A Brief History...

The largest concentration of the chemicalmanufacturing industry in the southern hemisphereis situated in Altona, a pleasant bayside suburb ofMelbourne, Victoria.

Altona was a quiet residential area surrounded byextensive paddocks which were used as agistmentfor horses until 1961 when these paddocksbecame development sites for the chemicalindustry. Fed the necessary feedstock by therecently expanded Mobil Altona Refinery and

serviced by the industries of the adjoining suburbsand with easy access to ports and major roads, thelocation seemed ideal to industry but less thanideal to neighbouring residents. Land zoned forresidential use extended to within three hundredmetres of a large petrochemical plant.

The Altona Chemical Complex brought with itprogress, profit, people, problems and pollution.The residents were assured that the noise, smokeand smell associated with the start-up of thevarious plants would lessen as they settled into thenormal routine. The nuisance did decrease but notnearly enough to satisfy residents and there weremany incidents involving injury to workers andreleases of toxic emissions. Residents wereconstantly annoyed and fearful. One companyalone, B.F. Goodrich (Australian Vinyls) had twopotentially catastrophic accidents resulting in therelease of six hundred and seventy six tonnes ofvinyl chloride monomer (VCM) in one incident andeleven tonnes of the same material in another.

Vinyl chloride monomer is a flammable, volatilecarcinogen. Luckily both these releases weredissipated by favourable winds.

THE ALTONA CHEMICAL COMPLEXNEIGHBOURHOOD CONSULTATIVE GROUP

By Nessie Hardy

Relying on the vagaries of wind strength anddirection to save us from disaster was notcomfortable. Local residents were also fearful of theeffect the constant emissions were having ongeneral health. There were many individualprotests but the people felt isolated and ignored.Much anger was expressed to friends and familyand concern felt about the health effects of theseexposures but most felt powerless to take theircomplaints further.

Some of the factors that influenced this feeling ofpowerlessness were:

• There was an understanding of the economicbenefit of the industries;

• There was a reluctance to offend those whoworked in or received commercial benefit fromthe chemical industry.

Most residents of Altona are not accustomed tohaving input into the decisions which most impacton their lives because the area has been virtuallydisenfranchised from all three levels ofgovernment. It is a safe Labor party seat in bothstate and federal parliaments and the uniquemethod of local government elections in place untilrecently has meant little chance of changinganything politically.

Although the officers of the Council healthdepartment did their best to cooperate, they werefrustrated by lack of proof that would stand scrutiny.

Many odours are transitory.

Calls to the industry were stonewalled. There wasno communication between management andresidents. Even after the Environment ProtectionAuthority was set up in 1971, it was not consideredas anything more than a bureaucracy set up tolicence industrial emissions. It was remote anddifficult to contact after office hours.

In spite of all these restrictions, a small group ofconcerned residents got together and called apublic meeting which was attended by 150 angrypeople. It was at this meeting that the AltonaEnvironmental Action Group was formed. Thisgroup played an important role in focussing the fearand anger of the community and providing a forumfor concerns to be discussed with a view toresolving the problems. At the time, many felt theonly resolution would be the closing of the industry.

The Action Group questioned the right of thechemical industry to impact on the health, safetyand amenity of the local residents. Everydevelopment proposal by the industry wasopposed.

There were street marches, placards, publicmeetings, petitions and letters to the editor in bothdaily and local papers. Indeed it was not unusualfor local media to have front-page headlines suchas, “TIME BOMB TICKING AWAY IN THE WEST'and 'THE FUSE IS BURNING'.2

Things come to a head

The situation deteriorated in 1986, when anapplication to establish a Social Club onundeveloped land close to the Complex wasrefused because the Chemical Complex,Environment Protection Authority (EPA) and theMinistry of Employment and Training appealedagainst the City of Altona's intention to grant apermit on the grounds that the:

- proposed development would be contraryto proper concern for public safety; proposeddevelopment would encroach on a potentiallyhazardous installation; and

- subject land was adversely affected byresidual air emissions and industrial noise fromnearby industries.

A further important aggravating factor was theGovernment's quantitative risk assessment studyconducted by Technica which found inappropriatelevels of risk to residents living close to theComplex.

