Position statement

As Victoria’s independent environmental regulator, EPA has a key role to play in protecting the community from the potential health impacts of pollution and waste. This is reflected in the works approval system, where EPA considers a project’s potential impact on the environment and human health before granting or withholding permission for it to go ahead.

 Works approval application guideline (publication 1658) outlines what types of information we generally require to assess a proposal’s health impacts. Sometimes, however, we may also require a human health risk assessment (HHRA).

This position statement outlines when EPA may use its discretionary powers to require works approval applicants to submit a HHRA or other relevant human health assessment documents. Our use of these powers needs to strike a balance between:

• protecting human health
• the potential regulatory challenges on works approval applicants
• the potential for requests for HHRAs by third parties, and
• transparency and procedural fairness.
  

EPA will consider matters such as those below in determining whether a HHRA or other documents may be required to accompany a works approval application:

• there has been a failure to meet the requirements of Victorian policy
• an initial assessment shows that adopted threshold policy or guideline values have been exceeded
• ‘predicted GLCs' [ground level concentrations] are above the design criteria identified in SEPP (Air Quality Management)’ (s 8.3.2 of publication 1658 )
• predicted emissions or wastes from a proposal include one or more key pollutant(s) that are not listed within the current Victorian policy framework and relevant alternative standards have not been identified
• current and robust scientific literature indicates a causal relationship between the proposed activity and a measurable health impact in the community
• the proposal involves the release of multiple chemicals with the potential for significant cumulative (additive or synergistic) health effects in the exposed community
• independent expert advice  sought by EPA highlights potential health effects and/or recommends that a HHRA be undertaken
• submissions received (including those in any s20B community conference report recommendations) have identified potential health impacts which justify more consideration and assessment, and
• EPA has determined that a HHRA that has previously been undertaken requires updating or review.
  

While a request for a HHRA would usually occur at the pre-application and pre-acceptance stages, it can also come during EPA’s technical assessment of an application.

Any HHRA that accompanies a works approval application must be prepared in accordance with this document: Environmental Health Risk Assessment Guidelines for assessing human health risks from environmental hazards.