Commonwealth Numbered Regulations - Explanatory Statements

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INDUSTRIAL CHEMICALS (NOTIFICATION AND ASSESSMENT) AMENDMENT REGULATIONS 2004 (NO. 1) 2004 NO. 158

Section 111 of Industrial Chemicals (Notification and Assessment) Act 1989 (the Act) provides in part that the Governor-General may make regulations, not inconsistent with the Act, prescribing matters required or permitted by the Act to be prescribed or necessary or convenient to be prescribed for carrying out or giving effect to the Act.

The object of the Act is to provide for a national system of notification and assessment of industrial chemicals for the purposes of aiding in the protection of the Australian people and the environment; providing information and making recommendations about industrial chemicals to Commonwealth, State and Territory bodies; giving effect to Australia's obligations under international agreements; and collecting statistics in relation to these chemicals.

Subsection 110 (1) provides that the regulations may prescribe fees for specified services. Subsections 110 (2) to (6) set out details for when fees are due, the payment schedules and other arrangements. The fees for services defined in Section 110 are prescribed in the Industrial Chemicals (Notification and Assessment) Regulations 1990.

The purpose of the Regulations is to increase the Company Registration and New Chemical assessment fees and charges for the National Industrial Chemicals Notification and Assessment Scheme (NICNAS) for 2004-05. It is proposed that these fees and charges be increased by 5.1% (rounded to the nearest dollar). The last increase to these fees and charges was made on 1 July 2003. That was the first increase since 1997.

The increase enables the NICNAS to continue to meet the Government's requirement that the NICNAS operates on a full cost-recovery basis. The increase was arrived at by agreement with the NICNAS's Industry Government Consultative Committee (IGCC) and the Community Engagement Forum (CEF).

The Act specifies no conditions that need to be met before the power to make the Regulations may be exercised.

Details of the Regulations are set out in the Attachment A. The Regulation Impact Statement is at Attachment B.

The Regulations commence on 1 July 2004.

ATTACHMENT A

DETAILS OF THE INDUSTRIAL CHEMICALS (NOTIFICATION AND ASSESSMENT) AMENDMENT REGULATIONS 2004 (NO. 1)

Regulation 1 names the Regulations as the Industrial Chemicals (Notification and Assessment) Amendment Regulations 2004 (No. 1).

Regulation 2 provides for the Regulations to commence on 1 July 2004.

Regulation 3 provides for Schedule 1 to amend the Industrial Chemicals (Notification and Assessment) Regulations 1990 (the Principal Regulations).

Schedule 1 - Amendments

Item 1

This item amends regulation 11AB of the Principal Regulations to increase the registration charge by 5.1% (rounded to the nearest dollar) to $1058 for the lower threshold and $7879 for the upper threshold. These amounts apply in relation to a registration year that begins on or after 1 September 2004. The previous charges, of $1007 for the lower threshold and $7497 for the upper threshold, continue to apply in relation to the registration year that began on 1 September 2003.

The registration charges are only applicable to those importers and manufacturers whose value of relevant industrial chemicals exceeds $500,000 in any registrable year. The registration charge has two tiers for cost recovery arrangements consistent with the cost recovery policy of user pays. The first tier is referred to as the lower threshold and is $500,000 to $4,999,999. The second tier is referred to as the upper threshold and is all values above $5,000,000.

Item 2

This item amends regulation 13 to increase the fees in paragraphs 13(2)(a) to (c), 13(3)(a) and (b) and 13(4)(a) and (b) of the Principal Regulations by 5.1% (rounded to the nearest dollar).

Item 3

This item amends Schedule 2 to the Principal Regulations to increase the fees in the Schedule by 5.1% (rounded to the nearest dollar).

