When completing a contaminated land investigation, you may need to use data or reports written by someone else or rely on past work your company completed. What are the Government’s requirements when using and relying on past or third-party data in contaminated land investigation documents (CLID) and how are they best addressed?
The following requirements come from the Department of Environment and Science (DES) Queensland auditor handbook for contaminated land: Module 6: Content requirements for contaminated land investigation documents, certifications and audit reports, and provide the primary framework for using past and third-party data:
When completing a contaminated land investigation for the Queensland Government, the Government requires that one suitably qualified person (SQP) lead the investigation and take responsibility for preparing the site suitability statement and making the declaration about it.
The CLID must be a stand-alone document and must not rely on cross-referencing to any other document not supplied as part of the CLID.
Practically, what does this mean? The best way to look at this is with some examples in the following table.
Key takeaways for SQPs:
The lead SQP is responsible for the investigation, the CLID content, and the resulting site suitability statement. You cannot defer this responsibility to past investigators or other parties. Support SQPs can be used to fill skill and experience gaps. Support SQP declarations are required.
Include any information you have used to form your opinion about the condition of the land.
Do not include replaced, replicated, superseded, or irrelevant information in a CLID.
Include statements in the CLID and cover notes on appended reports stating:
The specific sections of appended work that have been used and relied upon.
The purpose of the use of the appended data.
The completeness of the data/data gaps.
The representativeness of the data.
The suitability of the work for the use.
Are the requirements different for reports not prepared for statutory decisions? These requirements are considered best practice in Queensland.
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 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.
Comments