Submission cover sheet
Consultation on 84 toxic chemicals of security concern
Please complete Table 1 and attach this form as the first page of your submission.
Submissions close 27 August 2014.
Table 1: Submission details
Your details:
Name: Scott Burnell
Phone: 07 5552 8680
Mobile: 0402 802 750
Email: s.burnell@griffith.edu.au
Position: Team Leader – biosafety, Chemicals &
Radiation
Postal address: Health & Safety, HRM, Griffith University, Qld 4222
Business name: Griffith University
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supplied in confidence and can be
placed on the website
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supplied in confidence
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CONFIDENCE)
Is ENTIRELY
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Send submissions to:
Email:
Post:
Chemical.Security.RIS@ag.gov.au
Chemical Security RIS
Attorney-General’s Department
3-5 National Circuit
BARTON ACT 2600
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information included in submissions when published to the chemical security website at
www.chemicalsecurity.gov.au. Submissions provided in-confidence will not be published.
For a copy of the Attorney-General’s Department privacy statement visit
www.ag.gov.au/pages/privacystatement.aspx.
21st August 2014
Attention: Chemical Security RIS
Attorney-General’s Department
3-5 National Circuit
BARTON ACT 2600
Thank you for your recent request to provide comment on the draft policy options proposed to reduce the
national security risks posed by 84 toxic chemicals of security concern.
As a large organisation frequently using a broad range of chemicals including those of security concern, we
recognise and agree with the need to manage the security associated with these chemicals.
We
acknowledge that maintaining the status quo would not effectively reduce chemical security risks, but
equally increased regulation, enforcement and penalties would be problematic to the organisation due to
the costs and difficulties associated with implementing compliance controls and we do not necessarily see
that these would have any real impact. Whilst the university is apprehensive about additional compliance
costs it would readily support an awareness campaign as well as the expansion of the National Code of
Practice.
In regards to the likely costs and benefits of the proposed measures, we would like to comment that the
costs associated for employee and contractor security checking would be much higher for a University
compared to a standard business. This is due to the large number of staff and frequent turnover of
students that may be involved in the handling of chemicals. Whilst staff and students are subjected to
some initial identification scrutiny more comprehensive and frequent security checks would be
problematic. Given that additional scrutiny, such as criminal history checks, would likely have limited effect
in the identification of potential offenders, the cost would not justify the benefit. This type of security
checking only identifies those that have been convicted of a past offense and have that conviction
recorded, this in addition to the time delay in obtaining a Police Certificate (Nation-wide), in excess of 30
days would not provide any manageable security measures.
In addition, the costs associated with increased inventory control would also be substantial due to the
diverse management and location of chemical use and storage across multiple campuses. The University
comprises of numerous schools and research groups that have different approaches to inventory control.
As a result, significant resources would be required to enable comprehensive chemical inventory
monitoring across the organisation, which would effectively identify any criminal activity involving
chemicals of security concern.
The University would however be readily able to comply with other security measures proposed. Physical
and personnel access is already restricted to authorised persons throughout the organisation and the
receipt of chemicals is also effectively monitored. The organisation would also be readily able raise
awareness amongst staff and students by promoting the code of practice. The University would also be
willing to implement procedures recommended to deter the theft and diversion of chemicals of security
concern.
Due to the costs associated with implementing some of the chemical security measures proposed, it would
be unlikely that an awareness campaign alone would be sufficient incentive for an organisation to invest in
additional controls. We feel that an organisation would be more likely to voluntarily implement changes in
order to comply with a National Code of Practice.
Overall, we support most of the security recommendations proposed for the National Code of Practice for
Toxic Chemicals of Security Concern. The suggestions appear reasonable, practical and avoid regulations
and penalties that would be detrimental to the organisation. Please let us know if you would like further
comment or information.
Kind Regards,
Scott Burnell
Team Leader - Biosafety, Chemicals & Radiation
Health & Safety - Human Resource Management
Griffith University, Queensland 4222
s.burnell@griffith.edu.au
Ph: 07 5552 8680