ATTACHMENT B

Background

1.       NICNAS's Industry Government Consultative Committee (IGCC) meeting of 19 November 2002 (IGCC 17) considered a proposal to increase company registration and new chemicals assessment fees and charges for 2003-04. In considering the application of new fees and charges, NICNAS undertook intensive activity based costing (ABC) to determine the true costs of all NICNAS activities. The ABC model found that in some limited areas such as permit assessments, the effect of NICNAS efficiencies had resulted in NICNAS recouping fees for services based on the original costs that have subsequently reduced over time. It found that in other areas it undercharged or did not recoup costs at all.

2.       The proposed new fees and charges put to IGCC 17 were an effort to address charging anomalies, resulting in increases in some areas and decreases in other areas. The proposed increase did not pass onto industry 100 per cent of the cost, with NICNAS choosing to continue as in the past, to deliver further efficiency gains to industry by absorbing some of the costs.

3.       Three options were put to IGCC members in 2002 for their consideration:

�       Option1, Status Quo;

�       Option 2 provided for a 4.9% increase in New Chemical fees, a 7.9% (which represented only about 50% of the aggregate CPI/WCI increase from June 1997 to June 2002) increase in Company Registration charges and New Chemical charges and charging for searches of the Australian Inventory of Chemical Substances (AICS) database. This option provides a minimal surplus which was considered as insufficient to build reasonable operational reserves; and

�       Option 3 was estimated to generate a surplus of $200,000 via an additional one off 4% increase to all fees and charges (additional to option 2 estimates). This was to allow a reserve of $400,000 to be generated in approximately two years and reform projects to be funded from additional reserves subsequently.

4.       The final agreed fee increase for 2003-04 was to:

�       increase the current New Chemical assessment fees by 4.9%;

�       increase Company Registration and New Chemical Administrative charges by 7.9%;

�       introduce a $35 charge for searches of the Australian Inventory of Chemical Substances (AICS); and

�       a one off additional 4% rise in Company Registration charges and New Chemical fees and charges.

5.       It was anticipated that the preferred option would allow the generation of a small surplus to ensure the financial sustainability of NICNAS. It was planned to use this surplus to build an Operating Reserve with a target set at $400,000.

6.       The charging for AICS searches was introduced on 1 April 2004. NICNAS only receives a negligible amount of revenue from charging for AICS searches. Since with the introduction of AICS online and the introduction of a service charge the demand on NICNAS has been minimal.

7.       The cost of funding NICNAS's reform activities for 2004-05 is $448,000 to be allocated, subject to approval, as follows:

�       $183K is required to undertake additional low regulatory concern chemicals (LRCC) reform work;

�       $90K for the OECD New Chemicals Task Force ($90K), and

�       $175K for the Foreign Schemes program ($43K for Canada and $132K for the USA).

Details of reform activities planned for 2004-05 are at Attachment 1.

Problem

8.       IGCC agreed that NICNAS adopts a policy of maintaining an operating reserve to enable adequate discharge of responsibilities under the Act during times of low New Chemical activity. In addition, if the operating reserve is built up over time, it could be used to fund new reform work (post LRCC) and where possible, reduce fees in certain circumstances. Members agreed that $400,000 (approx. 9% of the 2002-03 budget revenue) should be accumulated for adequate operational purposes prior to allocating funding to further reform activities post the LRCC.

9.       A number of uncontrolled factors have been identified which will have a negative impact on the 2004-05 budget. There were four key factors identified as contributing to the projected budget deficit these were the IT costs, accommodation costs, staff costs and corporate overheads. Together these costs total $3,844,723 and represent a cost increase of 15% above the 2004-05 forecast budget.

10.       Even with significant cut backs in planned activities, travel and staff, the 2004-05 budget forecasts indicate that NICNAS will generate insufficient funding by an estimated $331,174 (Table 1, Option 1) to cover costs incurred in the discharge of its obligations under the Act. This is inconsistent with cost recovery policy. Given the range of demands on NICNAS's operating budget for 2004-05, consideration of fees and charges increases for 2004-05 to ensure adequate resources is required.

