The NSW site auditor scheme is administered by the Environment Protection Authority (EPA) under Part 4 of the Contaminated Land Management Act 1997 (CLM Act). The scheme provides a pool of accredited 'site auditors' who can be engaged to review investigation, remediation and validation work conducted by contaminated land consultants.
The aim of the scheme is to ensure the protection of the environment and human health through proper management of contaminated land, particularly during changes in land use. The scheme improves community access to competent technical advice on the investigation and remediation of contaminated land, and provides increased certainty in the 'sign-off' of contaminated land assessments and remediation.
The assessment and remediation of contaminated sites is technically difficult because of the complex behaviour of chemicals in the environment and their myriad effects on ecosystems and human health. Expert review of a consultant's work helps to determine the reliance that can be placed on their assessment and/or remediation.
Role of site auditors
Accredited site auditors can be engaged to independently review reports on assessment, remediation and validation actions to ensure that the methodology used by consultants and their interpretation of data are consistent with current EPA regulations and guidelines.
Under section 4 of the CLM Act, a site audit is defined as a review
- that relates to management, carried out in respect of the actual or possible contamination of land and
- that is conducted for the purpose of determining any one of the following matters
- the nature and extent of any contamination of the land
- the nature and extent of any management of actual or possible contamination of the land
- whether the land is suitable for any specified use or range of uses
- what management remains necessary before the land is suitable for any specified use or range of uses
- the suitability and appropriateness of a plan of management, a long-term management plan, or a voluntary management proposal.
Although the site audit is a separate process from the investigation and remediation, it is recommended that the site auditor is engaged at the beginning of the investigation and/or remediation project. Communication between the consultant and the site auditor from an early stage should ensure the consultant does sufficient work to satisfy the site auditor and therefore minimise potential delays for the site owner or developer.
For statutory site audits, a site auditor must notify the EPA in writing, using the site audit notification form (DOCX 45KB). This form was updated in October 2017.
Site audit statement and report
The outcomes of a site audit are
- a site audit statement which outlines the conclusions of a site audit - see Site Audit Statement form (DOCX 52KB). This form was updated in October 2017.
- an accompanying site audit report that summarises the information reviewed by the auditor and provides the basis for the conclusions contained in the site audit statement
Site auditing and the planning process
The site auditor scheme has an important role in supporting decision-making by planning authorities. State Environmental Planning Policy 55 (SEPP55) requires planning authorities to consider the potential for contamination at a site (and adjacent sites) prior to planning decisions being made. This has particular relevance, for instance, where land with a known or suspected history of potentially contaminating industrial or commercial activities is proposed to be redeveloped for a more 'sensitive' purpose, such as residential use. This consideration by planning authorities requires information about the nature and extent of any potential contamination.
Site auditors are able to provide increased certainty to planning authorities about the nature and extent of contamination and the suitability of a site for a specified use.
Managing Land Contamination: Planning Guidelines - SEPP55 - Remediation of Land (Department of Urban Affairs and Planning and EPA 1998) specifies that planning authorities may require an accredited site auditor to be engaged when the planning authority
- believes on reasonable grounds that the information provided by the proponent is incomplete or incorrect
- wishes to verify that the information provided by the proponent adheres to appropriate standards, procedures and guidelines or
- does not have the internal resources to conduct its own technical review
Where requested, site auditors can also provide conclusions about the suitability of a site for a proposed land use.
Guidelines for the NSW Site Auditor Scheme
Guidelines for the NSW Site Auditor Scheme (PDF 999KB) describes the obligations of site auditors in conducting a site audit and the administrative framework supporting the site auditor scheme.
The guidelines apply to individuals seeking accreditation as site auditors in NSW and accredited site auditors undertaking site audits in NSW. They may also be of use to other people with an interest in contaminated sites, such as contaminated land consultants and local councils, as guidance on what is expected of site auditors when engaging them or reviewing their work.
Accreditation of site auditors
As per the Contaminated Land Management (Adjustable Amounts) Notice 2018 (PDF 27KB) from 1 September 2018, the application fee for accreditation as a site auditor is $1,129 and the accreditation fee for a period one year or less is $7,892.
Applications for accreditation as a site auditor are not currently being accepted. The EPA anticipates inviting applications for accreditation under the CLM Act at least once every three years. The application requirements are based on Schedule B9 of the National Environment Protection (Assessment of Site Contamination) Measure 1999 and the requirements will be specified in the application form. The EPA will advertise when applications are being accepted and the application form will be available on the EPA website. Until then an example application form is available (PDF 271KB).
Mutual recognition of site auditors
Auditors registered/accredited in another State who wish to be accredited in NSW under the mutual recognition principle must lodge a written notice with the EPA.
If you seek accreditation as a site auditor in NSW under the CLM Act in accordance with the Mutual Recognition Act 1992 (Cth) please complete the application notice (DOC 107KB) and declaration form (DOC 51KB).