PDF printable version of Department of Health, Victoria submission (PDF 65 KB)
Manager Environmental Health Program
03 9096 5105 Ph
03 9096 9182 Fax
50 Lonsdale Street
MELBOURNE VIC 3000
GPO Box 4541
MELBOURNE VIC 3001
The Department of Health Victoria (the department) supports the 2011 Australian Government decision to review the National Industrial Chemicals Notification and Assessment Scheme (NICNAS) and is pleased for the opportunity to comment on this discussion paper dated June 2012.
The department notes that the roles of current chemical regulatory bodies can be confusing at times especially in relation to policy setting and risk communication. Clarifying the roles and responsibilities of each agency (for example NICNAS, the Department of Health and Ageing (DoHA), the Office of Chemical Safety and Environmental Health, the Australian Competition and Consumer Commission (ACCC) and state and territory risk managers), with the intention of refining legislation if necessary, should allow for all chemicals to be appropriately managed in relation to public health and the environment.
Additionally, the interface between NICNAS, the Therapeutic Goods Administration (TGA), the Australian Pesticides and Veterinary Medicines Authority (APVMA) and Food Standards Australia New Zealand (FSANZ), should be tightened to ensure that roles are clearly defined to limit the circumstances whereby chemicals may fall in between agency jurisdictions.
In regards to new chemical assessments, the department supports reform options which provide a more efficient and consistent assessment process, however, the overall assessment of public health risk should not be compromised. If NICNAS continues to utilise overseas chemical assessments, it would be essential for NICNAS to retain the authority to analyse the assessment in relation to the Australian context, to ensure that Australia’s unique population and environment are sufficiently considered.
The Priority Existing Chemical (PEC) assessment reports produced by NICNAS provide a comprehensive assessment of existing chemicals and an essential basis for understanding the potential risks to public health. The department agrees that NICNAS PEC and new chemical assessment report findings and recommendations should be considered in an effective and timely way to minimise the opportunity for gaps in regulatory controls. More developmental work is required on the mechanism(s) whereby the relevant standard setting bodies or risk managers could be formally required to respond to NICNAS assessment recommendations.
Any change to the current regulatory functions of NICNAS should not result in duplication with existing risk management mechanisms or create regulatory gaps that reduce the current level of public health, occupational health and safety or environmental protection. Such changes require careful consideration, consultation and thorough regulatory impact analyses.
The department welcomes any further opportunity to comment on the review of NICNAS and is committed to remain engaged in this process. For any enquiries, please contact Ms Sandra Falconer, Manager Environmental Health Program, Department of Health Victoria, on 1300 761 874.
A full list of all 2012 submissions can be viewed at June 2012 submissions to the review of NICNAS