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NSW Government Submission
to the Productivity Commission’s Issues Paper on
Chemicals and Plastics Regulation
Summary and Recommendations
Summary and Recommendations
The NSW Government recognises the benefits of chemicals to the NSW economy and quality of life, while noting the risks associated with the use of chemicals across their lifecycles will always need to be responsibly managed by industry, governments and consumers.
The NSW Government believes that most aspects of the current management systems governing chemicals and plastics operate effectively. Chemicals regulation in NSW is effectively integrated with other industry-based regulatory systems (e.g. for air, noise, water, workplace safety etc.) so that industry has straightforward and comprehensive interactions with Government. There would be major inefficiencies if chemical regulation was to be excised from such an integrated situation. There are some gaps, inefficiencies and inconsistencies that could be resolved, most notably in the area of industrial chemicals management.
The current chemicals management frameworks for dangerous goods and hazardous substances, agricultural and veterinary chemicals and food are operating effectively and efficiently and should be retained.
Improvements to the environmental management of chemicals under the National Framework for Chemicals Environmental Management (NChEM), as already agreed by Environment Ministers and all key stakeholders, should continue to be implemented as detailed in the NChEM Action Plan for the Environment.
NSW’s position as a best practice chemical regulator/manager needs to be recognised in any consideration of national uniformity – NSW will not lower its existing standards of responsible risk management in the pursuit of national uniformity.
There needs to be effective national system-wide policy coordination.
Australia’s performance in managing chemicals needs to be considered in the context of international best practice, for example developments in the European Union and Canada.
National level reforms to industrial chemicals management are needed. These reforms should include:
the provision of a full suite of regulatory and non-regulatory tools to the national industrial chemicals regulator;
streamlined linkages between national assessments and risk management actions;
measures to effectively assess the risks of ‘grandfathered’ existing chemicals;
regulation of chemicals in consumer products, including imported articles; and
support for chemical industry innovation to encourage the use of chemicals that reduce/eliminate health, safety and environmental risks.
The Globally Harmonised System of Classification and Labelling (GHS) is a valuable initiative but should be adequately supported, managed and resourced at the national level to address implementation challenges.
There needs to be consideration of enhancements to chemical risk management in Australia through increased national investment in overcoming information gaps and asymmetries (by way of better data collection and chemical monitoring) and increased investment in growing Australia’s chemical technical capacity/skills.
It is imperative to ensure that management regimes are appropriately resourced and that funding mechanisms are matched to regulatory and management approaches and powers if desired safety outcomes are to be achieved.
‘Effective . . . regulation is integral to successful markets, an essential ingredient of a vibrant, modern economy.’ 1
The NSW Government strives for an efficient, effective and streamlined regulatory framework. The regulatory framework governing the chemicals and plastics sector in NSW largely meets this goal. It is necessarily complex to some degree as it must protect human health, the environment and trade while providing economic certainty to NSW business and industry. The challenge is to provide a mix of policy tools that delivers the most cost effective outcomes: minimising compliance costs and maximising public benefits. The NSW Government has met this challenge by developing a regulatory framework to manage the potential impacts of chemicals and plastics that encompasses a diverse suite of regulatory tools. It encompasses strong regulations, along with co- and self-regulatory approaches. Within NSW, new regulations undergo a rigorous assessment process, including cost benefit analysis, to ensure that key principles of good regulation are met.
NSW is committed to a process of regulatory reform, with reductions in red tape one of the key priorities of the NSW State Plan.2 NSW has established the Better Regulation Office to foster best-practice regulation, cut red tape and reduce the regulatory burden faced by business and industry. In the same period, the NSW Government committed to implementing the recommendations made by the Independent Pricing and Regulatory Tribunal (IPART) in its Investigation into the Burden of Regulation and Improving Regulatory Efficiency.3
NSW has also been a national leader in implementing reforms in the realm of chemical and plastics regulation. For example NSW has led the development of the National Chemicals Environmental Management framework ([NChEM]), which will deliver improved environmental consistency between States, Territories and the Commonwealth while minimising the burden placed on business and industry.4
However, in reforming regulation and making it more efficient and effective, it is important that outcomes are improved, not undermined. In seeking a nationally cooperative approach, it is vital that moves towards harmonisation or consistency are not used as a mechanism to dilute existing risk management standards by moving to the ‘lowest common denominator’.
