The HSNO Act interfaces with the Resource Management Act, the Agricultural Compounds and Veterinary Medicines Act, the Food Act and others. There are several and varied issues with these interfaces. Some are addressed by other proposals in the strategy. For example, a person would not need to get approvals from both the New Zealand Food Safety Authority and ERMA for a low risk situation veterinary medicine if a standard was issued that covered the relevant substance. However some issues we have not addressed. For example environmental exposure limits do not sit comfortably with site specific discharge permits issued by regional councils under the Resource Management Act. Environmental exposure limits are difficult to set, monitor and enforce.
Future work for MfE
We have not considered these issues in detail at this point because we felt our time was better spent on other parts of the system at this time. However we think they are important issues to address as part of the longer-term work programme. We therefore propose that the Ministry for Environment include measures to address these issues in the regulatory proposals due to be put to Ministers in October 2003.
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9. Improve Regulatory Interfaces
June 2003
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