NewsBrief
Issue No.52 June 2006		TM

D- DAY! (Decision Day) 01 July 2006

The last day for replacing your obsolete Dangerous Goods (DG) Licence with the new and exciting 21 st century Location Test Certificate, is 30 June 2006.

The 01 July 2006 deadline poses and interesting challenge for chemical Suppliers – does one continue to supply hazardous substances to a customer who is known not to have the required Test Certificates?

Indications are approximately 55% of DG Licences have yet to be renewed with Location Test Certificates. It is argued that where a customer is “wait listed” by a Test Certifier who has not yet paid a visit, deliveries should continue until the site obtains the necessary Certification. Equally, if remediation work is required, deliveries should not be interrupted until Certification is complete.

Nor is there much comfort to be derived from the many calls to the NZCIC requesting advice about long-overdue, basic compliance issues, such as correct site signage.

These arguments conveniently overlook the fact delinquent companies will have had at least two years (and countless reminders) to obtain Test Certificates, review site signage, and upgrade Safety Data Sheets.

If ever there was a time for chemical Suppliers (whether NZCIC Members or not) to adopt a strong and united response to compliance, that time is now! Declining to supply hazardous substances for health and safety reasons is justifiable, certainly in the context of the global chemical industry’s Product Stewardship initiative. Such an action would not only protect workers, but would also provide a massive stimulus to compliance!

Regrettably, what should be a relatively straightforward decision for “Responsible Suppliers” is being undermined by unethical competitors. The Council is aware of one Member’s warning to suspend deliveries of a high-risk product to a site without the required Test Certificate and Approved Handlers, being compromised by competitors offering their product.

Non-compliant site operators are jeopardising their insurance cover and setting a poor example for our peers, critics, and the authorities. Persistently failing to meet your legal obligations makes a mockery of our industry’s claims about effective self-regulation and voluntary compliance.

Most importantly, it places people in harm’s way.