This finding was of great concern to local residentsmany of whom lived closer to the Complex than theproposed Social Club would have been. Planningamendments were drawn up which restricted useof all land near the Complex. This action angeredthe local residents who believed their homes were

devalued and the area stigmatised. The Complexcompanies were not totally happy with theamendments and other industrial landowners alsoopposed them.

The situation was inflamed by Companyannouncements of expansion plans made inignorance or disregard of local residents concerns.

A stalemate had been reached.

A Way Forward - theACNCG

The Minister for Planning then invited the LaborMember for Werribee, Dr. Ken Coghill to investigateways in which the various parties could be broughttogether and an equitable solution found.

In late 1988 Dr. Coghill held a number of publicmeetings to which he invited residents,representatives of the Chemical Complex, the Cityof Altona, the EPA and the Department of Planningand Environment.

As a result of these negotiations the AltonaComplex Neighbourhood Consultative Group(ACNCG) was set up to facilitate discussionsbetween industry, regulators and residents.

The Consultative Group is resourced by the local 3

council and is chaired by a City Councillor.Meetings are held monthly and rotate between thevarious industry sites and council offices. Minutesare taken and distributed by a council employee.Other council officers are also present with theHealth, Planning or Environment departmentsusually represented. The Victorian WorkcoverAuthority (VWA) is represented at meetings. TheEPA which has provided invaluable assistance hasbeen represented by at least two officers at everymeeting. The Chemical Complex which consistedof seven sites at that time had an obligation to berepresented by their senior site managers.

In fact, this commitment continues to be observedtoday and it is rare for any company not to berepresented by top management. TheEnvironmental Advisor and the Community LiaisonAdvisor employed by the Complex are always inattendance. There are presently eight residents orcommunity members. The Environment, Healthand Safety Managers of all companies usuallyattend and other employees are welcome.

The matters of concern raised at these meetingswere considered when the next amendment waspresented in April 1990. The principle change inthis was that the residential zone would retain itsResidential C status. This took the sting out ofresidents' objections to a degree but having beenalerted to the danger acknowledged by theauthorities a small group continued to be involved

in discussions with Council, EPA and Industry.

The first meetings were very difficult with theComplex representatives expecting to be shoutedat and the residents expecting to be patronised.Visiting a company's premises took courage andwas seen by some onlookers as “selling out”. Thissuspicion made it extremely difficult to make anyprogress and often members felt that it was awaste of time and energy but gradually the barriershave been lowered.

The 'them and us' attitude decreased as theindustry representatives learned that it waspossible to explain technical problems to untrainedpeople (untrained, that is, in chemical ormechanical engineering) and the residents havelearned to focus on the problems at hand.

Over the years there have been instances ofpaternalism and shouting but there has beenlaughter too. Most importantly, from anenvironmental point of view, there has been asubstantial reduction in emissions and otheradverse effects from industry and a moreresponsible attitude now generally prevails.

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ACNCG MeetingArrangements

With various mergers and plant closures, theAltona Chemical Complex now consists of BASFAustralia Ltd., Dow Chemical (Australia) Ltd., andQenos Pty Ltd. Qenos has four sites, namely:Olefins, Plastics, Elastomers and Resins whichmakes up seven plants in all. Each site hosts theACNCG annually. The Annual General meeting ishosted by the Hobsons Bay City Council.

A light meal is served and the meeting properbeings at 6.30 p.m. with a presentation by the hostcompany. This encompasses the company'senvironmental and safety performance of theprevious year.

An annual “state of the environment” report iscirculated with any other relevant documents, e.g.minutes of the previous meeting, backgroundpapers and the current agenda, several days priorto the meeting date. This information is discussedin detail by anyone in attendance.

Comment on the host company's environmentalperformance is then made by the EPA followed bycomment from any attending VWA representativeon safety performance.

Copies of annual reports are available to all. These

reports have been found to be extremely useful infocussing attention on performance and trends inhealth, safety and environmental matters.

These presentations are followed by EPA,Workcover, City West Water and Council's reportsdetailing any complaints received during theprevious month. These reports include details ofplanning permit applications, Works Approvals andlicence alterations requested for the Complex orthe surrounding area.

This procedure was negotiated when the Stategovernment granted the Complex companies as-of-right planning privileges which meant that theindustry was not required to notify their neighboursof all developments on their sites. The compromisereached then was that industries would notify theACNCG as early in the planning procedure aspossible of any on-site changes contemplated. It isthe ACNCG members' responsibility to advertisethe information as widely as possible into thecommunity and to assist industry to focus on theneed to reduce the environmental impact of anynew development.

