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Environmental Studies: Asbestos Management Report

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Updated: May 28th, 2020


Site History

Port Kembla is a blend of urban and coastal settings with extensive industrial land use forming a central hub with several historical buildings and heritage sites (Wollongong City Council 2008).

Because of the historical changes in the road patterns, limited and declining job opportunities, and competition from the neighboring Warrawong, Port Kembla had experienced a significant decline as a commercial and industrial center until the government decided to reinvigorate the Port.

The Port, created in 1883 had its growth initiated by a rail connection to the state rail network to enhance the transportation of coal from the area. In 1898, Port Kembla Habour act was passed aimed at creating the outer Habour. Construction work which resumed in 1900 covering 500 acres of Habour with the inner Habour dredging, which commenced1950 and commissioned in 1960 (Wollongong City Council 2008).

The Port is situated in the Illawarra region. In the construction process, different materials were used with different health and environmental implications. In the historical context, the land was reclaimed with a significant presence of land pollutants in the soil transported by ship to Port Kembla aimed for use in the outer Habour construction work.

Asbestos was one such material used extensively for construction work in different construction products in the 1980s (Lowry 2002). Studies initiated because of the implementation of the Contaminated Sites Act 2003 (CS Act) demonstrated a significant health impact on the people from asbestos poisoning.

To address the resulting environmental and health implications, the Environmental Protection Authority (EPA), Lend Lease, Port Minister and Kembla Port Corporation assured Kembla residents that the movement of soil to Port Kembla could be safe (Langford & Paver 2012, pp. 2).

It was necessary to conduct tests for asbestos because prior tests to the shipment of soil by Lend Lease had indicated the absence of asbestos, with the assurance the soil could not present any problem from Barangaroo to Port Kembla. EPA used tests information by Lend Lease to approve the movement of soil.

The discrepancy associated with the test procedure on soil samples for asbestos conducted by Lend Lease raised questions because of the discovery of asbestos in soils samples at Port Kembla (New South Wales Council 2011).

The need to conduct further tests were contained in an article by the Illawara Mercury report which reported a halt to the shipment of soil from the Sydney Barangaroo site to Port Kembla because of the discovery of asbestos in the soils, despite the previous assurance that no asbestos could be contained in the soil (Health Asbestos Regulations 1992).

The studies and suspicion based on physical observation of the materials and being moved in the sight at the Port Kembla reinforced the need to conduct an in-depth analysis of the samples to confirm the fears of the presence of asbestos. The typical step included an identification of asbestos based on observations before the laboratory process was started (Australian Standard AS4964 2004).


Asbestos is a naturally occurring mineral fiber constituted in six different fibrous groups including “amosite, chrysotile, crocidolite, and the fibrous varieties of tremolite, actinolite, and anthophyllite” (Oberta 2005). Because of Asbestos’s heat resisting strong flexible characteristics, asbestos has been used intensively in the building industry and manufacturing of building materials.

Continued exposure of asbestos wears it into the environment as small particles that remain in the soil remain unchanged for a significant period with the potential of asbestos poisoning (Perry 2004). The potential asbestos poisoning impact varies by fiber type, with different poisoning implications not covered in this section.

Example is asbestos poisoning related to mesothelioma in humans caused by asbestos fibres measuring 0.1 μm and 5 μm ((Australian Standard 2004). Sources of asbestos poisoning because of environmental exposure provide further implications of mesothelioma poisoning.

In general exposure to any cohort of asbestos is highly harmful to human health as it causes numerous diseases like lung cancer, asbestosis, and mesothelioma (Australian Standard 2004).

The potential to poison the local residents of Port Kembla the regulations according to Road and Rail Transport) Regulation 2009 and requirements in handling asbestos and other poisonous materials provided the rationale to examine the presence of asbestos in soil being transported from Bangaroo to Port Kembla (Safe Work Australia 2011).

Tests on bulk samples from the site based on instructions to collect appropriate samples to obtain meaningful data based program provided the basis for the study.

