GTEC has serious reservations about implementing full recovery of administrative costs. GTEC proposes that any fee charged for licence applications should be set at a level that most potential applicants could afford and that publicly funded research should be exempt.
Interface with other systems
9. Examine the interface between the Act and other Acts and schemes (either Australian Government or State and Territory) that regulate gene technology and gene technology products. Identify any discrepancies, including regulatory gaps and areas needing consistency and harmonization of provisions. Section 21 of the GT Act creates a mechanism that permits the Ministerial Council to designate, under State law, areas of the States and Territories that may be GM or non-GM for marketing purposes. GTEC notes that this mechanism enables the scientific assessment of risks to be conducted separately from consideration of other issues (which, so far, have been marketing issues). While the institutional separation of scientific aspects of risk analysis from other considerations, such as economic, social and cultural factors is a positive feature of the current regulatory system, GTEC considers there is an obvious advantage to having a single national scientific risk analysis. However, if States or Territories, having access to that national analysis of potential harm to human health, safety or the environment, subsequently consider that social or economic risks, or indeed the social or economic benefits, of a new technology outweigh predicted environmental or health effects, then section 21 provides a potential mechanism for more localized (State or Territory based) policy on genetically modified organisms. The separation of the scientific assessment of risk from social and economic policy choices provides for a more open and transparent regulatory system. [There are many examples of regulatory systems and institutional design that achieve this separation, for instance, the Netherlands EIA system http://www.eia.nl/eia/sitemap.htm]
GTEC makes no specific recommendation with respect to Term of Reference 9. Rather, it refers the Review Panel to Recommendation 2, which also applies to this section of the GTEC submission.