Submissions

Regulation Impact Statement For A National Phase Out Of PFOS

Posted on
March 13, 2019

Ports Australia supports the Government’s initiative to phase-out PFOS and it related chemicals. We are supportive of the strongest initiative outlined – Option 4: Ratify and phase out all non-essential uses.  

There is significant need for action given the impact on human health, stemming from consumption of affected marine life, and high-profile anecdotal evidence of PFOS in ground water surrounding NSW and Queensland military bases.   

While we note the Department’s view that evidence is still evolving regarding environmental and health impacts, there is significant evidence on the devastating impact to animals, (see examples in Regulation Impact Statement (RIS)).

Around the globe, 171 countries have already ratified the Stockholm Convention. Australia’s ports have been proactive in in responding with several disposing of PFOS fire-fighting foam prior to any government consideration on the matter (page. 2).

Challenges, however, exist for those Australian ports that are looking to effectively and efficiently dispose of this hazardous foam: 

  • Disposal of PFOS fire-fighting foam has been difficult due to issues with identification, transportation and incineration. Ports are struggling to source data that clearly identifies whether their fire-fighting foam contains PFOS or a PFOS derivative. There is a lack of guidance and expertise, which the Commonwealth government can overcome by continuing to provide formal advice on the issue or mandating that fire-fighting foam producing companies clearly identify the content with regards to PFOA. Furthermore, there is difficulty and high cost of disposal, with only a single facility for certified incineration of fire-fighting foam, and a lack of service providers that collect and transport the foam. The Commonwealth should look to implement short-term subsidizes for the use of this facility to encourage the proactive disposal of fire-fighting foam to reduce the risk of accidental discharge from those storing it until a cost-effective option is available.  
  • While we note that regulation regarding the fire-fighting foam onboard international ships is determined by the flag country, the use of hazardous foam while a vessel is berthed at a port will lead to run-off into Australian port waters. Lobbying at the International Maritime Organisation (IMO) has recently begun with respect to this matter. In the interim, the Commonwealth Government should consider options on operational restrictions to mitigate the risk caused from international ships carrying fire-fighting foam containing PFOA, including PFOS.

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