11.       In the five years to 30 June 2002, NICNAS generated reserves to the value of $470,000 to be used to fund industry requested reform work. At the commencement of the 2003-04 year, the notional reserve was $378,291. The IGCC approved out-of-session expenditure of $70,000 to fund additional reform work, reducing the notional reserve. The budget surplus forecast for 2003-04 was $200K, but due to increased activity for new chemicals assessments and salary savings due to delays in recruitment, the budget forecast for 2003-04 is estimated to be generating a notional reserve of around $400,000.

Objective

12.       The 2004-05 budget aims to generate sufficient funding to satisfactorily discharge mandatory obligations under the Act, whilst minimising market distortions though limiting cost increases to industry and limiting cross subsidisation of activities undertaken by NICNAS.

13.       NICNAS believes that legislative and regulatory reform to maximise the efficiency of the Scheme is valuable to the long-term efficiency and competitiveness of the industrial chemicals industry. Further, continuing the reform work now, and implementing the LRCC reform initiatives, subject to the passage of the LRCC Amendment Bill will decrease the regulatory and compliance burden in the longer term. A secondary objective is to generate sufficient funds over time to maintain ongoing reform to ensure industry competitiveness and, if sufficient funds accrue, to consider fee reductions or adjustments.

14.       There are 6 streams of income available to NICNAS:

1.       Company Registration fees and charges: All companies that introduce into Australia more than $500,000 worth of industrial chemicals per year must be registered.

2.       New Chemical Assessment fees.

3.       New Chemical Assessment charges: These are administrative charges associated with new chemical assessment fees.

4.       Government Appropriation: NICNAS receives an appropriation to cover the cost of compliance activities undertaken. This is indexed to inflation. The proposed amount for 2004-05 is $120,000.

5.       Charging for AICS searching which in 2003-04 was estimated to bring in revenue of $93, 870 for 2003-04 which was not realised for reasons explained above.

6.       Interest on Special Account funds has been estimated as $90,000 for 2004-05.

Options

15.       While a range of options exist to ensure that NICNAS's revenue base matches its proposed expenditure for 2004-05, 3 options have been presented to IGCC for consideration. Table 1 presents the impact of the proposed models on NICNAS's budget for 2004-05.

Option 1 - No Change

16.       This assumes that no changes to fees and charges are made and is not realistic, as it would result in a significant overspend and even drawing on NICNAS's reserves, would leave an overall projected deficit of $113,823. Though there are limited short-term benefits to industry, the long-term consequences in respect to public health and safety, reduced competitiveness of the chemical industry (e.g. lack of resource to implement LRCC and other reforms) and fiscal responsibility, are all unacceptable.

Option 2 - Apply CPI/WCI increase

17.       This option increases all administrative fees, Company Registration and New Chemicals assessment charges by 4.2% using an agreed formula used in the Office of Chemical Safety (OCS) which is the combined CPI/WCI formula (25% CPI and 75% WCI = 4.2% for 2004-05). In summary, an increase of 4.2% will be applied to:

�       New Chemical certificate assessment charges;

�       New Chemicals administrative fees; and

�       Company Registration fees and charges.

No increase in New Chemicals permits assessments is proposed for 2004-05 under this option.

18.       The ABC model using data from 2002-03 identified that activities were under recovered by 4.9% with a range from 195% under recovered to 30% over recovered in the area of NICNAS permits. The ABC model operating in NICNAS, which formed the basis of fee costs last year, found that for 2003-04, fees needed to rise in certificates but that permit assessments categories were still offsetting costs.

19.       Company Registration revenue pays for AICS maintenance and upgrades, public access to chemical safety information, compliance, education and awareness and the existing chemicals program. Increased activity for 2004-05 will be in the areas of compliance, public access to chemical safety information, community participation through the Community Engagement Forum and the existing chemicals review. The increase in administrative fees reflects the increased CPI/WCI costs to NICNAS. An increase in the CPI/WCI for certain activities such as new chemicals certificate assessments produces a deficit of $147,389 and result in a projected reserve at 30 June 2005 of only $69,956.