Preliminary Site Investigation

To confirm the presence of asbestos in the soil, preliminary investigations based on observing the site for the physical properties of asbestos were conducted. That was in addition to conducting physical examination of the materials being loaded and unloaded in accordance with the Guidelines for the Assessment, Remediation and Management of Asbestos-Contaminated Sites in Western Australia (2009).

Evidence gathered at the site could lead to detailed investigations based on the case study where a close observation revealed the presence of industrial waste containing fibro’, pipe lagging and fiberglass all mixed with the earth, that compelled the sanctioning of a halt in the movement of the industrial waste based on the POEO Act against illegal dumping (Australian Standard, 2004).

The process was initiated and executed according to the Model Work Health and Safety Bill ,based on subsection (1) (a) of the Model Work Health and Safety Bill to safeguard employee health engaged in the movement of the soil suspected to contain asbestos, and the Environment and Protection Authority (EPA).

Toward that end, a review meeting was convened with the attendees from all parties engaged in the movement of the earth and other stakeholders (Swartjes &Tromp 2008). The results from the meeting confirmed the need for a detailed site investigation to determine and confirm the suspicion of the presence of asbestos in the shipment.

Detailed Site Investigation

The Australian Government regulations contained in the Australian Government Australian Government (2012) in line with the World Health Organization (WHO) provide legal requirements and education awareness, transportation and storage of asbestos.

That was in accordance with the Protection of the Environment Operations Act 1997(POEO act) for the transportation of asbestos and the Contaminated Land Management Act 1997 (Oberta 2005; EnHealth Council 2005).

The presence of asbestos occurring as parallel fibres, fibres with curvatures, fibres with splayed ends, and individual fibres with matted ends facilitated the study.

The use of light microscopic methods using Phase contrast microscopy (PCM) to identify the presence and asbestos exposure levels used diameter of 5 μm in length and >0.25 μm was appropriate (Oberta 2005). Asbestos existing as bonded material with special reference to bulk samples were suspected to occur in dust matrices.


The approach included preparations based on the code of practice of the WHS Act on the appropriate removal of asbestos from the site requiring (Australian Standard AS4964 2004).

The approach required appropriate protection gear to minimize risks and eliminate airborne asbestos according to the specific duties embodied in WHS Act and WHS Regulations prior to identifying hazards at the site and mitigation for the hazards and the Occupational Health and Safety Regulation 2001 (Australian Standard AS4964 2004).

That is in addition to barricading the site, and use of the appropriate tools for the collection of soil from the site in accordance with the regulations governing the removal of asbestos (Australian Standard AS4964 2004). The entire approach used to obtain bulk samples included categorizing the samples needed into homogeneous and non-homogeneous classes.

Process Description

Instructions to the contracted Laboratory

Instructions to identify the type of asbestos fibre likely to be present in the soil and the type of products present provided the basis for obtaining meaningful data and appropriate sample (Oberta 2005; Australian Standard AS4964 2004). The contracted laboratory could have to identify the samples and classify them into homogeneous and non-homogeneous bulk samples, and conduct detailed assessment of the samples.

Sample treatments using diagnostic methods ensured use of the right samples in the laboratory (EnHealth Council 2005). Both the PLM and DS techniques could qualify for use with each appropriate for specific materials according to the EPA (Oberta 2005).

The contracted laboratory should identify the type of asbestos in the soils, the degree and nature of exposure to the soil, and recommend on the most appropriate method of mitigating the risks associate3.d with asbestos exposure to the environment.

Methods and measurements

Program for representative samples

Table 1

Initial Homogenous and non-homogenous bulk samples
Homogenous Non-Homogeneous
Use of eyes and a low power stereo-microscope to identify and record any separate layers and their nature Ensure the sample is spread out to a thickness layer no more than 3 mm to 5 mm, and then examine the sample closely.
Identify the sub-samples and ensure each sub-sample is taken from each layer Locate the fibrous material in the sample using low and high powered stereo-microscopic.
Examine for the evidence of fibres using low power stereo-microscope and ensure the fibre clumps are removed. Extract fibrous materials from the sample to enable DS and PLM identification to be possible on the sample. It was crucial to note that the possibility of trace analysis is not possible because of interfering materials. It is only possible to reduce the sample of a non-homogeneous material by the client.
For higher levels of accuracy and reliability, use dissecting needles to tease the fibre clumps apart to easily classify the fibres according to groups based on colour and morphology. It is possible to split the samples further into smaller sub-samples to ensure higher levels of accuracy in sample testing.
Soil samples
Samples from the soil will have to be subjected to the following procedure to ensure variability in laboratory testing.
Sieve the sample through 10 mm sieve to obtain smaller sized samples.
Use magnifying glass or the eye to inspect fibre in the +10 mm range
Conduct a PLM and DS analysis of the sample.
Conduct a -2mm sieve trace analysis on the material
Take the samples measurements
Determine the weight of the fibre samples

