Unlocking Value from Past Reports - Turning Past Data into Verified Evidence
- Christian Atkinson
- 5 days ago
- 2 min read
When preparing a Contaminated Land Investigation Document (CLID) in Queensland, it’s tempting to rely on previous consultants’ reports to save time and effort. However, both the Environmental Protection Act 1994 (Qld) and the Queensland Auditor Handbook for Contaminated Land (Module 6) set a high bar for the use of third-party data.
Here’s why, and what you need to do instead.
Verification Is Everything
The core issue is verification. Any data or findings from previous consultants’ reports cannot simply be adopted or referenced in your CLID without proper verification. The law requires that verification must be possible based solely on the information provided in the CLID itself — so that the SQP, auditor, regulator, or any reader can assess its reliability.
What Are the Requirements?
The CLID must be a stand-alone document. If a suitably qualified person (SQP) uses data from previous reports, they must clearly state how they have verified its reliability and representativeness (for example, by stepping through the NEPM process and showing compliance). The SQP must take full responsibility for its use.
All field investigations supporting your conclusions must be fully presented. SQPs need to include all necessary information to support and verify past data, as this information becomes part of the CLID and must meet its content requirements. The same level of data and documentation is required for every piece of evidence used to support the conclusions of the CLID, regardless of whether it was collected as part of a previous or current sampling program.
If the SQP relies on another person’s expertise or opinion (such as for site history or preliminary assessment), a support SQP declaration must be provided.
What About Government Data and Publications?
Published third-party data (such as guidelines or databases) that can be independently checked is generally excepted from this requirement.
Summaries Are Not Enough
Summarising past reports is not sufficient. The work must be fully integrated into the CLID, along with all supporting information, as required by the NEPM investigation process. For example, if the SQP wishes to rely on past sampling and analysis data, they need to verify and document all the steps that were taken in the original work—site history, DQOs, SAQP, sampling methods, QA/QC, and so on.
The Bottom Line
As an SQP, if you want your CLID to be accepted by the auditor and regulator, you must do more than reference or summarise previous work. You must demonstrate, in detail, how you have verified and integrated that data, and you must take responsibility for its accuracy and relevance.
Need help navigating the requirements? Get in touch with Grounded Environmental for expert guidance on preparing compliant CLIDs and environmental reports.
Christian Atkinson is a contaminated land auditor and a suitably qualified person for contaminated land assessment in Queensland with more than 30 years of experience. Any discussion is general 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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