Feedback on the "Sepi-Leaks" - Wastewater Whistle Blower Day
Thankyou all for attending and I hope you all made it home safely.
There was a much larger and diverse audience than I expected and we covered a lot of the legal, technical and financial ground issues effecting onsite wastewater management issues in one day.
I am sorry there was little time for discussion until the last part of the day because most presentations had not been provided in advance as requested - still there was something to learn from all of them.
I must also apologise for not having time to formally thank speakers with gifts and applause in most situations but I was pretty overwhelmed with the issues and last minute changes that had to be made to the day.
Overall thought I think we achieved the best outcomes we could given the circumstances and I think the outdoor displays worked really well.
We had many sponsors pull out at the last minute because of work commitments.
Hopefully more can make it next time. The sponsors we did have attend were very much appreciated and although there were disputed details sometimes, I think they now understand more about the wider issues and the fact their industry will now be changing faster than ever before.
Hopefully they will all be able to improve their products and services enough to keep up with what is a very competitive market with many interstate and overseas players trying to take market share. Being there showed commitment and players prepared to stand by their product.
Most of western Victoria was well represented so the next onsite wastewater day we hold may well be in the North East or Gippsland and maybe more focussed on specific issues such as development of educational tools for plumbers, land owners, Environmental Health Officers and others in the wastewater industry.
I understand some parts were a little slow if you were an experienced wastewater practioner but it was important that parts of the audience with less familiarity were bought up to speed.
It certainly highlighted where the hot issues are and where more work needs to be done.
I urge you to harness your concerns and ideas and put them into positive comments or register and create your own discussion threads or comment on other peoples threads on the same topic so the debate can be continued, resolutions identified and efforts made to meet again if necessary to thrash out the final details at another event.
Thankyou again for attending, don't switch off your mind just yet, harness those afterthoughts, and follow the ongoing discussion threads on line if they interest you.
Ark Angel's Wrap up of the Sepi-Leaks Conference
Dear Callum EHO,
I hope all is well. I wish to thank you for inviting me to be one of the Key Note Speakers at the EHA 'Sepi-Leaks' conference at Halls Gap; and also to all those who worked tirelessly to make it happen. I am quite impressed by all the multitude of things that are going on in environmental health. The conference also gave me a chance to view this industry from the other side of the fence.
I was particularly impressed by Tim Wood's talk on the South Australian perspective. I totally agree with his approach to pressure trench dosing. As you well know I also design and recommend this type of trench distribution system, particularly as it is recommended for difficult soils in AS/NZS1547:2000. What I find interesting about Tim's approach however is that he is trying to construct the right system for his clients, yet he is struggling to compete with plumbers and EHO's who either don't understand, support or enforce this type of system. I know just how he feels. If EHO's are not going to enforce this approach, then perhaps there needs to be more land capability assessors like myself to help specify minimum construction standards for everyone in this regard. I thus get the impression that the technology is sound, however onsite systems have a poor performance and reputation, mostly due to poor assessments, enforcement and ongoing management regulations.
I am disappointed with Sarah West's plans for the new code of practice. She mentioned a number of things that showed a poor understanding of the technical issues involved. In addition to this, I get the impression that the proposed Code of Practice is becoming more like a fashion statement than a best practice management document. "If other States are using it, why not Victoria". The fact that the basic technical assessments bear little to no relationship to the soils and climate being assessed, or the fact that the industry is poorly managed both interstate and here in Victoria is completely ignored. It should be mentioned here that all these proposals and opinions may not necessarily be that of Sarah's, i.e. They are her advisers proposals and opinions. These include:
1. The equation that estimates the permeability of soils using the "static head" percolation test method can also be easily modified so that the "falling head" test method can be used. Consequently the use of either method should boil down to personal preferences only and not to that of the code of practice. However having said this, it is my view that the percolation test is no longer best practice, and should be done away with all together. The typical user of this expensive and time consuming test only uses it obtain a permeability snapshot of the soils in the base of the trench without considering the wider soil permeability issues, e.g. Less permeable underlying soils like shallow groundwater tables, shallow bedrock and the long-term detrimental effects of shallow reactive clay soils with poor structure, hard pans, etc. are typically overlooked.
Soils suitable for good drip irrigation performance are not even considered at all, yet their permeability profile is an important requirement for determining effluent application rates when used in combination with an annual water balance analysis. Consequently I prefer to use the textural and structural analysis method, and apply this to the entire soil profile down to 2m or more where possible. This is a far superior method for any self respecting land capability assessor.
