We are seeking your view on proposed improvements to assessments and reassessments of hazardous substances. We have prepared a discussion document that sets out the policy proposals. This document can be found on the Ministry for the Environment's website: [url=https://www.mfe.govt.nz/publications/hazards/hazardous-substances-assessments-improving-decision-making-%E2%80%93-discussion]https://www.mfe.govt.nz/publications/hazards/hazardous-substances-assessments-improving-decision-making-%E2%80%93-discussion[/url]. We recommend you refer to the discussion document when completing your submission. Notes boxes are provided under each question for your comments. Supporting documents may also be attached at the end of the form. Please fill in the form below, then click Continue to review your submission. At any time you may click Save and Exit so that you can return later.

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Proposal 1: Making better use of international information
1. Do you agree that the EPA should make better use of international information during assessments and reassessments of hazardous substances? If so, how?
2. Do you agree with the criteria for defining who is a trusted regulator (see section 2.1.1 of the discussion document)? What other criteria should we consider?
3. Do you agree with the proposed principles and considerations of using information from trusted regulators (see section 2.1.1)? What other principles should we consider?
4. Which jurisdictions/agencies do you think we should regard as trusted regulators? Why?
5. What information should we regard as trusted?
6. Which options do you support for using information from trusted regulators for assessments of new hazardous substances? Why?
7. Which options do you support for using information from trusted regulators for reassessments of existing hazardous substances? Why?
8. Should the requirements for applying trusted regulators' information for the initial assessment to introduce a chemical to the New Zealand market be any different to a reassessment (see section 1.2 and 2.1)?
9. Do you suggest another option? If so, please explain.
10. When applying information from a trusted regulator, should the New Zealand context always be considered? (This is currently a requirement in the HSNO Act).
11. Are there any other issues with using information from international regulators that the discussion document has not covered?
Proposal 2: Immediate suspension based on trusted information
12. Do you think the current threshold for suspension is appropriate (that is, significant actual or imminent danger to human health or safety or the environment from the continued use of the substance – see section 3.1.2 – ‘The problem’)? Why/why not?
13. Does the current suspension apply at the right time in the process (that is, after a reassessment decision has been publicly notified – see section 3.1.2 – ‘The problem’)? Why/Why not?
14. Do you agree in addition to a suspension, a temporary restriction is also needed?
15. Which option do you support? Why?
16. If you choose Option 2, do you have any suggestions on change to the criteria or threshold for the EPA to suspend or temporarily restrict an approval?
17. If you choose Option 2, what are the potential impacts of a temporary restriction or suspension?
18. If you choose Option 2, what can be done to reduce the negative impacts of a temporary suspension or restriction on the industry and end-users?
19. Do you suggest another option? If so, please explain.
Proposal 3: Using a trusted regulator’s decision to change a hazard classification
20. Do you agree with the description of this issue (that is, it is not necessary for the EPA to always follow a modified reassessment process to change a hazard classification based on trusted information – see section 3.1.3 – ‘The problem’)? Why/why not?
21. Should the EPA be able to adopt a trusted regulator’s decision to change a hazard classification? Why/why not?
22. Which option to change a classification based on trusted information do you support? Why?
23. (If you choose Option 2 or 3) The EPA is planning to update the HSNO classification system to align with the Globally Harmonized System of Classification and Labelling (GHS). While this update is taking place, the EPA needs to verify the GHS classification with an HSNO classification. Should the EPA be able to adopt a trusted regulator’s classification change before the update is complete? Why/why not?
24. Do you suggest another option to change a classification based on trusted information? If so, please explain.
Proposal 4: Better consultation process to collect quality information
25. Do you agree with the description of this issue (that is, the current voluntary mechanism cannot help the EPA collect quality information for reassessments – see section 3.2.1 – ‘The problem’?) If not, why not?
26. What would motivate people to give more comprehensive information for a reassessment?
27. Which option do you support? Why?
28. Do you suggest another option to collect quality information? If so, please explain.
29. Should the EPA have the discretion to decide what a ‘lack of information’ means or this needs to be prescribed in the HSNO Act/regulations? Why/why not?
30. Do you find there are barriers when applying for a reassessment? If so, what are they?
Proposal 5: Amending modified reassessments for a more targeted consultation
31. Do you agree that the current modified reassessment process does not allow flexibility in consultation? If you don’t agree, why not?
32. One option is to allow the EPA more flexibility in consultations, that is, a more targeted consultation. Would you support this?
33. Do you suggest another option? If so, please explain.
Proposal 6: Avoiding duplication when reassessing priority chemicals
Proposal 7: Avoiding duplication when assessing new and existing substances
Proposal 8: Updating controls of existing substances
46. Do you agree that controls on existing substances should be updated quickly, to align with a more recent assessment? Why?
47. Which option do you support, and why?
48. Do you suggest another option? If so, please explain.
Other considerations to enable change
49. Should a process for updating controls be introduced as described in section 3.4? Why/why not?
50. Should EPA staff (rather than a decision-making committee) have the power to make decisions, if the change is purely technical? Why/why not?
Any other comments?