Consultation, documentation

In addition, the DoE proposed EQSs in a 1991 consultation document for those pesticides on the Red List (the UK s original priority hazardous substances list). Although non-statutory, the Government is committed to the reduction of Red List Substances discharging to the North Sea and the NRA uses the standards to assess the effects of these substances on the environment and to derive consents for point source discharges of these compounds. Failures for agricultural pesticides are rare. 

The original intention of the consultation document (a. 11) was that polymers would have to be registered, but an outcome of the Internet consultation was that... 

A Chemical Safety Report (CSR) is required for substances registered at 10 tonnes per annum (i.e., with Annex VI data). The burden on industry has been eased in the final proposal (a. 12), because in earlier drafts, such as the consultation document (a. 11), a CSR would have been needed for all registered substances. 

AUSFTA through a working group established by the Minister for Health to advise on the implementation of Australia s commitments. In July 2004 the Minister released a public consultation document, which outlines the proposed independent review mechanism and describes principles to support the implementation of hearings before the PBAC and for enhancing transparency of PBAC recommendations. Further work is required to enable these changes to be implemented. 

DEFRA] Department for Environment, Food and Rural Affairs. 2006 April. The air quality strategy for England, Scotland, Wales and Northern Ireland. A consultation document on options for further improvements in air quality, volume 1. London. 

Source Reprinted from Health Canada, Health Protection Branch consultative document on draft proposals-sub-jects (1) fortification of flour and pasta with folic acid, (2) harmonization of flour enrichment with the United States of America, (3) optional enrichment of flour. 

Revised Business Impact Assessment for the Consultation Document, Working Paper 4 - prepared for the European Commission Environment Directorate-General, Risk and Policy Analysts, London, 2003, p.92. 

GAMP Forum (1999), Complying with 21 CFR Part 11 Electronic Records and Electronic Signatures, First Draft Consultative Document to Solicit Feedback, December. 

Health and Safety Commission, "Control of Industrial Major Accident Hazards -Draft Regulations and Guidance", Consultative Document, Health and Safety Executive (1983) "Control of Industrial Major Accident Hazards Regulations 1984", Health and Safety Executive (1984). 

Extensive information concerning the development of the UK NAP, including intermediate proposals and consultation documents, is available online at www.defra.gov.uk/environment/climatechange/trading/eu/nap/dev.htm. 

HSC (2002) Consultative Document CD181 Issued February 2002 Published by HSE (Health and Safety Executive) Books (UK). 

Based on these conclusions a Consultation Document was published that made proposals to introduce a new OEL Framework (HSC 2003) that was a combination of the second and third options described in the Discussion Document. It reiterated the belief that many employers, particularly in small firms, did not know about OELs and of those that did, very few understood how to work out whether the chemicals in the air at their workplaces were above or below the relevant OELs. Because of this and other work on small firms it argued that a new approach was necessary. It advocated the replacement of the two types of OELs that had been in use since the mid-1980s (the OES and MEL) with a single type of OEL to be known as a workplace exposure limit (WEL). Employers would be required to ensure that the amount of chemical in workplace air did not exceed the WEL. However, since it was recognised that only for very few chemicals was there sufficient information to be able to say with certainty that harm would not occur to anyone exposed at the WEL, it was not possible to regard them as safe limits . Since it was essential that such uncertainties be accounted for in any system that aimed to protect workers properly a new COSHH Regulation 7 (7) replaced the COSH 2002 Reg. (7) and 7 (8). It stated ... 

To deal with the issue of employers understanding, the consultative document proposed ... 

However, although WELs would be useful in determining benchmarks for certain substances and their breach indicate a substantial risk gap which by definition would anticipate some form of enforcement action, the Consultative Document also made clear ... 

To understand the statements on enforcement in the Consultative Document they need to be viewed in the context of existing evidence on the role of OELs in inspectorate strategies seeking compliance with regulatory measures on risk management for hazardous substances. These in turn need to be understood within the context of evidence on the role of enforcement generally in health and safety in the UK. 

See for exanq)le the Consultative Document on this strategy (HSE 2004a) and the HSE statement on providing accessible advice and support , www.hse.gov.uk/aboutus/plans/ index/htm. 

That such notions are not merely a reflection of the protectionist approaches of professional interest groups is indicated by the expression of similar concerns by the Engineering Employers Federation (EEF), which according to Allen (2004 9) noted in response to the Consultative Document on the OEL framework, that ... 

HSC (2003). Proposals to introduce a new occupational exposure limits (OEL) framework. Consultative Document, Sudbury HSE Books. 

HSE (2004a). Regulation and recognition towards good performance in health and safety. Consultative Document, HSE Bootle. 

As an example of this implementation by a Member State, the UK has developed a scheme which is consistent with these Directives and is described in the Chemicals (Hazard Information and Packaging for Supply) Regulations (CHIP 2). These Regulations (which are currently at the Consultative Document stage) implement the above Directives and their Amendments and Adaptations as well as the Safety Data Sheets Directive (93/112/EC). 

Health and Safety Executive (HSE) (1994), Draft Proposals for the Chemicals (Hazard Information and Packaging for Supply) Regulations (CHIP 2) - Consultative Document, HSE, London. 

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