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Strategy for Improving the Workability of Hazardous Substances Provisions of the Hazardous Substances and New Organisms Act

  1. Introduction
  2. Summary of Strategy
    • Short-term actions: deliver on promises to establish some credibility
    • Longer-term actions: change HSNO to improve workability
  3. Background
    • Asked to improve workability of HSNO
    • Process applied to develop the strategy
  4. Key Elements of a Strategy to Improve Workability
    • Vision
    • Principles adhered to
    • Five key elements
  5. Sound Compliance Monitoring and Enforcement Arrangements
    • Situation
    • How
    • Give ERMA stronger directing and co-ordinating role
    • ERMA addresses local coverage
  6. Simplify Transfer
    • What is transfer?
    • Transfer needs to be streamlined
    • ERMA needs flexibility for practical solutions
    • How
    • Priority
    • Subsequent benefits
  7. Remove Redundancy and Cost from the Hazardous Substance Approval Process and Management System
    • Situation
    • New method to transfer notified toxic substances
    • Situation – not risk based
    • How – risk based
    • Situation – individual approvals for similar products
    • How – use ‘generic’ approvals
    • Situation – costs of approvals seen to be too high
    • How – reducing costs to business
  8. Make Controls Understandable for Users and Enforcement Officers
    • Situation
    • Opportunity
    • How
    • How in the short term – guidance
    • How – conditions on approvals
    • How – standards
    • How – a simple code of practice approval process
    • Subsequent benefits
  9. Improve Regulatory Interfaces
    • Future work for MfE
  10. Conclusion
  11. Summary of Recommendations
    • Short-term actions: deliver on promises to establish some credibility
    • Longer-term actions: change HSNO to improve workability