In Queensland you can do a contaminated land assessment without engaging an auditor, but if you want a statutory decision about your land parcel, such as removing it from the Environmental Management Register (EMR), then you will need the services of a certified contaminated land auditor and they should be engaged from the beginning.
Just as you wouldn't build a house and then get the building certifier in when you're finished, engaging a contaminated land auditor part way through, or at the end of the investigation, is a risky business. In an earlier post about how the assessment and audit process works, we laid out the sequence of events in a typical contaminated land assessment and certification.
Besides fulfilling the certification requirements on behalf of the Queensland Government, which requires review and inspection at all stages of the assessment process, contaminated land auditors are experienced professionals who can assist the smooth running of your project and the avoidance of common pitfalls. Auditors engaged at the commencement of the assessment process can assist in identifying:
Issues relating to proposed development scenarios for the land and allowable uses
Issues relating to realignment of lot boundaries, subdivision and lot amalgamation
Legislated requirements relating to contaminated land assessment and the most efficient pathway through the statutory process
Gaps and shortfalls in the proposed assessment
Alternative outcomes for the land if remedial action is difficult
Legislated notification requirements to ensure you stay on the right side of the regulator
Common issues associated with the activities that have previously occurred on land
Engaging an auditor late in the process can lead to additional inspections, possible re-work, additional reporting, and in extreme cases, recommencement of assessment works or a refusal to certify. Generally, there is a minor upfront cost to engaging an auditor at commencement and this engagement does not commit you to any particular course of action or increase your statutory notification requirements.
Most experienced consultants will advise you to engage an auditor as soon as possible in the process, as they are aware of the benefits of a second pair of eyes and the pitfalls of leaving it too late in the process. Those that don't might not be your best choice. There is no substitute for experience.
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Christian Atkinson is a contaminated land auditor and a suitably qualified person for contaminated land assessment in Queensland with more than 25 years of experience. Any discussion is general in nature and does not consider your specific circumstances. If you are considering acting on any matters discussed, you should seek advice from qualified and experienced professionals.
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