Sampling Procedure


It was crucial to ensure the correct and representative samples from the site were obtained with the residents called to ensure sampling concerns were addressed. The sampling responsibilities of the technicians were to ensure correct sampling methods to address the technical question on the presence of asbestos in the soil, in addition to obtaining analytical values for study ((Australian Standard AS4964 2004).

Sampling Program

  1. Scoop the soil using appropriate tools
  2. Store the sample in the right container
  3. Samples to be labeled according to point of extraction
  4. Prepare the sample for analysis
  5. Collect samples from different locations of site soil to obtain a representative sample.
  6. Conduct an analysis of the samples to obtain a representative sample for laboratory analysis.
  7. Use Transmission electron microscopy (TEM) to detect smaller than eye fiber can detect.

The main objectives, according to the Guidelines for the Assessment Remediation and Management of Asbestos-Contaminated Sites in Western Australia (2009) were to:

  1. Identify the presence of asbestos at the site under investigation
  2. Determine the lateral and vertical extent of the asbestos presence

Site activities were halted as mentioned before to minimize the possibility of further contamination from asbestos. The use of direct transfer method to avoid disturbing the orientation of samples was identifiably used with indirect methods to capture intermediate particles to prepare the specimen for analysis.

Use of well-established standardized methods approved by the EPA and the National Institute for Occupational Safety and Health (NIOSH) and Association of Official Analytical Chemists (AOAC) to determine the size of fibre distribution with an aspect ratio of 3:1 and a minimum length of 5 μm was appropriate (OSHA 1992).

Resistant of asbestos to chemical and thermal degradation were properties used to analyze the properties of the samples (Australian Standard AS4964 2004). Electron Microscopic methods adequately addressed the presence of smaller samples that could not be detected using the naked eye.

It was crucial to identify the most appropriate and correct sampling practices to minimize errors by taking samples to incrementally minimize group segregation error, minimize materialization error because of correct sampling tools, and use of appropriate physical practices to minimize preparation error (Australian Standard AS4964 2004).


A “weight-of-evidence approach” (Assessment Remediation and Management of Asbestos-Contaminated Sites in Western Australia 2009) was used to confirm the presence of asbestos in the soil based on relevant impacted strata and inclusion of non-impacted samples. Calculations based on:

% Soil Asbestos = (% Asbestos Content x ACM (kg)/Soil Volume (L) x Soil Density (kg/L) based on the AS4964–2004 Australian standard were used to confirm the results (Department of Health 2005). That was in addition to validating the results to ensure the presence or absence of asbestos contamination in the oils samples collected from the site under investigation.

That was in addition to the methods used in collecting samples from the site including hand picking, fine screening, and tilling. Excavation, hand picking, and tilling were methods found suitable for the soil sampling method used. A least a sample was collected per 5 m length of material.


The results were indicative of the presence of asbestos in the soil at the site of investigation. The laboratory results were evaluated against the Guidelines for the Assessment Remediation and Management of Asbestos-Contaminated Sites in Western Australia (2009).

Each of the samples for analysis was assigned scores expressed as percentages (%) to provide the basis for identifying the presence of a particular type of asbestos. The results were tabulated in table 2 below.