This demonstration of the acknowledgment that thecommunity does have the right to know of potentialimpact on them by industrial processes is one ofthe more encouraging outcomes of the greater co-operation between industry and its neighbours.This is not to say that Australia does not need Right 5

to Know legislation but this local initiative shoulddemonstrate that not only would it possible to livewith such legislation but that if industry has nothingexcept commercial secrets to hide it will not be aproblem to them and will help to break downbarriers. Ignorance breeds fear.

Another outcome of the acknowledgment that thecommunity does have a right to know is that if anincident occurs in any of the Complex companieswhich could have had a health, safety orenvironmental impact on the community the SiteManager and other employees involved in theincident attend the next scheduled ACNCGmeeting to describe the incident and answer anyquestions. This information gives valuable insightinto the efficiency of the plant and managementand should prove effective in maximising safety inthe workplace as it is embarrassing for a managerto have to report faults to peers and neighbours. Ifthe incident is serious the relevant company willhold a special ACNCG meeting as part of theirEnvironmental Monitoring Team process (referbelow).

Each company reports on progress being plannedor in process, the progress of EnvironmentImprovement Plans, training programs, emergencyresponse exercises or ongoing issues, e.g.contaminated ground water or disposal of odorouswastewater.

The EPA and VWA discuss any breach of licenceor changes in procedure which may impact on theComplex or the local area.

Resident members discuss local issues which mayinvolve the Complex and report on meetingsattended on behalf of the ACNCG or as an adjunctto it.

Meetings are open to all and visitors are welcometo become involved in discussions.

Environmental MonitoringTeams (EMT)

Dealing with three companies on six sites iscomplicated. So much so that residents felt thatthey didn't have enough time to explore and digestall the information provided at the monthlymeetings of the ACNCG. Moreover, the meetingswere taking far too long.

It was decided to create sub-committees called anEnvironmental Monitoring Team (EMT) for eachcompany whose principle task would be to helpformulate and monitor the EnvironmentImprovement Plans for each individual company.These EMTs meet bi-monthly and report back tothe ACNCG which now also meets bi-monthly.6

This system has resulted in a more focused andhands-on consultation with individual companieswhere reports are detailed and incidents examinedand discussed with a small, dedicated band ofresidents, the EPA, Work Safe, and City WestWater representatives.

EMT Minutes are included in the ACNCG's Agendaand clarification and explanation given to thebroader group if requested.

Issues of a general and/or inclusive nature i.e.emergency response, regulations, town planning,land zonings etc. are discussed with the largergroup an ACNCG meetings.

All meetings are open to all.

Groundwater

One of the ongoing and most serious issues dealtwith by the ACNCG is that of contaminatedgroundwater which has, in some instances, spreadfrom “hot spots” within the Complex beyond theboundaries.

Presently (2004) three sites have a problem withcontaminated ground water which has resultedfrom accidents and/or poor waste disposalpractices in the past. They are the former

Australian Vinyls site, Dow Chemical and QenosOlefins.

Although Australian Vinyls Altona closed their sitesome years ago (February 2002), remediationwork to cleanse the groundwater is still beingcarried out by the site's owners, Orica Limited, whoset up a firm, Altona Properties Pty. Ltd., tomanage this task.

Results of trials and investigations are reported atEMT and ACNCG meetings as well as at especiallyconvened meetings held in community halls todiscuss remediation efforts.

Benefits and Achievements

The ACNCG has been host to many people fromAustralia and overseas who are interested instudying the group's method of consultation. Inaddition, members of the ACNCG have beeninvited to address other industry/resident groupsand to assist them in developing lines ofcommunication.

For some time a member of the ACNCG was adelegate on the National Community AdvisoryPanel for the Responsible Care program of thePlastics and Chemical Industry Association. Thisposition involved assisting the formulation of Codes 7

of Practice which form the core of the program andongoing input to discussions of compliance withthe codes and the spirit of Responsible Care.

