Streamlining the dark art of trade waste New
Date: 16-Apr-2025
Streamlining trade waste management in Queensland's regional water utilities is long overdue. By cutting through the complexities, compliance can be achieved without overwhelming councils.
Trade waste management in Queensland's regional water utilities is often seen as a "dark art," where the lack of a coordinated, state-wide framework leads to inconsistent practices across the state.
In a recent presentation, industry veteran Col Hester explored what he terms a “stream of consciousness fever dream” about trade waste management in regional Queensland and asked a critical question: what is the least you could do and still claim to be a competent trade waste manager?
This question is pertinent given Queensland’s vast geography and diverse regional communities. The lack of a unified approach means that trade waste management, typically seen as an administrative burden, is often overcomplicated or under-managed, particularly in remote areas. As Col explains, the absence of meaningful guidance from regulators has forced regional councils to either ignore their obligations or develop individual policies. This leads to inefficiency and inconsistent outcomes across the state.
The challenge: regional disparities
Queensland's sheer size presents a unique challenge. Many regional centres are located further from the state's capital than they are from cities in neighbouring states, making regional challenges particularly acute. While larger centres like Cairns, Townsville, and Mackay have the resources to implement trade waste management frameworks that rival their metropolitan counterparts, smaller and more remote towns struggle. Some small towns are challenged to maintain sewerage schemes serving fewer than 500 people.
In these areas, trade waste management can become an afterthought. Yet, under Queensland’s Water Supply (Safety and Reliability) Act, water service providers must have a system to assess and approve trade waste discharges into their sewerage systems. The absence of a clear and coordinated model leaves many councils reinventing the wheel.
One example Col provides is Mornington Island’s small community of Gununa, where fewer than 1,000 residents rely on a sewerage system. Despite this small scale, commercial activities such as hospitals and schools technically discharge trade waste into the system. Under Queensland legislation, these activities should be the subject of a regulated system of assessments and approvals. Yet, the scale and scope of the community make significant trade waste management efforts impractical.
So, how can regional councils balance compliance with practicality? Col proposes a simple yet effective solution: an efficient, minimalistic approach to trade waste management that ensures compliance while reducing unnecessary burdens.
A model trade waste management plan
Col’s answer to the problem lies in a Model Trade Waste Management Plan (TWMP) tailored to regional councils. The premise is straightforward: the plan should focus on the essentials instead of burdening councils with overly complex or unnecessary trade waste management practices. His goal is to develop a clear, consistent framework that smaller councils can adopt without reinventing policies or spending resources on low-risk activities.
This leads to the core of his proposal – Category Zero. Category Zero businesses pose no greater risk than domestic sewage and do not need trade waste management attention. Col advocates for a high tolerance for discharge before trade waste management is required, including for typical small businesses such as hairdressers, florists, dentists and childcare centres. Even motels and schools could fall under Category Zero, provided they operate at a relatively small scale, such as schools with fewer than 100 students. Larger institutions may require additional controls, such as grease arrestors, but the idea is to ensure that trade waste regulations focus only on those businesses that truly warrant it.
The second element of the Model TWMP is a volume-based exemption for food service businesses. Col proposes that small businesses using less than 600 litres of water per day should be exempt from requiring grease arrestors, arguing that their waste load is comparable to that of a small residential building. Larger establishments that exceed this threshold would need additional controls. Still, this simple rule would exempt many smaller food service operators, allowing councils to focus on businesses with a more significant risk profile.
Simplifying grease arrestor requirements
One common complexity in trade waste management is determining when grease arrestors are necessary and what size they should be. Col suggests a simplified approach for regional councils: mandate a standard 1,000-litre grease arrestor for all new installations unless a business’s scale or risk justifies a larger one. This approach, already used by metropolitan water utilities, could significantly streamline trade waste approvals in regional areas.
More significant management efforts are required for larger customers – those Col labels Category 2. These include businesses such as shopping centres, large hotels and major food processors. In these cases, councils should focus on ensuring that trade waste discharges do not overwhelm the capacity of local sewage treatment plants. By implementing a template approval process for Category 2 customers, councils can provide consistent and effective management without becoming bogged down in complex negotiations or bespoke agreements.
Trade waste pricing and risk assessment
Pricing trade waste services can be a complicated task, often fraught with assumptions about volumes and waste strengths. Col’s approach is to simplify this process by eliminating unnecessary calculations and focusing on a straightforward charging model. For Category Zero customers, there would be no charge. For Category 1 businesses – those using between 600 and 1,200 litres per day – charges would apply only to the volume exceeding the 600-litre threshold. For Category 2 customers, more detailed cost recovery mechanisms would be used, but transparency and simplicity are key.
For Category 2 customers, Col recommends a risk-based approach to trade waste management. Instead of relying on complex risk assessment algorithms, councils can use simple characteristics to determine whether a business poses a significant trade waste risk. These include corrosive discharges, obstructive materials, and high biological or chemical loads. By focusing on these clear indicators, councils can identify high-risk customers without overcomplicating the assessment process.
The road ahead
Col’s Model TWMP offers a practical, scalable solution for trade waste management in regional Queensland. Regional councils can effectively manage trade waste without expending unnecessary resources by focusing on simplicity, risk, and clear guidelines. Most importantly, a consistent, state-wide framework could save councils from developing their own policies while ensuring that trade waste is managed efficiently and effectively across the state.
Adopting such a model would meet regulatory obligations and provide much-needed relief to the many trade waste officers in regional areas currently tasked with creating unique solutions for problems that have already been solved. Col notes that the real goal is to “save about 50 councils and their miniature commercial customers from having to do anything at all” unless it’s truly necessary. And that is trade waste management done right.
Image: Inlet works, Mornington Island STP, Gununa
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