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.

Consultants working in contaminated land assessment must balance good intentions with professional responsibility. Mixed fill sites pose high uncertainty, and shortcutting guidelines can mislead landowners and increase risk. Your role is to provide clear, evidence-based advice so landowners can make informed decisions. The risk, responsibility, and reward remain with them—your fee reflects your own boundaries.

In Queensland, the movement of clean soil between lots within a development footprint raises a key regulatory question: must it always be treated as “waste” under the WRR Act? This post explores the intersection of the Waste and Contaminated Land frameworks, clarifies when soil becomes waste or contaminated, and discusses lawful pathways for reuse without triggering levy obligations.