2. Only using the water balance model for the peak winter month of June shows a complete lack of understanding for water balance assessment procedure. This is quite a complex modeling issue: basically the balancing storage capacity of the underlying soil is ignored in this method, and in my experience this type of assessment procedure will not allow anything to be installed in the wetter parts of the State, e.g. Gippsland. In preference to this method, I recommend the annual water balance procedure like that described in my paper for the conference. In this procedure the deep infiltration rate is set at a standard average of 2.0 mm/d or 730 mm/y, or less for all sites; as determined from field observations. The water balance assessment procedure is then used to determine the effluent application rate for the 90th %ile rainfall year, as is common practice for all engineering assessment of this nature. A proper deep soil profile analysis will then be used by the assessor to determine if the proposed effluent and deep infiltration rates are suitable or not. It should be emphasized here that salinity and nutrient based application rates should also be considered here for drip irrigation systems.
3. The use of standard trench length tables for soils of various permeability is no longer best practice. Such a practice ignores environmental influences on trench length, e.g. Climatic conditions, aspect, vegetation type, and deeper underlying soil conditions with poor permeability, etc. In my experience these influences can have quite a substantial impact on trench lengths, widths and separation distances. Instead of standard trench length tables, I would prefer to see more information on standard assessment procedures that best determine the size of effluent dispersal systems for nonstandard site and soil conditions that are typically found at all sites. In any event the code of practice should not exclude this superior first principals analysis approach.
4. It is proposed that LCA's are not compulsory (this is also the current situation). However this management proposal does not comply with Section 46 (anti monopoly) and Section 53 (non standard compliance) of the Trade Practices Act. It is my view and experience (based on the highly variable outcome of many LCA assessments) that all onsite sewage systems should be assessed, designed, constructed, checked and maintained by suitably qualified and experienced onsite professionals. This approach is also recommended by the US EPA as well. Anything else will result in a piss poor performance. If your looking to improve the way onsite systems are managed in this State, I recommend that the entire procedure of building and managing onsite sewage systems should be handed over to private professional onsite sewage builders who's role is equivalent to that of house builders; or to that of water authorities. At the moment this industry is too disjointed, there are not enough people who know what is going on from a technical and asset management perspective (I can say this because I have been in the public water industry which I can use as a comparison), and there is little to no incentive to improve this situation. Consequently this wholistic industry management proposal is what we should be aiming for.
I hope this information helps you sort out the beauty from the bullshit. We certainly all need to talk more about these issues. The Sepi-Leaks conference has been a good start. I strongly recommend that we should have more of this...
Your fellow Pooadorian
There are some locations where LCA's are not needed such as in consistant sand dunes where they are high enough above groundwater.
There is a real issue with quality of guidelines and quality of LCA's so I can understand some EHO's saying they get better results not asking for LCA's in some situations. EG on enormous farms - you have to consider the politics and risks sometimes.
The are real issues with quality of LCA's and the advice being given by some systems providers and installers. The majority of assessors are no longer considering primary treatment based systems because it involves harder work and management of risks. There are not many LCA's that are providing real value for money - most of the time a plumber and EHO's experience could make a better call but there are at least a few assessors trying to improve the industry. Making assessments compulsory might just generate a higher volume of dodgy assessments and still leave quality assessors without much work.
I think the generation of better guidelines is the go and addendums where there are shortfalls in EPA documentation. Using computer powerpoint aninmations to get across the complex concepts is also important - the fixed page diagrams just don't seem to be doing the trick and residents deserve to be more informed as well if they are going to make better informed decisions about the type of system and maintenance.
Handing it all over to water authorities sounds easy but I don't know that they necessarily want the risk, liability and backlog of workload defective guidelines, practices of the past and the disasters some dodgy operators in the industry have created. Most EHO's would not mind if somebody else took it on but clear legal, technical and financial planning issues need to be resolved or there will be no gains made and it would create a political nightmare.
We can't wait for legislation changes and interstate documents to arrive - there are systems out there that are starting to fail really badly and also some new solutions that offer some hope. Perhaps using some of these discussion threads will also help with raising awareness and development of legal, technical and financial solutions.
Dear Callum EHO,
Thanks for your reply. I will attempt to answer each issue that you raised as follows:
While there has been a history of leaving the assessment process up to EHO’s in the past, it is my contention that this should not be the case in the future. The reasons for this are as follows:
1. When compared to a properly trained and experienced soil science professional, EHO’s do not have the right technical training to carry out these assessments in a low risk manner that is acceptable and expected in today’s technically orientated society.
2. If EHO’s are doing their managerial job right they do not have enough time to carry out proper low risk assessments.
3. If EHO’s are using rule of thumb assessment procedures, or are stealing the assessment results carried out by a professional assessor on one site and then extrapolating the outcome to another site (legally called intellectual property theft) without a proper assessment shows a complete lack of understanding of not only the technical issues involved, but also of the social managerial issues and the adverse consequences involved for the performance of the industry as a whole.