NSW also notes that moves towards national regulatory consistency and harmony must not lead to an erosion of whatever local measures are necessary to protect human health, the environment or local economies that may result from conditions specific to a region. Although some issues are consistent across state borders, each state has a unique set of circumstances that result from differences in the environment, climate, culture, economic activity, regulatory history and community expectations. In developing NSW regulations, the key driver has - and must continue to be - the State’s own needs and objectives. There is no culture of “regulate first and ask questions later” in NSW. On the contrary, chemicals management is grounded in - and all regulation flows from - rigorous risk assessment.
2. Cross-cutting issues for consideration
A number of general issues cut across all aspects of chemicals and plastics regulation. These include:
the lack of a whole-of-system chemicals policy coordination process;
the appropriate allocation of responsibilities for managing chemical risks;
the use of a risk-based approach to chemicals assessment and management and related data issues;
problems with information flows and access to information;
the need to effectively address community expectations;
the appropriate use of alternatives to ‘traditional’ regulation;
the importance of accurately assessing human health and environmental externalities when assessing costs and benefits in chemicals regulation;
the case for limited jurisdictional variation to reflect the very different contexts across Australia in which chemicals are used or produced; and
the importance of comprehensive and inclusive consultation processes.
2.1 Lack of a system-wide coordination process
Responsibility for national chemicals policy in Australia is unclear. No single agency, Minister or Ministerial Council at Australian Government level has a designated policy leadership or oversight role in relation to chemicals. This is inconsistent with Commonwealth calls for greater uniformity of regulatory arrangements at the state and territory level, promotes reactive rather than proactive responses in identifying and managing chemical issues and can result in inconsistencies of approach between sectors (agricultural and veterinary chemicals, industrials, therapeutics, food safety). More effective national policy leadership by the Commonwealth would support regulatory agencies, capture efficiencies and allow lessons learned to be more effectively communicated so industry and the community understand requirements. It would also improve and assist Australia’s engagement with international chemicals management issues, such as the Globally Harmonised System of Classification and Labelling of Chemicals (GHS).
2.2 Balancing responsibilities for managing chemical risks
It is essential that the Commission explicitly address the appropriate balance of responsibilities for management of risks associated with the use of chemicals. Relevant considerations include who should bear these responsibilities and how Australia compares with international best practice. A critical corollary issue is ensuring that adequate resources are allocated to meet assigned responsibilities.
With regard to how responsibilities should be allocated between industry, community and governments, there is an indisputable need for all levels of government to ensure risks associated with chemical use are prevented as much as possible and otherwise managed. For the most part, the burden of establishing whether a chemical meets societal expectations regarding its safety currently rests with government. For example, the current system for industrial chemicals allows industry to use chemicals that have never been subject to modern health or environmental risk assessments. It is up to governments to initiate reviews and set risk management actions where required.
This current regulatory context can be contrasted with developments overseas. For example, in the European Union (EU) the EU Parliament and Council of Ministers has enacted legislation through REACH (the Registration, Evaluation, Authorisation and Restriction of Chemical substances) which reverses the burden of proof onto chemical producers instead of the government chemical regulator.5 Another notable development includes Canada's recently completed Domestic Substances List (DSL) Categorization, which has for the first time examined information available on approximately 23,000 previously unassessed chemicals. It has identified more than 4,000 chemicals warranting further scrutiny of their potential risks to human health and the environment.
Major overseas chemical reforms such as those noted above are highly likely to impact on Australian chemicals management. There would be benefit in a clearly articulated national approach to considering and acting on such developments to ensure that Australia ‘keeps pace’ with international best practice. Australia needs to be able to both maximise our potential to influence international developments and minimise the risk of chemical market exclusion if regulatory and policy settings are not aligned with trading partners.
The Commission should specifically consider ways responsibilities could be more equitably assumed by the manufacturer of chemicals rather than by the community or government, consistent with manufacturers of other types of products.
2.3 Chemical risk assessments and data issues
Effective assessment of chemicals is essential to ensuring the benefits of their use are properly realised and negative social and environmental externalities from unforeseen consequences of use are avoided or minimised. Risks of chemical use must be properly characterised so they can be effectively managed. Use of international data can contribute to more efficient risk assessment processes.
