Draft Discussion Paper: Consistency in Applying Queensland's EMR Removal Framework This paper explores how uncertainty regarding the interaction between the EP Act, ASC NEPM, Auditor Handbook and DETSI guidance may contribute to inconsistent contaminated land outcomes. Using PFAS as a case study, it examines the role of statutory definitions, risk assessment and professional judgement, and argues that similar sites should not reach materially different outcomes solely becaus

Risk assessment is widely used to improve our understanding of contamination risks. But when risk assessment is used to support removal of land from Queensland's Environmental Management Register (EMR), who determines what level of residual risk is acceptable? The landowner, consultant, auditor or regulator? This infographic explores whether risk assessment reduces risk, or whether it can transfer professional and regulatory risk between parties where no clearly accepted path

There is growing confusion around the duty to notify provisions of Queensland’s Environmental Protection Act 1994, particularly in the context of contaminated land. This article explains what the Act actually requires, who holds primary responsibility for notification, and how the roles of landowners, suitably qualified persons and auditors fit together within the statutory framework.

The term “appropriately qualified person” (AQP) is increasingly being used in Queensland contaminated land guidance, replacing the long‑established concept of a suitably qualified person (SQP). While intended to provide flexibility, AQP is not defined in legislation or guidance and carries no minimum competency, professional membership or insurance requirements. This raises important questions about accountability, risk and client protection.

Unlocking value from past reports requires more than summarising old data. Under Queensland’s Environmental Protection Act and Auditor Handbook, verification is essential. Any third-party data used in a Contaminated Land Investigation Document (CLID) must be fully integrated and supported with evidence, ensuring compliance with NEPM processes. Past data isn’t enough—verified evidence is the key.

Contaminated land audits in Queensland aren’t standard consulting jobs—they’re statutory functions under the EP Act and Auditor Handbook. Scope is set by law, not client direction, and auditors must maintain independence. Standard PO terms often conflict with these obligations. The safest approach? Use auditor-specific terms that preserve compliance and professional integrity.