Sub-committees and individual members of theACNCG have been involved in a various activitiesover the years and continue to participate in anumber of consultative processes. An example ofthese are:

• Submitted comment to the Coode IslandReview Panel;

• Assisted in the formulation of the NationalStandards for the Control of Major HazardFacilities;

• Assisted in the regional emergency plan(DISPLAN);

• Group gained government funding forbeautification projects (tree planting etc.) andcarried them out with the assistance of thewider community;

• Participation in various training workshops withindustry employees;

• Assisted the EPA by meeting with interstate andoverseas visitors and sharing their experiences;

• Being involved in formulating the CorporatePlan for the new City of Hobsons Bay;

• One member is involved with the VictorianWorkCover Authority as part of their

community/regulatory authority consultativeprocesses;

• Two members are office holders at the localMigrant Resource Centre;

• A number of members also participate invarious community/industry consultative groupswithin the western suburbs.

The above activities are not by any meanscomprehensive, they are merely an indication ofthe network of communication which results wheninterested people seize the opportunity to make adifference.

By far the most important indication of the group'seffectiveness is the reduction of emissions from theComplex since the ACNCG was formed in 1989,although the group doesn't claim sole responsibilityfor this improvement.

During this time many people have recognised thenecessity of reducing industries impact on theenvironment. The Complex has accepted itsobligation to reduce nuisance and risk to theirneighbours and its impact on the widerenvironment. Much work has been done toaccomplish this end.

The tables below illustrates the considerablechanges in the Complex emissions and use ofresources over the past fifteen years:

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The Complex EnvironmentAdvisor and the ComplexCommunity Liaison Advisor

Owing to the increased communication betweenindustry and neighbours and the complexity ofregulations, the Altona Chemical Complexemployed a full-time Environmental Officer on acontract basis. The role was re-defined by theComplex companies in December 1997 when itwas decided to share responsibilities between twoQenos employees. These advisors are contractedout to the other Complex companies on a part-timebasis.

Both are based at Qenos Olefins site. The duties ofthe Complex Environmental Advisor and theComplex Community Liaison Advisor haveincorporated the following:

• Liaising between industry, regulators, Counciland residents and representing the Complex onmatters affecting all of the companies;

• Facilitating the direct telephone links whichhave been introduced into the localkindergarten, schools and Migrant ResourceCentre as a means of alerting them immediatelyto any emergency at the Complex

• Producing The Consultative Chronicle; and

• Overseeing the operation of the Environmental

The Consultative Chronicle

The Consultative Chronicle is the newsletter of theACNCG. The newsletter is printed three timesannually and is the principle method ofcommunication between the ACNCG and the widercommunity. Each edition is delivered toapproximately 10,000 households and businessesin Altona and Altona Meadows. A further 2,000copies are mailed to community organisations andcirculated to employees within the Complexcompanies.

The newsletter is produced by a sub-committee ofthe ACNCG. The newsletter is financed by theAltona Complex except for one edition annuallywhich is financed by the City of Hobsons Bay. It isrecognised as conveying the views of the entireACNCG. To this end all members are supplied witha draft copy before publication with the right tocriticise and change content. As with all activities ofthe ACNCG constant vigilance is required by all toensure that the information conveyed is unbiased,factual, relevant and interesting to the generalpublic.

The ACNCG has recently established their ownwebsite; www.acncg.info and email address;acncg@qenos.com.au. Recent copies of theChronicle can be accessed on the website.

Environmental Action Line

The environmental Action Line was set up followingdiscussions between ACNCG members about thedifficulties in reporting nuisances which may bedangerous to health but which may also betransient and so impossible to detect by the time aninvestigator arrives on the scene.

The Environmental Action Line is a free-call hotline(1800 061 050) set up by the Complex to providean immediate response to residents concernedabout operations in or about the chemical complex.The responsibility of servicing the line has beenshared between the companies though since mid1994 the 24 hr, seven days a week line has beenstaffed by Qenos Olefins shift personnel.

Each call is recorded and details passed on to theEPA and Council within two days. Personal detailsof the complainant are not passed on. All calls areinvestigated immediately and, if the source of theproblem is within the Complex, endeavours aremade to have the problem addressed and to notify 11

the caller of the result as soon as possible. Thecaller may elect to remain anonymous and willunder these circumstances not receive a call back.

The hot line has reduced the tension betweenindustry and its neighbours as complainants cannow receive immediate replies to concernsknowing that the EPA and Council will also beinvolved. An information magnet advertising thisnumber has been distributed to all households whoreceive the Consultative Chronicle.

