Proposed changes to Trade Waste Acceptance Criteria (OHS)
We are improving the way we manage trade waste and are proposing some new changes to 21 common trade waste parameters that relate to occupational health and safety (OHS).
We have been seeking trade waste customer feedback on the proposed changes, which are being considered to ensure the health and safety of our workers who maintain our sewerage system.
Update - July 2017
In January and February 2017, we consulted with you regarding the submission we prepared in co-operation with City West Water, South East Water and Melbourne Water to the Essential Services Commission (ESC), to make changes to trade waste acceptance criteria with respect to occupational health and safety (OHS) limits for 21 parameters.
The result of the consultation was that overall customer feedback was positive and the reason why the changes were being made was understood.
Why the changes?
Some trade waste compounds pose a health and safety risk to workers who maintain our sewerage system. A water industry working group (Yarra Valley Water, South East Water, City West Water and Melbourne Water) has been reviewing the occupational health and safety (OH&S) methodology used to determine health risks associated with exposure to particular trade waste components.
This review has led to the development of a new risk assessment methodology resulting in proposed changes to Acceptance Criteria (limits) for 21 common trade waste parameters.
How was the review done?
Along with the water industry working group, a toxicology consultant conducted an independent review of risk assessment methods. The industry working group with the assistance of an occupational hygienist then evaluated the outcomes of the consultant’s findings and refined the risk assessment process.
What do the changes involve?
The new assessment methodology consists of a tool that calculates the OH&S impact of a trade waste contaminant. It uses occupational exposure scenarios across the career of a sewer worker exposed daily to trade waste effluent measured against known exposure standards for three routes of exposure: inhalation, skin absorption and ingestion. The tool then informs two tiers of assessment.
The first tier was deemed to be a safe level for an immediate granting of C-SAC (Customer-Specific Acceptance Criteria). The second tier would require a case-by-case assessment using current methodology. The industry working group is streamlining the process further by seeking to incorporate the tier one limits for the 21 parameters in the trade waste acceptance criteria.
To avoid non-compliance, Customer-Specific Acceptance Criteria (C-SAC) for each non-compliant contaminant must be developed using a risk-based approach at the cost of the customer and retail water company.
What are the benefits of these changes?
The benefits include:
- Reduced administrative burden for retail water companies, Melbourne Water and trade waste customers.
- Lower cost to trade waste customers in avoiding C-SAC application fees every three years.
When will these changes happen?
For these changes to take effect, the Essential Services Commission (ESC) requires a customer impact assessment to be completed, based on customer consultation and feedback as part of the submission to change the acceptance criteria.
We submitted our customer impact assessment to the ESC in June 2017, and the ESC has advised us that they will not make a decision until September 2017.
Depending on the timing of the decision, the changes may not come into effect until the end of September or October 2017. We will provide all customers with an update once we receive the ESC’s decision.
Additionally, we have identified a requirement to further investigate the impact of the proposed concentration limits for two of these parameters (Fluoride and Malathion) on Melbourne Water’s metropolitan sewage treatment plants at Carrum and Werribee. We’ve therefore withdrawn Fluoride and Malathion from the current acceptance criteria change submission to the ESC, with likely inclusion in limit change submissions in the future.