A risk-based approach to chemicals management
NSW supports the Commission investigating ways to encourage more efficient risk assessment processes. In doing so, the Commission should have regard to the following issues:
assessment of risk involves both intrinsic hazard of the chemical and exposure. It is usually easier to obtain data on intrinsic hazard than it is to find information on exposure, which is usually commercial in confidence;
for some groups of chemicals (polyelectrolyte flocculants for instance), material safety data sheets (MSDSs) rely heavily on generic toxicity data from similar chemicals. NSW authorities have found this information to be wrong at times due to significant differences in chemical components or formulations;
community stakeholders have identified the commercial sensitivity of information as a barrier to more efficient sharing of information on chemical risks;
the risk management approach must appropriately address uncertainty (e.g. where future risks cannot accurately be assessed), ignorance (i.e. lack of sufficient data and/or the question of information we do not know we need) and indeterminacy (i.e. information we may never have) by applying a precautionary approach in order to prevent human and environmental harm and the resulting high environmental remediation and public/worker health management costs in the longer term. Experience has shown high costs may result from the inadequate management of risks (a classic example is the extended inappropriate management of asbestos until an absolute ‘causal’ link was established despite the widely recognised human health risks). Scientifically plausible emerging risks need to be responded to in a transparent, timely manner;
the need to address the challenge facing regulators and industry of finding appropriately trained/skilled staff to assess potential impacts of chemicals and develop safer alternatives. For example, there are shortages of toxicologists and ecotoxicologists;
a sustained national commitment to enhanced monitoring of the effects and fate of chemicals is needed. Existing data gaps prevent meaningful measurement and monitoring of the effectiveness of both industry self-management measures and current government regulations and compromise effective dialogues between industry, community and government; and
risk assessment processes need to comprehensively address whole of life cycle issues. For example, currently national regulators do not consistently assess the ultimate fate of chemicals in product waste streams and ultimately landfill in their decision-making. This can result in the creation of chemically contaminated waste streams that compromise industry and government resource recovery and re-use programs. Detailed examples of the implications of not fully considering the pathways for release to the environment and the ultimate fate of chemicals are provided in the Appendix.
Developments in risk management processes overseas
A case study is provided in the Appendix on the proactive approach California is currently driving to improve its chemicals risk assessment approaches and take account of some of the challenges highlighted above.
2.4 International data, information flows and access to information
Use of international data
Using international data for Australian chemical risk assessments can be a valid approach particularly for initial risk assessment work, provided it is scientifically sound and can be reasonably related to how and where a chemical may be used.
However use of data from overseas assessments without review or consideration of its relevance or transferability would not be acceptable. One of the areas where Australian data are still required is that relating to efficacy against Australian pest, weeds or diseases in the context of the Australian environment.
The movement of chemicals within the physical environment is also an area where the Australian environment has particular characteristics which are different to those overseas. Differences in soil type between eastern and western Australia, or in pest ecology between South Australian and NSW coastal citrus, make extrapolation difficult even within Australia.
The data requirements for new chemicals must continue to reflect the needs of contemporary risk assessment science and remain broadly consistent with the requirements of international regulators. Nevertheless, the fact that Australia is a climatically and biophysically diverse continent means that neither the data nor the risk assessments generated overseas will necessarily be applicable in the Australian context. This will remain problematic for Australia where the cost per unit of risk addressed is high relative to the size of the market.
The NSW Government supports Australia’s national chemical regulators cooperating internationally via bilateral or multilateral arrangements to enable access to relevant risk assessments conducted overseas (for example in Canada or the EU), in order to share information and reduce the burden of regulation on Australian industry.
Information flows, access and collection
There are opportunities to improve the flow of information, access to existing information and collection of new information that would benefit most stakeholders. Issues recommended for the Commission’s consideration include:
assessment and regulatory actions by government agencies would clearly be more efficient and responsive if the flow of information between regulators was improved. NChEM is helping to address this issue for the management of industrial chemicals that impact on the environment and any further developments should build on that framework; and
sufficient public and consumer information to allow informed choice about potential risks associated with chemicals, most notably with regard to industrial chemicals and chemicals in products.
In this regard, the National Pollutant Inventory (NPI) is a useful general information tool for basic information on some chemicals and it has been improving with time. However, because it currently only covers a small subset of chemicals and because the data is an estimation, it would be inappropriate to rely on it as a precise monitoring tool.
2.5 Meeting community expectations
The community expects to be protected from the risks of poor chemical management, to participate in decision making and to have adequate access to information about chemicals in the environment and in products.
