The HSNO Act has been amended to improve its workability and make it easier for people to know what their obligations are with hazardous substances. Part of this reform is the development of EPA Notices.
These documents will allow us to simplify the key requirements set under the HSNO Act. They’ll also allow us to consolidate and update requirements that are currently spread across regulations, transfer notices, individual approvals and group standards. Notices will be approved by the EPA Board rather than going through Cabinet as required for regulation changes. This will allow the notices to be updated more easily than regulations and to be kept up to date with international developments.
We have undertaken three consultations on proposals for notices.
1. Manufacturer and importer information requirements
One of the most significant changes for the EPA that resulted from the amendments to the HSNO Act is that we will soon have a new enforcement role which includes responsibility for:
- enforcing compliance with labelling, safety data sheets, packaging and product content controls
- enforcing compliance with the prohibitions on persistent organic pollutants
- ensuring each hazardous substance is covered by a HSNO approval.
To support this new role people who import or manufacture hazardous substances must supply us with their correct contact information.
Please note: the period for submissions and feedback closed 28 April 2015.
We received 39 submissions on the proposal. The notice was issued in November 2015.
2. Classification system, labelling, safety data sheets and packaging
We released one consultation document covering four proposed notices:
- hazard classification system
- safety data sheets
The document proposed aligning the HSNO hazardous substances classification system and controls more closely with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). We also proposed implementing the GHS in a way that is consistent with how it has been implemented by our major trading partners.
Please note: The period for feedback and submissions closed on 20 February 2015.
We received 80 submissions on this consultation.
We are now considering the submissions. We expect to progress these notices soon.
3. Enforcement officer qualifications
The enforcement officer qualifications consultation document provided proposals for changing the requirements for hazardous substances enforcement officer qualifications under HSNO. We suggested simplifying the current qualification requirements and basing these on competency and experience. We also proposed removing the requirement that prospective officers need to work under the supervision of a HSNO enforcement officer for a specified period of time. We did not suggest any changes to the new organisms enforcement officer qualifications.
Please note: The period for feedback and submissions closed on 9 February 2015.
We received 10 submissions on this consultation.
We are hoping to publish the Enforcement Officer Qualifications Notice soon.
If you have questions about our notice proposals you can email us at firstname.lastname@example.org.