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11. Summary of Recommendations

Short-term actions: deliver on promises to establish some credibility

We recommend that compliance monitoring and enforcement is a high priority for the strategy. We propose that:

  1. ERMA takes a more directive role in compliance monitoring and enforcement.

Transfer of substances into the HSNO regime has been promised for sometime but not delivered on. Transfer is relatively easy to address, will improve the HSNO Act’s workability and consequently restore some credibility to it. To get transfer back on track, we recommend that:

  1. Explosives are transferred in July/August 2003.
  2. Control regulations are completed this year.
  3. The transfer process is simplified.
  4. ERMA is enabled to apply use controls and to substitute new controls for the default controls in the HSNO regulations.

We propose that short-term easy gains can be made by two non-regulatory steps: one to make HSNO controls easier to understand and two to reduce compliance costs for applicants. We recommend that:

  1. User-friendly guidance be developed to interpret the HSNO controls for businesses.
  2. ERMA take steps to reduce the information provision costs for applicants.

Longer-term actions: change HSNO to improve workability

We propose that ERMA be given new tools to remove redundancies from the HSNO system and better link HSNO to how everyday people use products with hazardous properties. We consider that with new tools, ERMA can take advantage of the opportunity that transferring 70,000 toxic substances provides to simplify the whole HSNO regime. We believe our proposals will have a significant impact on improving compliance with the HSNO regime and remove unnecessary compliance costs. We recommend that:

  1. The Ministry for Environment prepares papers for ministers by October/November 2003 on new tools for ERMA including:
    • the use of conditions on approvals and standard sets of controls;
    • a quick and largely automatic low risk pathway for substance transfer and approvals; and
    • ‘generic’ approvals for key groups of similar products that attract the same controls. This will reduce the number of new substance applications necessary.

We also propose that in October/November 2003, the Ministry for Environment report to ministers on proposals to:

  1. Change HSNO to clarify the role of ERMA, territorial authorities and regional councils with respect to compliance monitoring and enforcement.
  2. Address gaps and overlaps between HSNO and other legislation.
  3. We further recommend that the Ministry for Environment review the effectiveness of the strategy on the issues identified two years after strategy implementation and substance transfer is completed.
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