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4. Key Elements of a Strategy to Improve Workability

Vision

The following describes the features of hazardous substances management that are being sought through development of the strategy.

  1. A cost-effective risk-based management regime where:
    • the costs of preparing an application, including the level of supporting data;
    • the costs of getting an application assessed and approved;
    • the time it takes to get an approval;
    • the number and level of controls; and
    • the intensity of the compliance monitoring
    are related to the risks posed by a substance or group of substances.
  2. Hazardous substances without a HSNO approval are not allowed into the country.
  3. People using hazardous substances are familiar with the hazards and know what they need to do to reduce adverse effects. People find it easy to learn what they need to do to comply with the HSNO Act.
  4. Businesses who wish to use innovative ways of complying with the HSNO substance controls can.
  5. An expert, trusted and pragmatic agency (ERMA) is empowered to be flexible in undertaking its responsibilities.
  6. There is risk-based, co-ordinated, comprehensive and consistent compliance monitoring across the country. Voluntary compliance is recognised and encouraged. Information on locations of significant quantities of hazardous substances and their users is available at a national level.
  7. There are enforcement officers familiar with hazardous substances and areas of risk at a local level.
  8. There are hazardous substance emergency response agreements for all parts of the country.
  9. Inspection visits by regulatory agencies are co-ordinated to minimise interruptions and associated costs for business.
  10. There are minimal gaps, overlaps or inconsistencies with other pieces of legislation.

Principles adhered to

A number of key principles that underlie the Act were considered necessary to preserve in the strategy development process, i.e.

  • the current precautionary approach of the Act;
  • the use of the ‘globally harmonised system’ of hazardous substance classification and labelling controls to help achieve international consistency;
  • the current opportunity for public input for higher risk substance approvals; and
  • the flexibility that the performance-based approach to hazardous substance controls provides.

The other features of the HSNO Act, such as monitoring of the effectiveness of the Act, opportunity for reassessments, promoting awareness of the adverse effects of hazardous substances, using international best practice are maintained.

Five key elements

Five key elements were identified for improving the workability of the hazardous substances provisions. These are summarised as follows and form the foundations of the proposed strategy.

  1. Sound compliance monitoring and enforcement arrangements – ensure that compliance monitoring and enforcement arrangements demonstrate effective risk management.
  2. Simplify transfer – ensure that the HSNO transfer process is practical, clear and timely.
  3. Remove redundancy and cost from the hazardous substance approval process and management system that does not add to the protection of the environment, and the health and safety of people and communities, reducing barriers to the introduction of new hazardous substances used in low-risk situations.
  4. Make controls understandable for users and enforcement officers – ensure hazardous substances controls are practical, clear and cost effective, and that there are accessible means to secure understanding and compliance for enterprises.
  5. Improve regulatory interfaces – programme further work to address the interface between HSNO and other legislation including the RMA, the ACVM Act, Health Safety and Employment Act, the Building Act, and the Food Act.
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