The technical issues are as follows:
1. Soils are a highly variable 3-dimentional medium and can vary quite considerably in any dimension in permeability from one location to another. Hence there is a high risk involved in assuming that what is valid for one location is also valid for another location, especially as other factors such as sewage quality, evapotranspiration, and competing rainfall percolate also have a substantial influence on the outcome.
2. Unfortunately the LCA assessment tools recommended by the EPA to date do not properly treat soil as a 3-dimentional medium or show any understanding of how sewage quality, climate, plants and rainfall have an effect on the design outcome. For example, any mention of a traditional percolation testing procedure, or a tabulated trench length for a measured soil permeability, typically results in soil being treated as a uniform media and completely ignores all other environmental effects; which in my experience can have a substantial effect on the design outcome. Take the design of drip effluent dispersal systems on sandy soils for instance. In the past little or no consideration has been given to the requirements of nutrient and salt balanced irrigation systems. Yet these assessment procedures are necessary for these areas, just as much as any other area. When properly assessed by a qualified assessor the dispersal system in these areas will be sized in accordance with the nutrient and salinity concentration in the sewage (note this will vary between tank and public water supply systems), the dispersal area will be zoned in accordance with the salinity assessment; and the zones will be rotated on an annual basis in accordance with the nutrient balance assessment. This is not a simple process.
3. Many of the Certificates of Approval for public domain treatment systems have out of date and expensive to manage technology, e.g. sand filters can be designed to manage sewage influent of various qualities, and septic tanks can be designed to increase the average desluge time from 3 year to about 9 years, traditional trench systems are no longer the cheapest solution, etc. Where is a good onsite sewage technical expert when you need one to help better manage these inflexible systems?
The social managerial issues are as follows:
When the EPA (and/or its technical advisors) say that an LCA is not required for all assessments they clearly do not understand the technical or social issues involved. The way I see this policy is that the EPA is abandoning its due diligence responsibility of good industry management and passing it directly onto EHO’s to manage without considering the consequences. While this action my keep the political peace and bolster the Christmas bonuses and egos of the EPA and EHO’s involved, it does little to protect the input by those most qualified (e.g. assessors) to ensure that the industry performs at the highest possible standards. In fact, one can claim that there are no recognised Standards for this industry with this policy in place. In my experience many EHO’s abandon their compliance LCA checking role and virtually monopolise the land capability assessment process by using rule of thumb assessment procedures, or steal the assessment results given to them by professional qualified assessors for a local site and extrapolate this to another nearby site.
Firstly let me state that there is no recognised standard for rule of thumb assessment procedures, consequently if something goes wrong, then the EHO is wholly and solely to blame. As a consequence, this type of LCA also cannot claim to be legally compliant with any recognised standard under Section 53 of the trade practices act. An appropriate understanding of the consequences of this this section of the trade practices act will result in all EHOs having an attitude that all products that are sold on the market comply with an appropriate standard. Whether they are in a high risk township area or a low risk rural area, it does not matter, all systems need to be assessed and designed to the adopted standards to ensure that they work in a safe and proper manner. Anything less is unacceptable.
Secondly a monopoly scam of this nature is against the anti-monopoly, Section 46 of the trade practices act. I will say more about this later on. Thirdly, when LCA information is given to EHO’s in confidence by a professional assessor, and this information is then used to diminish the commercial role of that assessor, then this is called intellectual property theft, and this is illegal.
The social outcome of this EHO monopoly activity is that the role that professional land capability assessors play is an ever diminishing one. In this situation, instead of the EHO working for the community, they are working for themself (e.g. for their improved social standing and ego) and certainly not in the community’s best interests. As a result of this misplaced policy, the majority of good quality assessors have voted with their feet and gone elsewhere. Consequently the industry is left with poorly trained assessors and assessments, and indeed poor quality, high risk, and expensive onsite systems. Incentives for improvements are few and far between. In addition to this the knowledge and standards of the whole industry have also suffered. For example, not one practicing land capability assessor is on the Standards Committee for AS/NZS1547, yet the whole standard is virtually about LCA’s.
Looking to the Future
Just about everything that EHO’s know about this industry is based on past poor quality standards and managerial practices. However in my experience, there are better assessment and design technologies for standard onsite sewerage systems, and there are better ways of managing this industry.
Some States in the USA have been down this path before. As a result they have implemented a compulsory training course and experience period for assessors, plumbers and EHO’s alike. I strongly urge EHO’s to support a scheme of this nature for Victoria.
Hi Ark Angel,
Sorry about the delays in responding. Once again, I think the challenge is out to the best of EHO's, the best Plumbers and the best Assessors to explain the value of good land capability assessments in appropriate situations.
When the public is given appropriate information then they tend to make appropriate decisions. The current situation is not ideal but making land capability assessments compulsory could have created more problems than what it resolved in some locations because of problems with the assessments and the recommended technologies in many cases. The same issue applies to making water sampling compulsory every year for secondary treatment systems. To enforce this now when reliable alternatives either don't exist, are hard to identify or are not affordable would be counter productive. When we ask owners to switch from sprinklers to subsurface drippers, will we ask for another LCA? Will we be confident that the replacement system is also going to get to a secondary treatment?