This hot line does not replace the service providedby the EPA and Council but provides an alternativeservice twenty-four hours a day and on the spotinvestigation.

All calls on the environment hot line are reported tothe ACNCG at the next meeting.

If an incident occurs at a Complex site whichresults in multiple complaints the company involvedwill contact all households in the area affected witha printed apology and explanation.

Complex-Schools-CouncilTelephone Network

A Complex-Schools-Council Telephone Networkhas been installed to enable local schools,

kindergartens and the Hobsons Bay City Council tobe notified promptly if there is an incident whichmay either cause concern or present some risk tothe schools and the wider community. The phonescan also be used by the schools, kindergartens,Council or the Westgate Migrant Resource Centreto seek information from the Complex.

The Telephone Network consists of direct-dialtelephones in eight local schools andkindergartens, Westgate Migrant Resource Centreand the Hobsons Bay City Council. Thesetelephones are not connected to switchboards andhave unlisted numbers to facilitate communication.

Odour Detection

A particular problem encountered by localresidents and the industry, was the difficulty ofidentifying odours travelling off-site which resultedin a complaint being registered.

With this in mind, Qenos invited interestedresidents to visit each of their sites annually to helpthem to recognize any errant odour they havenoticed off-site. This assists the plant operators tocorrect the problem causing complaint. The peoplewho regularly undertake these “odour tours” alsoscore the various odours they detect on-site forintensity in comparison to former years.12

Accredited Licensee

Because of the reduction in emissions from theComplex and elsewhere, volatile organiccompound emissions have been significantlyreduced by all Complex companies since 1989. Toensure ongoing improvements in cleanerproduction, the EPA has formulated a new systemof regulating companies which have a good safetyand environmental record, good managementsystems in place and a commitment to clean andsafe production.

The following criteria must be met before acompany will be considered for this new andcoveted Accredited Licensee status:

• An Environment Improvement Plan (EIP) mustbe formulated with the assistance of the EPA,Council and the community. The EIP will detailimprovements to be made and set target datesfor the completion of this work;

• An Environment Management System must bein place and certified against an approvedstandard; and

• An Environmental Audits Program must be inplace involving independent auditors.

Companies which qualify for Licensee statusbenefit by having;

• Less stringent inspection of their compliancewith regulations (which will not be more relaxedthan before).

• Exemption from some works approvalsrequirements.

• Lower licence fees.

This new and somewhat revolutionary concept ofplacing more reliance on the industry to beresponsible for compliance to the standards set bythe regulatory bodies is controversial. It reliesheavily on involvement by community membersand of their being alert and aware of companypractices and, more importantly, company culture.

This is difficult to obtain and even more difficult tosustain. To be an active member of an EIP teamdemands a large commitment of time and effort.The possibility of a compliant resident memberbeing used to confirm or validate poor performanceshould be seen by industry and all otherparticipants as the weak link which could destroyan otherwise worthy initiative. It may also bedifficult to recruit enough people from the widercommunity who feel competent to discusstechnical matters pertaining to a chemical plantand who feel that their effort would be worthwhile.

It is important that the EPA maintain a closerelationship with their Licensees and othermembers of the EIP teams. This is especiallyimportant when there is a change of management 13

in industry as company culture is fostered from thetop down.

The Licensee policy is in its infancy. If it is to growit must be nurtured but it will succeed only if thecommunity considers that it is a better method ofassisting industry toward clean production.Success will be measured in:

• A reduction of incidents affecting health, safetyand environment.

• An improvement in the stewardship of rawmaterials and products.

• Reduction of resource use.

• The elimination of waste.

Towards the Future

We expect that industry management will achievea higher standard of excellence if they areencouraged in their efforts and rewarded for theirachievements than if they are forced to comply witha minimum standard and threatened withpunishment if they fail.

Standards must be set and sanctions legislated,but the efforts of the Altona ComplexNeighbourhood Consultative Group, ResponsibleCare, Community Right to Know, Victorian

Workcover Authority and theEnvironment Protection Authorityare all focussed on ongoingimprovement in the health, safetyand environmental performance ofthe chemical industry which goeswell beyond any that is presentlyrequired by law.

Together we are trying to create aculture of care and responsibility.

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For further information contact:Nessie Hardy, 03 9398 4803

or visit the ACNCG website onwww.acncg.info