Victorian Occupational Health and Safety Review AICD additional submission

14 October 2003

The Secretariat
Occupational Health and Safety Act Review
Level 26
222 Exhibition Street
Melbourne Vic 3000

Dear Sir/Madam,

Re: AICD Submission dated 3 October 2003

An issue has just been brought to our attention which should have been included in our earlier submission. Whilst the deadline for first round submissions closed last week, we believe that it is an issue which the Review ought to consider now for the sake of completeness and hope that we have raised it in sufficient time to enable the Review to do so.

Specifically, we refer to the work of the National Occupational Health and Safety Commission (NOHSC) of which Victoria is a member. The NOHSC National Strategy 2002-2012 was endorsed on 24 May 2002 by the Workplace Relations Ministers Council. A copy of the Strategy Chart is attached.

The NOHSC Strategic Plan 2002-2005 in its own words recognises and reflects the commitment of all NOHSC members to implementing the National Strategy. A copy of the Strategic Plan is attached. We draw your attention to Output 2: Improve the prevention of occupational death, injury and disease across Australia. This is backed up by Strategic priority b: providing advice on the regulatory framework and promoting national consistency, including through NOHSC standards and guidance material.

It is not clear how the NOHSC Strategy and Plan relates to the Productivity Commission work. However, the work of the Productivity Commission on national frameworks and the NOHSC's emphasis on national consistency has a common theme.

As a member of NOHSC, Victoria has given a commitment to the aim of national consistency. We observe that the NOHSC is not referred to in the Terms of Reference published by the Review and as we have already said, the objective seems to be that Victoria has more exacting OHS legislation than any other State. Cost is an issue, but best practice and optimum result are more important results of national consistency.

Should you have any questions please feel free to contact me.

Yours sincerely,

John Hall
Chief Executive Officer