As an example, in relation to the environment, social research demonstrates two key points. Firstly, the community expects government to protect the environment through strong regulation, and to frame these regulations with a long-term perspective. Secondly, while the community is willing to bear some of the costs associated with environmental protection, they also expect the private sector to bear costs associated with the private gains they make. Specifically, NSW research6,7 shows that:
87% of respondents express concern about environmental problems and have particular concerns about the environment future generations will encounter;
64% express a willingness to pay more to fix environmental problems;
68% consider that chemicals have quite a lot or a very harmful effect on the environment; and
75% believe that controls on using chemicals should be tightened (such as with stricter legal requirements).
Recent research8 on community views about the availability of information regarding chemicals shows:
89% want more information about chemicals and their impacts to be provided;
88% want more information about chemicals in the environment to be gathered; and
almost 90% of people think more should be done to help people make choices about chemicals.
2.6 Alternatives to ‘traditional’ regulation
NSW recognises the value of using a range of regulatory approaches – from ‘command and control’ regulatory powers to co- and self-regulatory approaches.
Self regulation and co-regulation
Co-regulatory approaches can be very successful where industry bodies have broad representation and are supported by government regulatory bodies. Self regulation schemes can also achieve good outcomes, provided industry associations have sufficient market coverage, are based on transparent and credible arrangements, participants have proven capabilities, are responsive to any concerns that may arise from the community or government and deliver agreed targets within acceptable timelines.
NSW considers that the chemicals industry has shown considerable initiative in developing stewardship programs such as Responsible Care, Agsafe, DrumMUSTER and ChemClear, which complement existing regulatory requirements and aid in compliance (for full details see .au/index.cfm?mmid=001 and .au/Home.php).
Significant resources from government and chemical user industries are committed to encouraging awareness and compliance with regulation through advisory and education programs as part of the overall compliance effort. Industry-based Codes of Practice reflect the current regulatory requirements and assist chemical users achieve compliance in a practical setting. The more effective these non regulatory strategies are, the less resources are required for enforcement.
It needs to be recognised that there are limits to what can be achieved through co- or self regulation in some circumstances and NSW experience has been that there are few alternatives to government regulation which have proven acceptable to the wider community. This was illustrated by recent experience with excess lead levels in paint on certain toy products, where it is understood that the Australian Competition and Consumer Commission moved to implement a ban, noting voluntary industry recall measures had proven insufficient to protect public health and safety in this case (there have been a number of other recent examples including diethylene glycol use in imported toothpaste).
There are also recent examples of industry calls for increased government regulatory intervention (especially to promote clarity in the market). Examples include industry calls for regulatory approaches to manage air emissions of volatile organic compounds (VOCs) from surface coatings and consumer products (see Case Study 1 in the Appendix for more detail) and calls for product safety standards.
Outcomes-based regulation already occurs
NSW acknowledges in general terms that a regulatory regime based on the achievement of broad outcomes is likely to be the most efficient and least costly for the regulated community. In reality, regulatory objectives relating to public health or environment protection are more likely to rely on a precautionary mix of output and outcomes focussed controls. Section 6.1 describes how such a mix is utilised within the NSW environment protection framework.
The Commission should also acknowledge that the current regulatory framework for agvet chemicals utilises a mix of both outcome and output focussed objectives for substantive reasons:
agvet chemicals can have both acute and chronic impacts on public health, worker safety and environment. Acute impacts are often addressed by outcomes focussed regulation because the link between action and effect is immediate and more easily identifiable. Providing that appropriate performance indicators can be set and measured at reasonable cost, outcomes based regulation provides the clearest link between regulation and the underpinning objective;
in the case of chronic impacts, the negative effects of exposure may not be obvious for some time. Process or output focussed controls are often utilised where the outcomes are too difficult or costly to measure, or where the outcome is too far in the future for effective feedback; and
in many cases, the direct measurement of outcomes - such as the rate of occurrence of a chemical related disease in the community - is unacceptable. By the time the performance of a particular suite of regulatory controls is measured, the damage has been done. Clearly, in these circumstances a range of indirect measures such as the competence of the operator, adherence to label instructions, completion of an on-site risk assessment and the use of personal protective equipment provide valuable proxies for minimising the risk of exposure.
