The Victorian Farmers Federation is the peak body representing Victorian agriculture. VFF has been on the record regarding our concerns in relation to lack of regulatory knowledge and considerations in relation to agriculture and the GED and the appropriateness of the EPA in relation to human health.
Even though some aspects of the 1970 Act applied to agriculture – such as organic matter as industrial waste, agriculture was applying the circular economy approach to what we know is a key material for plant growth and soil health.
The guidelines are not suited for agriculture. They are not fit for purpose or clear in regulatory intent.
It is acknowledged that agriculture is a low-risk activity, but there is not clear guidance on when it ‘notifiable’. The guidelines seem to have been written with consultants in mind who should already understand the system. The document is not suitable for the target audience.
Agriculture should be removed from these guidelines and a specific guidance note be prepared in conjunction with industry.
The existing document must be reviewed to remove ‘farming’ from a contaminating process. Every aspect of every farm is not a contaminating activity. In fact, these are rare. Certain practices may, in certain circumstances, lead to contamination. They should be specified.
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