Option 3 -Break even

20.       This option increases New Chemicals fees and charges and Company Registration fees and charges by 9.5%. In addition, it applies the CPI/WCI to New Chemicals permit fees. These increases will result in an overall deficit of NICNAS's projected budget for 2004-05 of $88,904 (including the funding of reform for 2004-05 to come from the reserve), leaving a reserve of $311,096. This option will allow reform work to be undertaken to improve the Scheme's efficiency and effectiveness. The additional cost is expected to have minimal impact on industry. The industry is estimated to have an annual turnover of $22 billion. The annual cost of the regulatory scheme is approximately $5 million which represents 0.02% of the annual industry turnover. The proposed increase of 9.5% for cost recovered activities on the overall cost of the regulatory scheme is negligible. NICNAS reserves will be reduced but will allow the undertaking of further legislative and regulatory reform work. If no reform work is undertaken, the estimated reserve for 2004-05 will be $493, 757.

21.       Cost recovery policy suggests that fees should reflect the cost of providing the service. Proposed New Chemicals activities are under funded in the budget due to the increase in salaries, IT and accommodation. The major costs for New Chemicals is in salaries and SLA's which amounts to 88% of its expenditure. In previous years the ABC model indicated that permits were over-recovered. The decision to apply only the CPI/WCI of 4.2% to Permits rather than 9.5% reflects the efficiency gains achieved by industry's increased uptake of permit templates, currently at around 80% of notifications lodged. However, in other areas of New Chemicals activities such as certificates, cost recovery needs to reflect the costs of providing this service to industry.

Impact analysis

Parties affected

22.       Parties likely to be affected by the proposed changes are industry, government and the community. The imposts on small business are likely to be minimal because under the current threshold system for company registration, small businesses which import or manufacturer less that $500,000 of industrial chemicals in a registration year are exempt from company registration charges. Government and the community will benefit from a viable industrial chemicals regulator.

Option 1 - No Change

23.       Though there are limited short-term benefits to industry from no immediate fee increase, the long-term consequences in respect to public health and safety, competitiveness of the chemical industry are unacceptable. The cost to government and the public would be unacceptable as the Scheme would be under funded and not viable increasing the risk to public health, worker safety and environmental standards. This option does not meet the Government's cost recovery policy or the IGCC's objective to generate sufficient funding to satisfactorily discharge mandatory obligations under the Act, and is therefore not preferred.

Option 2 - Apply CPI/WCI increase

24.       This option increases all administrative fees, Company Registration charges and New Chemicals assessment charges by 4.2%. While industry will benefit in the short term, NICNAS will continue to under recover the costs of its activities which will have long-term negative consequences for industry, government and the community. This option does not generate sufficient revenue to cover costs for NICNAS's planned activities for 2004-05 and while there are there sufficient reserves to meet the projected shortfall, the estimated reserve at 30 June 2005 is $69,956. This option does not meet the Government's cost recovery policy or the IGCC's objective to generate sufficient funding to satisfactorily discharge mandatory obligations under the Act, and is therefore not preferred.

Option 3 - Break even

25.       This option still under recovers an estimated $88,904 (including reform activities) for 2004-05, leaving a projected reserve of $311,096 at 30 June 2005. The fee increase may generate concern from industry, but will ensure long-term viability for industry and enable funding of projects such as the bilateral negotiations with the USA. The establishment of a bilateral arrangement with the USA will be of great benefit to industry. Government and the community will benefit as the Scheme will remain viable and not rely on Government supplementation. The community will have confidence in the integrity of the Scheme as public health, worker safety and environmental standards are maintained. It is the recommended option as it represents a financially sustainable approach that is consistent with the Commonwealth Government's cost recovery policies and imposes the least impost on industry.

