Final Report of the HSNO Industry Review Group(Letter to Minister for the Environment, 29 July 1999)Earlier this year a number of individual companies and industry organisations came to you with concerns about how implementing the HSNO Act might affect their businesses. The ERMA Industry Consultative Group (ICG) responded to your invitation to specify the concerns raised by forming a technical expert group to review the specifications for regulation as well as advise on other technical aspects. The NZ Chemical Industry Council, with the agreement of the ICG, undertook to organise the meetings of the Group and NZCIC member companies have provided the venues. You will recall that in March this group presented a preliminary report recommending:
In the intervening 3½ months the Ministry for the Environment has done an enormous amount of work, assisted by Group members. This has included technical information provided by international chemical companies which brought valuable expertise to the discussion. I am pleased to report that the concerns raised in he Group’s earlier report to you have been largely allayed and we believe that with a minimum of fine tuning, New Zealand companies with international associations will be able to work comfortably within the regulations. The other major concern expressed at the first meeting was that large amounts of data not generally available elsewhere would be required in order to determine both whether or not a substance was hazardous (and so within the scope of the Act) and how to control it. This was regarded as particularly significant for ecotoxic effects. ERMA New Zealand was able to assure the group this information will only be required if it is available internationally. Drafts of documents setting out acceptable methods of estimating and extrapolating data were considered by the Group which concluded that the development of these into formal documents as either Codes under the Act or ERMA Protocols. The principle that in the absence of toxic and ecotoxic data, the substance may attract more severe controls was also accepted by the Group. -2-In the matter of whether the Act should start up the Regulations before the HSNO Amendment Bill is passed, the feeling is that the members did not get from the meeting sufficient background and briefing on the likely outcomes of the alternatives to make a sound decision. I have therefore asked the group to reconvene for the Ministry for the Environment and the ERMA to brief us specifically on this. I will report the group’s views to you as soon as possible after that meeting which I anticipate will be within the next two weeks.The group confirmed our willingness to continue our consultative role, given the constraints of work commitments. The members feel that the experience of participating in this group has given them a depth of knowledge of this legislation which will prove extremely useful in any future discussions.Our report with recommendations is attached. Yours faithfullyA.J. Haggerty Go here for the report of the second meeting of the Industry Review Group advising on the HSNO Act implementation
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