2.7 Accurately assessing costs and benefits
Chemicals provide many benefits to society. These benefits tend to be well recognised and costed (for example through estimates of chemicals and plastics industry contributions to economic outputs etc.). The negative externalities of chemical use have tended to be less well costed and accounted for in most assessments of costs and benefits regarding regulation of the chemicals and plastics industry.
The Commission should consider the persistence of market failures in various aspects of chemicals management and the need to comprehensively consider health and environmental externalities to accurately quantify the size and incidence of costs and benefits of effective chemicals regulation.
There are two primary sources of market failure in relation to chemicals and plastics regulation in Australia: non-price excludability and information failure. Both are discussed below with examples drawn from chemical management experiences in NSW.
Non-price excludability occurs where an activity has positive or negative economic welfare effects on others who are not direct parties to the transaction and they are not compensated for these welfare changes. The inappropriate application, use, storage and disposal of chemicals may adversely affect workers, consumers, local communities, industry sectors and ecosystems. Many industrial chemicals currently in use in Australia have a growing body of scientific evidence of associated health and/or environmental risks (such as polybrominated diphenyl ether compounds (PBDEs)/ brominated flame retardants (BFRs) which are used in a wide range of products and perfluorooctane sulfonate (PFOS) a persistent organic pollutant with increasing scientific evidence of environmental and health effects). The market does not always satisfactorily account for the external costs (health and environmental) of such chemicals. Without some appropriate market signal, companies have no incentive to test, monitor and prevent long term risks and impacts since the high social costs are not always internalised or accounted for. For example:
in 2005, testing of Sydney Harbour seafood showed dioxin contamination caused by industrial activity (especially chemicals manufacturing activities in the Homebush Bay area).9 Commercial fishing was banned until 2011 with $5.8 million spent to buy back fishing licences – a significant drain on the public purse and an indication of lost commercial value from chemical contamination;10
contamination from past industrial activity in Botany Industrial Park in Sydney has resulted in massive clean up costs for government and third parties, particularly serious groundwater contamination in and around Botany Industrial Park. The principal contaminants are volatile chlorinated hydrocarbons.11 To date, $167 million has been committed to cleaning up chemically contaminated groundwater emanating from the Orica site in Botany and this represents only one of numerous site contamination costs12;
it is estimated that it will cost at least $180 million to clean up chemical contamination at Rhodes Peninsula13;
jurisdictions around Australia have expended up to $27 million in collecting and disposing of unwanted and deregistered farm chemicals under the ChemCollect program – yet consideration of end-of-life fate of chemicals and chemical disposal practices by both industry and chemical risk assessors is often limited; and
a 2004 study by the University of Ontario demonstrated that pesticide exposure is associated with increased risk of developing cancers; chromosome aberrations; immune-system irregularities; Parkinson’s disease; neurological impacts and reproductive problems (including birth defects).14 Even for more minor effects, an individual suffering a headache or migraine associated with pesticide exposure may lose a day’s work, pay money to visit the doctor and buy pain-killing medication which could have an economic cost close to $190 per person.15
Information failures occur where there is insufficient or inadequate information about such matters as price, quality, safety and availability for firms, investors and consumers to make informed decisions.16 There is often limited biophysical and economic data available to measure the social, environmental and health benefits and costs of implementing regulatory changes in chemicals management. A complete analysis of costs and benefits of chemical use and their impacts is often inhibited by the complex nature of their toxicity, the manner of their use, whether solely, or in combination, the potential impact on, for instance, complex ecosystems and human health, the long time lags between the application of chemicals and potentially adverse impacts, and the diffuse nature of chemical use in products and its application.
Complex dose-response functions may mean that cause-and-effect relationships between chemical use and their impacts on human health and the environment are not always clear, there are often confounding factors (or other health impact triggers) and often may only be established over time. Consequently, there is likely to be a high financial cost in determining the toxicity of chemicals and their impact on ecosystems and human health.
A particular form of information failure in chemicals management is information asymmetry, such as:
where consumers have difficulty in verifying or assessing producer’s claims that products are healthier or have been produced using environmentally friendlier production methods. Consumers have no way of cost-effectively assessing such claims themselves;17
in the case of consumer products, many of which provide no information about their chemical composition; and
between new and ‘existing’ chemicals (where the latter have been ‘grandfathered’ and thus not undergone the same level of assessment for health, safety and environmental risks), which constitutes a barrier to the substitution of potentially less harmful chemicals as introduction of new chemicals requires a modern risk assessment process.
