Peter W. Tait, PHAA member
In the past five years Australia’s agricultural, veterinary (agvet) and industrial chemical regulation has undergone a series of reviews and reforms. The purpose of these has been to reduce the regulatory burden on manufacturers, importers, and industry while retaining protection of the environment and human health.
Industrial chemical regulation falls under the purview of the Australian Industrial Chemicals Introduction Scheme (AICIS) and agvet chemicals are regulated by the Australian Pesticides and Veterinary Medicines Authority (APVMA). AICIS replaces the National Industrial Chemicals Notification and Assessment Scheme (NICNAS). The APVMA reform continues.
In 2021 the Public Health Association of Australia, with students from the Australian National University Medical School, undertook a comparison of Australia’s chemical regulatory system to regulation in comparable countries, specifically the USA, Canada and the European Union. The aim was to assess what Australia’s regulators were doing well and where improvements might be made.
Many agvet and industrial chemicals are known to have, or potentially have, adverse effects on human health and the environment (summarised in our review and here; see also here). Chemical impacts present a global problem and each country has to play its part in minimising harm. Thus regulation to eliminate or seriously reduce this threat is an important public and planetary health objective in Australia.
Consequent to the review, we have made a series of recommendations for policy and regulatory improvements. While there is some overlap in recommendations for the agvet and industrial sectors, we grouped recommendations within each sector, and identified common ones.
Strengthening Australia’s Agvet Chemicals Regulation: Recommendations
- Establish a National Domestic Produce Pesticide Residue Monitoring Program, prioritising high risk agricultural zones and water catchments to optimise costs in line with the EU, USA, and Canadian systems. This would be an extension of resources and outputs of the National Residue Survey and the Australia Total Diet Study and other industry residue monitoring programs such as FreshTest. Such a program would not only benefit assessments of effects on human health, but also ecosystem health and water safety.
- Implement well-defined review triggers, such as deregistration by an international regulator, reaching a threshold number of validated adverse event reports, and scheduled periodic reviews backed up by a re-registration scheme similar to the EU, USA, and Canada. This could build upon existing mechanisms such as codes of practice, work health and safety risk management plans, pesticide spray records, and industry waste stewardship schemes.
- Establish a National Licensing Framework to regulate occupational agvet chemical exposure activity backed up by a set of training standards, especially for restricted chemical products.
- Adopt machine-readable, smart chemical product labels to enable communication of key information such as chemical safety properties, safe use measures, first aid, and safe disposal requirements.
- As part of the current APVMA review, extend the current adverse events reporting system beyond animal health concerns, and integrate better with jurisdictional reporting of other agvet chemicals such as pesticides. This would link with the residue monitoring program.
Strengthening Australia’s Industrial Chemicals Regulation: Recommendations
- Similarly to the agvet sector, Australia needs to establish biomonitoring of industrial chemical residues and exposure with a continuous funding stream similar to the chemical body burden monitoring programs in Europe, USA, and Canada. In parallel, we need a comprehensive national database to collect biomonitoring results to assist in identifying exposure trends over time and by geographical regions, and to enable detection of populations that may have increased exposure and risk of adverse effects.
- Under the recently Introduced National Industrial Chemicals Environmental Management Standard (IChEMS), specify standards for states and territories to incorporate into their legislation to facilitate nationally harmonised risk management and develop a robust system of measurable indicators. IChEMS should also include performance metrics to enable industry to show that the standards are being met.
- AICIS needs improved resourcing (from government and industry) to enable the Inventory Multi-Tiered Assessment and Prioritisation (IMAP) Program to accelerate assessment of the large number of unassessed chemicals currently in use.
Strengthening both systems where overlap exists: Recommendations
- Australia should implement a National Adverse Chemical Events Reporting System with reports from chemical registrants, regulators, users and the general public funneled into a single entity. This should systematically report the potential indirect human health impacts of chemicals in the environment. These reports need to be accessible by the public once validated as a confidence building measure.
- There needs to be a National Surveillance System to link together fragmented data sources in the current regulatory framework. Such inputs would include data from sales, national residue monitoring programs, chemical use, industry quality assurance programs, compliance, adverse events reported, and other associated reports, research, and decisions from international regulators.
- A further necessary support and confidence measure is a performance measurement structure to ensure risk reduction strategies are effective in protecting human and environmental health. This might include AICIS and APVMA conducting reviews involving comparison with other international regulatory bodies, exploring adoption of successful strategies enacted overseas, and regular external expert audits to complement regular self-assessments. These need to be backed up by clear reporting obligations with proportionate penalties for breaches.
- Clearer distinction is required between risks to humans from consumer products, and risks from environmental exposure to agvet and industrial chemicals.
- It is critical to ensure stakeholder consultation and engagement with the ongoing effectiveness monitoring of the national data collection and regulatory effort. Information collected through these programs should then be readily available to all stakeholders, including the public, in an appropriate form, to help instil confidence in Australia’s chemical regulatory framework.
- The process for monitoring to determine if recent reforms to agvet and industrial chemical regulation will be sufficient to facilitate timely ratification of international conventions must continue.
- Adequate system funding for operation and evaluation is essential.
Chemical exposures adversely affect human health, and disproportionately affect vulnerable populations, including the young, aged, pregnant women and their fetuses, Indigenous peoples, and people in lower socioeconomic circumstances.
A key principle of all regulation is the protection of human and environmental health. Regulation failures increase exposures and hence increase preventable disease burden. Combined with other major environmental changes (climate disruption, topsoil loss, and biodiversity loss among others), accumulating chemical toxins in the environment reduces the adaptive capacity of all species including our own.
Both the Australian agvet and industrial chemicals regulatory frameworks require further improvement to bring them in line with comparative international regulators.
The recent changes to AICIS and the proposed changes to the APVMA have been guided by government priorities to reduce the regulatory burden on the industry. This may increase the chemical exposure risk to people and the environment, and must be monitored.
Protection of animal and human populations from unnecessary and damaging chemical exposures is, therefore, a central public health action, and another opportunity for the new ALP government to improve the public good.
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