Contaminated Land Auditor - How do I engage one?

Updated 22 September 2025

Contaminated land auditors are independent professionals approved under Queensland’s Environmental Protection Act to evaluate and certify contaminated land investigation documents (CLIDs) prepared by suitably qualified persons (SQPs). They perform a statutory function for the community and DETSI (the Department of Environment, Tourism, Science and Innovation), but they are not government employees.

In Queensland, all CLIDs submitted to the department must be certified by an approved auditor. That includes Site Investigation Reports (SIRs), Validation Reports (VRs) and draft Site Management Plans (SMPs). Because the auditor confirms the document meets the regulatory content requirements (including a clear statement of uses for which the land is suitable), it’s best to engage the auditor at the start of the project so expectations are clear and re‑work is avoided.

Who engages and pays the auditor? Typically the landowner, occupier or developer engages and pays the auditor on a user‑pays basis. The critical requirement is independence: the auditor must not audit their own work, and must not have any direct or indirect financial interest in the matter beyond the fee for their service. That’s the legal test for conflicts of interest—rather than who issues the purchase order.

Auditor vs SQP—what’s the difference? The SQP investigates the land and prepares the CLID. The auditor independently evaluates that work against the EP Act, the Auditor’s Handbook and the ASC NEPM, and certifies when the requirements are met. Auditors can advise on standards and compliance expectations, but they don’t direct the investigation or undertake the SQP role on the same project.

Terms of engagement. Standard consultant subcontract Ts&Cs (e.g., client‑set scope, “fitness‑for‑purpose” warranties, unilateral termination for convenience that could truncate the statutory function) can cut across an auditor’s obligations. Use auditor‑specific terms that preserve independence and allow the statutory function to be completed properly under the Code of professional conduct.

Changing auditors or stopping an audit. If you need to change auditors or an audit won’t proceed, the auditor must notify DETSI using the Auditor notification form (ESR/2016/2148). The complaints process is only for alleged misconduct—not a prerequisite to end a normal engagement. This approach avoids “auditor‑shopping” while allowing legitimate changes.

#ContaminationSimplified

References

Engaging a contaminated land auditor

Queensland auditor handbook for contaminated land

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Christian Atkinson is an approved contaminated land auditor in Queensland with more than 25 years of experience. Any discussion is general in nature and does not consider your specific circumstances. It should not be taken as legal or financial advice. If you are considering acting on any matters discussed, you should seek advice from qualified and experienced professionals.