Government

Department of Environment and Science

Our Ref: CTS 19601/18

Mr Andrew Laming MP Chair PFAS Sub-Committee PO Box 6021 Parliament House CANBERRA ACT 2600

Dear Mr Laming

I refer to your letter of 30 May 2018 to the Honourable Annastacia Palaszczuk MP, Premier and Minister for the Arts regarding the Per- and Polyfluroalkyl Substances (PFAS) Sub-Committee's inquiry into the management of PFAS contamination in and around Defence bases.

As environmental contamination falls within the portfolio responsibilities of the Honourable Leeanne Enoch MP, Minster for Environment and the Great Barrier Reef, Minister for Science and Minister for the Arts, the Premier forwarded your correspondence to the Minister for the Department of Environment and Science to consider and respond.

On behalf of the Queensland Government, I am pleased to provide the attached submission for consideration.

Should you have any further enquiries, you may contact Mr Andrew Connor, Executive Director, Industry Development and South East Queensland Compliance, Environmental Services and Regulation of the department on telephone (07) 3330 6335 or by email at Andrew.connordes.cild.qov.au.

Yours sincerely

Jamie rnck Direct -General / / lg

Encl. (1)

1 William Street GPO Box 2454 Brisbane Queensland 4001 Australia Telephone + 61 7 3338 9304 Website www.des.old.qov.au ABN 46 640 294 485 Queensland Government submission to the Joint Standing Committee on Foreign Affairs, Defence and Trade — Inquiry into the management of per- and polyfluoroalkyl substances (PFAS) contamination in and around Defence bases

Introduction The Queensland Government acknowledges that the legacy of PFAS contamination is a society level issue, given the use of these chemicals fora broad range of household and commercial purposes over many decades. It is incumbent on all levels of government to demonstrate to our communities that we are identifying potential risks associated with PFAS contamination and taking precautionary approaches to managing those risks.

The Queensland Government is aware of 15 Federally-operated activities in Queensland with some level of PFAS contamination. While investigations have shown that sites operated by the Department of Defence are the most polluted in terms of PFAS levels and plume size, there are other sites which fall under the Federal Government's responsibilities. These include sites where Airservices Australia (ASA) activities are conducted.

Queensland Government's approach to managing PFAS contamination For sites that fall within Queensland's jurisdiction, the Queensland Government has taken a proactive approach to reducing further releases of PFAS into the environment. As investigations have shown that the most dispersive form of PFAS contamination is through fluorinated firefighting foam, Queensland's environmental regulator — the Department of Environment and Science — has adopted a number of measures to reduce and respond to this form of contamination.

In 2016, Queensland became the first state to introduce a ban on firefighting foams containing PFOS and PFOA. The Environmental Management of Firefighting Foam Operational Policy ('the Policy') sets new standards for foam management in Queensland, and requires operators to transition to policy compliant foams by July 2019.

Queensland's transition phase of the Policy has included a series of seminars, surveys and industry education activities to canvass firefighting activities and stocks along Queensland's east coast, and provide operators with the information needed to transition to sustainable alternatives.

The Queensland Government has also adopted a proactive and risk-based approach to investigations and community engagement. While supporting open and transparent investigations, the Queensland Government expects that polluters and 'responsible entities' (including site owners and/or operators) will engage proactively with communities when there is any potential that they may be exposed to elevated levels of PFAS. It is expected that these entities will appropriately manage the risks associated with PFAS contamination and remediate sites where necessary.

Department of Defence The Queensland Government is aware of four in-depth and four preliminary PFAS investigations being undertaken by the Department of Defence in Queensland.

The four in-depth sites which form the basis of this submission are:

• Army Aviation Centre Oakey (Oakey) • Royal Australian Air Force Base Amberley (RAAF Amberley) • Royal Australian Air Force Base • Lavarack Barracks (Townsville)

1 While the Department of Defence sites are the most polluted sites by PFAS chemicals in Queensland, the Queensland Government notes that Defence has made significant improvements in the investigation and management of PFAS contamination in and around Defence facilities. Since the 2015-16 Senate Inquiry, the Department of Defence has demonstrated a willingness to conduct full, in-depth and proactive investigations to identify potential human and ecological exposure pathways and characterise health risks.

The Department of Defence has also made improvements in collaborating with stakeholders. Since the last Senate Inquiry, the Department of Defence has consulted with State and local government, as well as local interest groups, on the approach to investigating off-site contamination. In most circumstances where the Queensland Government has identified a cause for concern, the Department of Defence has accepted and acted upon recommendations made by Queensland's technical experts. This effort and willingness to collaborate has led to many significant findings, including the June 2018 identification of PFAS in biota in the Bremer River and Warrill Creek around RAAF Amberley.

Room for improvement While the Department of Defence has improved its approach to investigating PFAS contamination, there is room for improvement in its approach to proactive and timely communication of information about its investigations to local communities. This was evident in the recent case of RAAF Amberley, where high levels of PFAS were found in preliminary sampling of fish in the Bremer River and Warrill Creek in areas surrounding the airbase. After protracted negotiations with the Department of Defence the Queensland government made the decision to notify the community.

Airservices Australia The Queensland Government is aware of seven ASA sites in Queensland which are affected by PFAS contamination. These include:

• • • • Airport • • • Hamilton Island Airport

The Queensland Government considers that further and full investigations are required to determine the nature and extent of PFAS contamination at airports where ASA/firefighting training activities have occurred. The Queensland Government also expects that the findings of these investigations be communicated proactively to stakeholders. The Queensland Government is committed to working constructively with Federal agencies and regulators to manage the investigations of PFAS contamination.

National Guidelines — standards and legislation Since the 2015-16 Senate Inquiry there has been a number of nationally developed and adopted guidelines pertaining to PEAS contamination:

• Tolerable Daily Intake (Food Standards Australia New Zealand) • Health based guidance values for site investigations (Australian Department of Health)

2 • Intergovernmental Agreement on a National Framework for Responding to PFAS Contamination • PFAS National Environment Management Plan (Heads of EPAs Australia and New Zealand).

Where appropriate Queensland Government agencies have constructively contributed to the work of other state and federal agencies involved in developing the frameworks. These guidelines, while precautionary, have been used by both polluters and Government regulators to investigate PFAS contamination, assess associated risks and provide communities with advice. Since the implementation of the National Environment Management Plan in particular there has been a significant increase in the cohesiveness of investigations, as well as a better understanding from polluters of their basic obligations to assess risks.

Blood testing People who have been exposed to high levels of PFAS chemicals often want access to blood testing to see if they are affected. While it is important to know the diagnostic limitations of blood testing, it is the Queensland Government's experience that blood testing has the potential of reducing community anxiety. For this reason, the Queensland Government offered free voluntary blood testing to people inside the Svensson Heights investigation area of Bundaberg. All results were well within the acceptable background levels of PFAS in Australia. Because of this testing, the community had a tangible means of reassurance that they were not heavily affected.

It is therefore recommended that Federal Government agencies consider offering blood testing when people inside Federal investigation areas are or may have been exposed to PFAS above national draft criteria guidelines.

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