As hardship begins to spread through communities then every component and every cost associated with wastewater management gets examined. The septic tank system is often the last component of a new house to be installed and many owners have already blown their budget. There are some residents that can not afford best practice and only have limited space. EHO's sometimes know enough to work with local plumbers to get the best we can out of the limited funds and space that exist in some situations. It can be legally tricky but sometimes it is better than nothing and very few people are voluntarily getting systems fixed up anyway because the industry has such a bad reputation. In some reliable consistent soils then the LCA is sometimes something that can go and the money put into infrastructure. I think that every component that is asked for has to have its advantages and disadvantages explained and where possible proven. Pressure distribution might be an improvement but how much does it extend system life, change the microbiology etc. Can it be reliably added later on? For a long time there were no assessors prepared to accept anything less than secondary treatment because many had lost the skills or insurance or capacity to continue to install basic septic tank systems when the property was surrounded with many neighbouring systems that appear to be working perfectly.
Lets focus on the common objectives here and build on our strengths. If an assessor can prove a design will work for a primary treatment system then this alternative could be very attractive to residents and save them a fortune in long term operation costs. So much money is saved that residents may well be able to afford the other valuable add ons such as pressure distribution if they are proven but they have a right to know all the choices.
Good assessments do effect the future decisions of EHO's and the Town Land Capability Assessments you have provided have greatly guided me as an EHO, positively influenced other assessors and helped plumbers and owners to make more informed decisions.
I hope we can continue to build on the progress we made this year and have another workshop next year somewhere in Gippsland.
Dear Callum EHO,
With regards to using pumped effluent dispersal systems for trenches there are a number of things to consider other than longevity of the trench system. These include:
1. Improved trench soil treatment quality, consequently less potential contamination of valuable groundwater resources.
2. The proposed trench system are loaded that the standard design irrigation rate and therefore both the EHO and designer are legally covered if something goes wrong; provided everything else is in order.
3. As the trenches are loaded at the standard design irrigation rate, they are less likely to fail in extreme effluent surcharge and wet weather events.
4. The improved longevity of the trench system also means that the risk of failure and threat to life and the environment is less.
When an Environmental Health Officer consults with a plumber to design an onsite sewage system without the proper advice of a qualified assessor, the obvious questions to ask are:
1. To what standard are the EHO’s designing the proposed system to, and who is responsible if something goes wrong? If EHO’s are regularly not designing to a standard procedure, then there is a higher chance that the proposed systems will fail (NB: rule of thumb or experience design procedures are not a standard design procedure). The EHO’s in this circumstance then carry all the risk and responsibility. However if EHO’s encourage an appropriately qualified assessor to conduct the assessment in accordance with standard design procedures, then not only will the system comply with design standards, the risk of failure will be less; and both the EHO and assessor are covered if in the event something still goes wrong. Note that Standard design procedures do not offer a 100% guarantee that the system will not fail. They will allow for a small percentage failure rate that is acceptable to the community.
2. If you are not considering all the appropriate design parameters that a qualified assessor can offer, how do you know if you have got the right system for the job or in deed that the site is suitable at all for the installation of an onsite system? I encourage EHO’s to consider that the system with the cheapest up front cost may not always offer the client and the community the cheapest long term management cost, particularly if the cheapest system has a shorter than expected life and has to be replaced in short measure, or is not suitable at all.
3. How do you know if the proposed system is not failing because it is relying on generous factors of safety in the household occupancy rate or the effluent production rate, and that when the system is loaded at the maximum expected design occupancy rate that it will not fail?
4. How do you know that a properly qualified and experienced assessor cannot offer a cheaper system, or a better environmentally sustainable system? For example, for nonreactive clay soils, and for Category 3-6 soil profiles I can already design a cheaper trench system than any EHO who uses a rule of thumb assessment procedure.
5. If the proper job of EHO’s in this regard, like that of building inspectors is to offer an independent quality assurance service (e.g. checking for regulatory compliance and performance), however if Council EHO’s have set themselves up as a design consulting service that competes directly with private assessment business in the community, how do we know that EHO’s can offer a credible and independent service that has no conflict of interest? In fact how can we trust EHO’s to carry out their duties when it comes to assessing themselves? How does the EHO know that they are offering the right type of qualified advice? What happens when the EHO is faced with a system that has failed that they offered consulting advice on, or the Council/EHO has a policy that is not in the best interests of the stakeholder and everything hinges on the outcome of the LCA? When EHO’s abuse their duties like this, how credible are they, can the community trust them at all?
These are just some of the questions that all Council EHO, LCA consultants should be asking themselves.
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