Response to feedback on technical details of reforms
Last update 17 August 2017
Following is our summary of feedback received on technical aspects of the reforms:
- Overview of reforms feedback
- Part 1: Amendments to technical detail following feedback
- Part 2: Feedback not resulting in amendments to the technical details
Overview of reforms feedback
The NICNAS reforms have had ongoing and robust feedback from industry, community and the regulatory sector since 2015.
The consultation process has asked for feedback on a variety of issues including the best way to implement the reforms.
All feedback is valuable and we would like to thank our stakeholders for their comments and suggestions.
Following the release of an implementation plan and 4 consultation papers, we have received and reviewed 148 submissions on these documents.
We have held 8 public workshops so far with over 350 participants. These workshops focused on the proposed regulatory framework. Participants were from industry, the community, academia and the regulatory sector.
This page covers stakeholder feedback received to date about the technical details of the reforms, and describes how this feedback has informed the development of Consultation Paper 5. It does not address stakeholder feedback related to primary legislation.
Stakeholder views on the reforms have varied between and within industry and the community.
We have adjusted the proposed implementation approach to accommodate the views of stakeholders, where views are in keeping with the Government decision about the purpose of the reforms.
Part 2 outlines feedback on technical details that we have not changed. In these cases, if possible, we have prepared an alternative proposal. These alternative proposals aim to address (or partially address) stakeholder concerns.
Reasons for not including changes suggested by stakeholders include:
- the proposals were not consistent with the Government decision or were inconsistent with fundamental objectives of the reforms
- the proposals were not consistent with criteria for the adoption of international standards and risk assessment set by portfolio Ministers
- when we received polarised suggestions and needed to consider competing interests.
We do not directly refer to all stakeholder feedback here.
We are still considering some stakeholder feedback. This is generally for matters that do not have an impact on the proposed delegated legislation. We will look at this feedback again when developing the Characterisation Guide and/or guidance materials. (See Consultation Paper 5 for detailed explanation).
Examples of this include stakeholder feedback about:
- Developing well-defined default release factors for use when determining the Exposure Band for the environment.
- The use of analogues.
- Appropriate sources of information to address categorisation and assessment requirements of unlisted chemical introductions (we will provide more information in guidance materials which we will consult on later in 2017).
- Evaluations initiated by the Australian Industrial Chemicals Introduction Scheme (AICIS) (we will commence consultation on the evaluation framework and guidance later in 2017).
 See Consultation Paper 5 Supporting Material for more information.