CRIS 2018-19 — Attachment 1 Summary of stakeholder views and NICNAS responses

IssueStakeholder commentNICNAS response
Indexation of fees for services
  • Proposed indexation of 2.3% is not supported
  • The Departments of Health and Environment and Energy wage increases are 2% and 1%, respectively
  • Recent Consumer Price Index (CPI) quarterly increases are less than the annual increase for 2017, which is nearly 2 %

NICNAS notes stakeholder views.

The proposed indexation of 2.3% is based on the weighted average annual indexation of Wage Price Index (WPI) – public sector group - and CPI – all groups.

Increase in registration fee

  • The proposed increase of $56 per registrant is not supported because this equates to approximately $1 million per annum to maintain a database of 6,000 registrants

NICNAS notes stakeholder views.

The registration fee has not increased in four years. The increment of $56 per registrant is necessary to recover the actual cost of maintaining the Register of Industrial Chemicals Introducers and undertaking all registration-related processes in 2018-19, in accordance with the Cost Recovery Guidelines.

Increase in registration charges (Registration levels B-D)

  • The proposed 5% increase in registration charges is not supported
  • Additional effort required to deliver regulatory services should result from productivity improvements and not increases in registration charges

NICNAS notes stakeholder views.

In accordance with the Australian Government Cost Recovery Guidelines, the CRIS estimates registration charges based on the full cost of regulatory services funded through the charge.

The Australian Government has decided to defer commencement of the new Australian Industrial Chemicals Introduction Scheme (AICIS) until 1 July 2019. Therefore, reforms-related expenditure and revenue are not aligned on a yearly basis. The overall recovery of costs for these activities is aligned over a longer period.

NICNAS reserves
  • The cumulative balance in the reserves has increased significantly in recent years
  • This over recovery of funds demonstrates that the overall budget assumptions used by NICNAS are conservative
  • Given the strength of the reserves, an increase in fees and charges is not supported

NICNAS notes stakeholder views.

The reserve is required as a risk mitigation measure to allow the scheme to continue to operate in the event that there is a shortfall in income and to avoid a subsequent adverse impact on the Australian Government’s budget position.

Funds held in the reserve provide for business continuity, future capital projects and for the resources required for the implementation of the new Scheme over a longer period than originally anticipated (refer above).

Reduction in regulatory costs to industry

  • It is difficult to assess if the expected reduced costs will materialise in forward years given the complexity of the proposed new scheme
  • All that industry can see the reform process is increased costs

NICNAS notes stakeholder views.

The new regulatory scheme is designed within the policy parameters agreed by Government.

It is noted that the Regulatory Burden Measurement Framework excludes direct financial costs, such as fees and levies payable to government from regulatory costs (https://www.pmc.gov.au/sites/default/files/publications/005_Regulatory_Burden_Measurement_Framework.pdf).

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Last update 9 August 2018