The ACTU considers a fundamental question for this review is “what systemic structures are required to protect human, animal and environmental health whilst using agricultural and veterinary chemicals?”
The ACTU is not convinced that the Issues Paper has provided a balanced, evidenced review of the effectiveness of the current system or proposed changes which would ensure such protection.
The ACTU recommends that this review needs significant revision to outline structures and mechanisms that:
a. Give effect to better communication and transfer of information and knowledge to users of agvet chemicals;
b. Encourage users of agvet chemicals to reduce the use of hazardous chemicals to reduce the toxic load on humans and the environment;
c. Create a regulatory system that encourages users of agvet chemicals to focus on the higher end of the hierarchy of risk control through elimination and substitution of chemicals that meet the following GHS classifications: carcinogenicity, target organ systemic toxicity, germ cell mutagenicity, and reproductive toxicity, with particular attention to highly hazardous pesticides, as per the WHO.
The ACTU recommends the submissions of the Cancer Council of Australia and the Public Health Association of Australia, noting that both organisations possess significant expertise in the application of scientific evidence to public and environmental health matters.