Consultation

26.       NICNAS's Industry Government Consultative Committee (IGCC) is a key mechanism for consultation with industry and government stakeholders. IGCC industry members represent the peak associations dealing with industrial chemicals, the Plastics and Chemicals Industries Association (PACIA), the Australian Consumer & Specialty Products Association (ACSPA), the Australian Paint Manufacturers Federation (APMF) and the Australian Chamber of Commerce & Industry (ACCI). The IGCC was established to provide industry with the opportunity to participate in the NICNAS budgetary process and review the utilisation of resources against NICNAS objectives. The prospect of increases in fees and charges was first raised in this forum in April 2000 when it was decided to prepare an ABC model. A paper detailing proposals for fee increases was presented at the first combined CEF/IGCC on 7 May 2004 and discussed again on 27 May 2004.

27.       During consultations, industry rejected Option 3 and put up an alternative model (Table 2) as its final position which includes the following elements:

�       capping any fee increase for 2004-05 at 5.1%;

�       prioritising the 2004-05 NICNAS work program and maintaining core activities, including the LRCC reform program;

�       re-scheduling the NICNAS international work program on Canadian and USA bi-lateral discussions over a longer period to reduce the budgeted costs for 2004-05; and

�       maintaining an operating reserve of $311,000.

The proposed industry alternative was agreed to as the preferred option.

28.       The Community Engagement Forum (CEF) is NICNAS's key mechanism to consult with the community. The CEF was established in October 2003. The CEF was provided with information the meeting on 7 May 2004.

Conclusion and Recommendation

29.       Taking into consideration the views of industry, the preferred option (Table 3) is the industry alternative model which maintains a modest reserve of approximately $254K for NICNAS via an additional 5.1% increase to Company Registration fees and charges, New Chemicals fees and charges, and New Chemicals permit fees. Table 2 indicates the costs to each of NICNAS's fees and charges in the application of this option. The preferred model (Table 3) also takes into account reduced reform activity on the part of NICNAS and delaying bilateral discussions with Canada and the USA by 6 months.

30.       The industry alternative model is acceptable to NICNAS given industry assurances that the priority for the 2005-06 budget will be to re-establish the operating reserve to acceptable levels, that is 9% of the 2005-06 budget.

Implementation and review

31.       NICNAS' cost recovery arrangements are scheduled for review in 2004-05. This will provide an opportunity to ensure that NICNAS' arrangements comply with Government policy and are appropriately transparent and accountable.

32.       NICNAS and industry have agreed that the IGCC will review NICNAS's budget in November each year to identify possible increases in fees and charges to apply in the next financial year. This will provide industry members with adequate time to advise their members of budget increases which can be built into the industry budget and business planning cycle.

ATTACHMENT 1

1       NICNAS's reform budget for 2004-05 is estimated at $314,788 and represents a significant investment by industry in NICNAS. Reforms bring about substantial benefits to industry, for example, The introduction of the low volume <10kg/per year category in July 1997 has facilitated the safe use of some 643 chemicals which would otherwise have required assessment at a cost to industry or the chemicals would not have been marketed. Estimates on the saving in assessment fees to industry ranges from a minimum of $1,671,800 (if all priced as low volume permits) to a maximum of $6,301,400(if all priced as limited certificate application). This estimate in savings does not include savings related to data generation or industry administration costs. (NICNAS Annual Report for 2000-01, p28). Currently, there are three streams to NICNAS's reform program:

�       low regulatory concern chemicals (LRCC) (R1);

�       OECD activities (R2); and

�       foreign schemes (R3).

Low regulatory concern chemicals (LRCC)

2       LRCC reforms for 2004-05 will focus on the following activities and outcomes:

�       implementation of the Industrial Chemicals (Notification and Assessment) (Low Regulatory Concern Chemicals) Amendment Bill 2004

�       the development of low hazard/low risk assessment criteria;

�       improved regulation of cosmetics by:

Ø       implementing the LRCC cosmetics reforms;

Ø       development of a joint NICNAS/TGA Cosmetics Claims Guideline; and

Ø       focussing on emerging issues such as transmission of BSE through the use of cosmetics; issues with hair dyes; and tattoo inks.

