Review of the Gene Technology Act 2000 (Cth) Submission from the Gene Technology Ethics Committee (gtec)


the stakeholders included in consultations for various applications under the Act



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the stakeholders included in consultations for various applications under the Act

GTEC considers that the most appropriate avenue for the expression of stakeholder views is via the process of public submissions and /or public hearings in relation to applications and via the advisory committee/s. Section 47(4) stipulates entities (authorities, committees, agencies and individuals) the Regulator may consult in relation to applications. GTEC proposes that GTEC be added to this section of the Act.

Recommendation 12: Consultation on Applications

GTEC recommends that GTEC be listed under Section 47(4) as committees the Regulator may consult in relation to applications.




Regulatory Burden

  1. Examine whether compliance and administrative costs, including information requirements, for organisations working in gene technology are reasonable and justified compared to the benefits achieved and possible alternatives to legislation.

GTEC has in the past expressed the view that full cost recovery of administrative costs of the regulatory system would be highly undesirable. GTEC stands by this view for the following reasons.



  1. Full cost recovery has the potential for inequity since it would favour those applicants who could afford to pay and could have the effect of discouraging smaller research organizations or companies from conducting work using gene technology.

  2. Seeking full costs from public research institutions would be unfair and potentially futile since researchers would be likely to add the cost to their grant applications or request it from their institution, which in most cases are sources of public funding.

  3. Full cost recovery has the potential to undermine public trust in the Regulator if the public perceives, even erroneously, that the approval of licence applications can be bought.

If there is to be a fee charged for licence applications it would need to be set at a level that most potential applicants could afford and publicly-funded research should be exempt.






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