Table 2

Lab Sample No. Report PLM Asbestos % Asbestos Fibers Asbestos Type Non-fibrous components % Non-asbestos Fibers
X KP1 Black asphaltic matter None detected none Asphalt 15 cellulose
X KP2 White powdery matter, lumpy foamy material <4.25 Detected Chrysotile asphalt 2 cellulose
X KP3 Tan fibrous matter with mastic <26.6 Detected Chrysotile Binder, mastic 15 cellulose
X KP4 Tan sheet vinyl None detected none Vinyl binder 5 cellulose

Using PLM, DS, and observation methods, two samples revealed the existence of asbestos in the soil samples obtained at the port. The presence of Chrysotile asbestos (2%) was detected in the soil samples from Port Kembla. Some samples including KP1 obtained from the backside of the Port were asbestos free.

The absence of asbestos in the KP1 sample was linked to the an initial shipment of soil into the Port, with the possible explanation that Lend Lease had only conducted partial analysis without thorough investigation according to the requirements set out for sampling and testing of the whole bulk of the soil for shipment.

Chrysotile was detected in the other samples including KP1 (15%), KP2 (2%), KP3 (15%), which were significantly high. This presents serious public and occupational health threat to the residents of Port Kembla and workers at the port. The samples, both homogeneous and non-homogeneous indicated a 0.1 g/kg asbestos presence indicating respiratory implications on the health of the residents.

Overview of various Government requirements

The Australian Government (2012) in line with the World Health Organization (WHO) and the National Health and Medical Research Council provides public awareness, information on the import and export of asbestos, and the removal and handling of asbestos.

That is in addition to the National Environmental Protection Council’s Movement of Controlled Waste National Environmental Protection Control Measure (Controlled Waste NEPM). Confirmed presence of asbestos in soil shipments to Port Kembla was in violation of the code of practice for the transportation and removal of asbestos in line with the Occupational Health and Safety Regulation 2001.

That was in addition to violating the Environment Operations (Waste) Regulation 2005 for the asbestos disposal and the general duties applying to asbestos laundries, according to the OHS Act.

Contravention of the code of practice for clearance inspection and Mine Health and Safety Act 2004, Contaminated Land Management (CLM) Act, Fair Trading NSW and Australian Consumer and Competition Authority (ACCC), and the WorkCover NSW were also evident in the findings.

Recommendations have it that a detailed investigation be conducted and documentation provided by the Lend Lease for the analysis conducted to determine the appropriate course of action.


In conclusion, the suspect dumbing of asbestos containing materials confirmed after analytical tests on homogeneous and non-homogeneous samples confirmed the presence of asbestos. There in need for further evaluation and analysis of the documentation provided by the Lend Lease by the Australian Asbestos Awareness and Management Agency (AAAMA to further confirm and engage appropriate stakeholders for the handling of asbestos by providing technical expertise.


Australian Government 2012, Asbestos Management Review: Report- 2012

Australian Standard, 2004 Method for the qualitative identification of asbestos in bulk samples. Published by Standards Australia International Ltd GPO Box 5420, Sydney, NSW 2001.

Australian Standard . Web.

Department of Health, 2005, Guidance on Health Risk Assessment. Web.

Guidelines for the Assessment, Remediation and Management of Asbestos Contaminated Sites in Western Australia, 2009 Toxicology Branch Environmental Health Directorate Department of Health PO Box 8172 PERTH BUSINESS CENTRE WA 6849. Web.

Contaminated Sites in Western Australia, 2009 Toxicology Branch Environmental Health Directorate Department of Health PO Box 8172 PERTH BUSINESS CENTRE WA 6849. Web.

EnHealth Council, 2005, Management of Asbestos in the Non-Occupational Environment, Commonwealth of Australia: Canberra. Web.

Health Asbestos Regulations, 1992.

Lowry, E 2002, . Web.

New South Wales Council 2011, . Web.

New South Wales Council 2012, Work Health and Safety Act 2011 No. 10. Web.

Oberta, F 2005, Asbestos control surveys, removal, and management, ASTM International, West Conshohocken.

Perry, A 2004, A discussion of asbestos detection techniques for air and soil. Web.

Safe Work Australia 2011, Asbestos registers and asbestos management plans. Web.

Swartjes F A and Tromp P C, 2008, A Tiered Approach for the Assessment of the Human Health Risks of Asbestos Soils, Soil & Sediment Contamination, 17:137-149. Web.

Wollongong City Council 2008, Port Kembla – History. Web.

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