The Commission should consider how the ongoing information uncertainties (that may not ever be wholly overcome) should best be handled by industry, governments and the community in chemical risk management decision-making, making it impossible for consumers to exercise judgement or make informed decisions.
Concerns about best use of information within chemical management settings are common to all international and domestic chemical management regimes. The European Environment Agency (EEA) has looked in detail at this issue in a report entitled Late Lesson from Early Warnings. This report uses specific real world case studies to identify the costs and benefits arising from the use and non-use of early warning information in managing risks. The report concludes that “regulatory appraisal and control of technologies and economic development involves balancing the costs of being too restrictive on innovation with the hazards and costs of being too permissive, in situations of scientific uncertainty and ignorance. The cases studies provide many examples where regulatory inaction led to costly consequences that were not – and sometimes could not have been – foreseen.”18
International analysis of costs and benefits in chemicals regulation
The EU undertook comprehensive impact assessment and cost benefit analyses over an extended time period prior to the introduction of REACH. There is a range of other useful international references on costs and benefits associated with chemicals regulation.19
The issue of health and environmental costs/externalities resulting from the inappropriate or inadequate management of chemicals, as well as analysis on the implications of market failures, has also been comprehensively explored in a recent academic report in California. A brief summary of the key points from this analysis is provided in the Appendix.
2.8 The case for limited State and Territory regulatory variation
NSW supports the Commission investigating opportunities to enhance the uniformity of the regulatory systems operated by States and Territories. However NSW considers it essential that jurisdictions retain the ability to take local conditions and within-jurisdictional simplification and streamlining initiatives fully into account in developing any revised regulatory system and to respond in a timely manner to local industry and community needs.
The Commission’s attention is drawn to the following NSW examples:
NSW has introduced mandatory training and record keeping requirements for all persons who use pesticides in their work or business, and requires certain users to provide notice of pesticide use. These reforms were overseen by the broadly representative Pesticides Implementation Committee with extensive industry and community consultation. These requirements are key tools to prevent pesticide misuse and most NSW stakeholders would not support wind-back of these requirements in the name of national uniformity;
To help simplify and streamline requirements affecting chemical industries and regulation of waste, the NSW Government is increasingly aligning regulatory parameters across portfolios. For example, requirements for environment protection licensing (draft amendments to the thresholds and categories for industries that are licensed under the NSW Protection of the Environment Operations Act 1997 are currently subject to public consultation) aim to be as consistent as possible with requirements under development assessment and other regulatory systems. It is important that these within-jurisdiction improvements are not compromised by centrally-imposed constraints which apply only to a single specific area; and
It will always be necessary to introduce jurisdiction-specific requirements for some agvet products to accommodate unique environments, community needs, climatic regions or a particular mix of physical, biophysical and social factors. For example, some States have restricted the application of certain herbicides (such as 2-4-D esters) to particular times of the year to avoid damage to crops that may be more sensitive to herbicides at that time. In other States, similar provisions, while available in legislation, have not been implemented because the particular mix of risk factors has not been present and the imposition of such a restriction is not justified.
At a recent roundtable discussion chaired by NSW regarding the options for linking environmental recommendations being made by NICNAS with State and Territory on-ground actions, all stakeholders recognised and supported the need for exemption provisions in any regulatory system. They also noted that such provisions, and the processes for their implementation, should be clearly and transparently set out, based on robust criteria and include an opportunity for review.
2.9 Consultation processes
Transparent and inclusive public consultation processes are an important part of an effective chemicals and plastic management regime. A number of improvements could be made to existing consultation mechanisms. The Commission should consider more effective public consultation mechanisms, such as greater use of the internet for public dialogue and feedback on chemicals issues (as occurs in California).
The NSW Government supports greater involvement of indigenous communities in chemicals/plastics management. Chemicals management decisions have the potential to affect Aboriginal owned land and Aboriginal communities and targeted consultation strategies are needed. This would align with the NSW Government’s activities for involvement of, and consultation with, indigenous communities in other environmental/government decision-making processes. For example, the NSW Government currently engages indigenous communities on issues such as waste management and illegal dumping. NSW suggests the Commission consult specifically with representative Aboriginal bodies, such as local Aboriginal Land Councils, to ascertain how and on what issues Land Councils might want to be consulted.
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