Page 1992 - Week 10 - Tuesday, 24 October 1989

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considerable administrative and economic hardship to genuine small businesses.

The Chamber of Commerce considers that similar requirements to New South Wales should apply, that is, only employers who have more than 20 employees of whom 50 per cent request that a health and safety representative be selected. This will ensure those employers who provide a safe and healthy working environment will not be burdened with the additional administrative obligations.

The Confederation of ACT Industry put in a very detailed and lengthy submission of about 20 or so pages. It stated:

In putting forward a constructive appraisal of the Bill, we have made recommendations which support the principles of the legislation, but also draw attention to:

(a) deficiencies in the legislation

(b) features which private sector employers in the Territory do, and will continue to, object to.

Given the intention of the legislation, namely, to facilitate consultation and cooperation at every level of an enterprise as a prerequisite to occupational health and safety, it is essential that employers' cooperation and support for the legislation be freely given - not coerced from them. In its present form, the Bill could not be expected to achieve this.

It went on to say:

The views put forward in this paper should be regarded as a very real indication of the degree of concern being expressed by the business community.

It is our view that here in the ACT we have the opportunity to set in place legislation which avoids the many problems experienced in other States; to get it right the first time around.

A further issue of concern relates to the administrative costs which will be incurred by ACT Administration if it intends managing and policing the system. As this is an issue of vital concern to the ACT community as a whole, this paper will be publicly available on request.

It went on to conclude its preliminary comments by saying:

It is the view of the Confederation that, without supporting evidence to justify the need for the


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