Mass balance reporting

The following reference materials will be added as soon as they are available:

• Environment Protection (Mass Balance Reporting and other Measures) Variation Regulations 2020
• Waste reporting, record keeping and measurement standard
• Mass balance monthly reporting for waste depots information sheet
• Mass balance monthly reporting upload spreadsheet
• Data specifications for mass balance instructions
• Mass Balance technical presentation video, 30 March 2021
• Training information.

What if the EPA’s list of material types does not include one of the material we need to report?
We ask that you choose a waste and material types that best fits the material you are trying to categorise. If there are specific material that are not covered by any category then please email or contact us on (08) 8204 2099 .

If I recycle all incoming material into new product which often happens ie new asphalt, how is that categorised or does it need to be?
Yes it needs to be categorised and you should use the best fit material type and then can provide a description for the product in the ‘Further information’ field.

If mixed wastes are split into the various categories upon receipt based on origin or bin type. The waste will be stored based on waste type after sorting and it will not be easy to determine whether outgoing waste was originally receipted as hard waste, skip, kerbside, etc. How can we categorise those wastes when reporting stockpile balances & outgoing waste?
You will only need to categorise the material type when it is being sent out. This does not need to be the same material type as when it was received.

Can we access the upload template via the EPA website?
Yes, this is the link to the template.

How do we access the system?
Reporting the mass balance monthly returns will be done through the online electronic licencing forms (ELF) system portal using your current credentials.

Access to each licence is done using the Authorisation number and a single password provided to the holder of the licence. The system cannot create more than a single login and it is the responsibility of the licence holder to manage access to this portal.

When will this be live in ELF?
The online portal will be live from 1 July 2021, with access for pre-testing purposes in June 2021.

If the system is going live from 1 July 2021 is it possible to carry out a stocktake on the same day so that we start with a base line?
The EPA is allowing licensees flexibility to stocktake until end-September 2021. You can  stocktake on 1 July 2021. Subsequent stocktakes or surveys will need to be undertaken within 3 months prior to your annual return submission date. Note that no stocktakes or surveys will be required to be undertaken between October 2021 and March 2022.

How does the EPA define a qualified surveyor?
The definition can be found in the Waste reporting, record keeping and measurement standard. It requires that a licensed or registered surveyor under the Survey Act 1992 be used.

Is it an option to use another method such as drone imagery, rather than a surveyor?
The EPA requires a third party (verified surveyor) to undertake stocktakes and surveys, however exemptions can be applied for and will be assessed on a case-by-case basis.

Surveys and stocktakes – how often are these required? Is the frequency dependent on our scale of operation?
Baseline survey required to be undertaken between 1 July and 30 September 2021. Annual surveys/stocktakes are to be submitted with the licence annual return.

Other government departments require information to be confirmed with a statutory declaration. Is this an option as surveyors add cost to this process?
The EPA is not looking to do statutory declarations. Licensees are able to apply for exemption to undertake themselves. A declaration by an authorised person confirming information provided is correct is required when submitting a survey or stocktake report.

Do the transporters also have to keep those records? Or does the facility manage that data?
Only waste facilities undertaking mass balance reporting have to keep those records

We noticed in the Waste reporting, record keeping and measurement standard that video monitoring records are required to be kept for 12 months. Under what conditions might exemptions for this be considered given the potential costs of expanding storage by 10–15 times to comply with the requirement?
Note the requirement to install and operate a video monitoring system will only be required upon the EPA issuing a notice in writing to do so.

What if there are differences in tonnages between the monthly reporting and the stocktakes or surveys?
The EPA understands there will be some variations between reports due factors such as material loss/gain and calculation, eg density factors used. Data tolerances will be considered when assessing the data. Licensees are encouraged to provide an explanation of any variance in the data when these differences arise.

Will there be a mechanism for comparing weighbridges at transfer stations and landfill sites?

Through mass balance reporting data it would not be possible to track specific loads transferred between sites and any changes in weights. If large discrepancies are identified in the data reported by connected sites the EPA may use this as a trigger for further investigation to understand the issue, while recognising that there can be legitimate reasons for these changes (such as moisture loss).

Will macro-level data be reported/available to industry?
Macro-level data will be used to inform public documents such as the annual recycling activities survey published by Green Industries SA.

What about waste generated on site, ie trommel fines? These are a residual of our process and used on site under an approval. Do these have to go over the weighbridge or can we use a conversion factor?
All material must be weighed when coming into the site, but when reporting the amount used, on-site conversion factors can be used so it does not have to be re-weighed. There is more information on this in the Waste reporting, record keeping and measurement standard.

What is required in place of weighbridge operator’s name where the weighbridge is unmanned/automatic?
If your weighbridge is unmanned/automatic, please inform the EPA via email and mark ‘Attention: Melanie Long’.

Any plans to provide industry specific training? Organics industry operators have a lot of commonality, such as material loss in process (decomposition) and will presumably affect our conversion factors
The EPA is happy to provide further training to industry sectors. Please email or contact us on (08) 8204 2099.

Mass balance reporting will require certain licensed waste facilities including transfer stations, resource recovery facilities and waste disposal depots, to report on the monthly tonnages of waste and other matter that a site receives, stockpiles, uses onsite, disposes of or transfers from the site for sale or disposal.

Mass balance reporting requirements have been developed through ongoing consultation with the waste and resource recovery industry since 2015, including:

• 2015 discussion paper, Reforming Waste Management
• 2017 Explanatory Paper: mass balance reporting
• 2018 voluntary pilot trial
• 2020 consultation with mass balance reporters on the draft Waste Reporting and Record Keeping Standard (including conversion factors and waste types)

The Environment Protection (Mass Balance Reporting and other Measures) Variation Regulations 2020 were gazetted on 10 December 2020 and will commence on 1 July 2021, introducing necessary reporting, verification and record keeping requirements into the Environment Protection Regulations 2009.