.
5.2 Geographic Information Systems
All mapping Geographic Information System (GIS) data is required to be provided to Defence inNational Spatial Information Management System (NSIMS) metadata format. The DefenceNSIMS metadata tool is available through an online search and on DEQMS.
Refer to the Defence Contamination Management Manual, Annex L – Data Management.
UNCLASSIFIED
6. ReferencesCommonwealth of Australia, Work Health and Safety (Construction Work) Code of Practice2015.
Commonwealth of Australia, Work Health and Safety (Demolition Work) Code of Practice 2015:https://www.legislation.gov.au/Details/F2016L00409
Commonwealth of Australia, Work Health and Safety (How to Manage Work Health and SafetyRisks) Code of Practice 2015.
Commonwealth of Australia, Work Health Safety Regulations 2011.
Department of Sustainability, Environment, Water, Population and Communities - Constructionand Demolition Waste Guide - Recycling and Re-Use across the Supply Chain, 2011:http://www.environment.gov.au/protection/national-waste-policy/publications/construction-and-demolition-waste-guide
Department of Defence Health and Safety Manual.
Pollution Prevention Management Manual - Annex B CCA treated timber.
Department of Defence Waste minimisation policy.
Department of the Environment and Energy, The National Waste Policy: Less Waste, MoreResources, 2018.
Hazardous Waste (Regulation of Exports and Imports) Act 1989 (Cth).
Australian and New Zealand Environment and Conservation Council (ANZECC),Polychlorinated Biphenyls Management Plan (the NMP), 2003.
Safe Work Australia, How to Safely Remove Asbestos Code of Practice, October 2018.
Safe Work Australia, Managing Electrical Risks in the Workplace. Code of Practice. October2018.
Safe Work Australia, Managing the Work Environment and Facilities, Code of Practice May2018.
Safe Work Australia, Demolition Work, Code of Practice, October 2018
Standards Association of Australia, AS/NZS 4361.2, Guide to Hazardous Paint Management,‘Part 2 – Lead Paint in Residential, publicand Commercial buildings’, 2017.
Standards Association of Australia, AS 4964- 2004, Method for the qualitative identification ofasbestos in bulk samples.
The Environment Protection and Biodiversity Conservation Act 1999 (Cth).
Workplace Health and Safety Act 2011 (Cth)
The Ozone Protection and Synthetic Greenhouse Gas Management Act 1989 (Cth).