OECD activities

3.       The following OECD activities for 2004-05 are planned, subject to funding:

�       NICNAS has been active in the work of the OECD New Chemicals Task Force, particularly participation in the Work Elements I focussing on Multilateral comparison of assessment reports and Work Element V, which concern definitions and chemicals of low priority for assessment. Following the video presentation by the Director prior to its October 2003 meeting, the Task Force has embraced the low regulatory concern concept currently being introduced into NICNAS legislation;

�       significant progress has been made in developing the concept of Mutual Acceptance of Notifications, (MAN). The Director NICNAS has been asked to Chair a high level meeting of experts to further develop the concept; and

�       improving progress in the adoption of the NICNAS template under Work Element III, where Australia is the lead country.

Foreign schemes

4.       Recognising that the industrial chemicals business is global, the international regulatory community is working towards global approaches to drive improved health, worker safety and environmental outcomes through the promotion of national and international business competitiveness. Australia is at the forefront of international activity in undertaking activity to recognise schemes comparable to NICNAS as Foreign Schemes under its legislation. For 2004-05, subject to funding, NICNAS will focus its efforts on:

�       extending its bilateral arrangements with Canada (R3.1). The Bilateral Arrangement with Canada has been consolidated through regular teleconferences and work with Canada on the OECD New Chemicals Task Force workshop on multilateral comparison of assessment reports. The current arrangement expires in 2004 and NICNAS is currently working with Canada to renew the arrangement and update the work plan with a view to recognising Canada as a Foreign Scheme under the Industrial Chemicals (Notification and Assessment) Act 1989 (the Act); and

�       continuing discussions with the US EPA to develop a similar Bilateral Arrangement with the US (R3.2). Work has begun towards development of a work plan between the two countries.

Option 1			Option 2	4.20%		Option 3	9.50%
REVENUE			REVENUE			REVENUE
New Chemicals Assessment fees			New Chemicals Assessment fees			New Chemicals Assessment fees
Certificates	1,583,384		Certificates (4.2%)	1,647,508		Certificates (9.5%)	1,730,804
Permits	163,350		Permits (0 increase)	163,350		Permits (4.2%)	170,211
Charges	185,306		Charges (4.2%)	193,089		Charges (9.5%)	202,911
Company Registration fees			Company Registration fees			Company Registration fees
Lower Tier Registration Charge	671,500		Lower Tier Registration Charge (4.2%)	699,703		Lower Tier Registration Charge (9.5%)	735,293
Upper Tier Registration Charge	1,997,415		Upper Tier Registration Charge (4.2%)	2,081,306		Upper Tier Registration Charge (9.5%)	2,187,169
Other Income			Other Income			Other Income
Interest	90,000		Interest	90,000		Interest	90,000
Government Appropriation	120,000		Government Appropriation	120,000		Government Appropriation	120,000
TOTAL REVENUE	4,810,956		TOTAL REVENUE	4,994,957		TOTAL REVENUE	5,236,388
EXPENSES			EXPENSES			EXPENSES
Employee	3,224,142		Employee	3,224,142		Employee	3,224,142
Supplier	570,058		Supplier	570,058		Supplier	570,058
Other corporate costs incl Depreciation	420,263		Other corporate costs incl Depreciation	420,485		Other corporate costs incl Depreciation	420,775
Corporate SLAs	1,110,315		Corporate SLAs	1,110,315		Corporate SLAs	1,110,315
TOTAL EXPENSES	5,324,779		TOTAL EXPENSES	5,325,001		TOTAL EXPENSES	5,325,291
Net result	-513,823		Net result	-330,044		Net result	-88,904
Less Reform costs (to come from reserves)	182,649		Less Reform costs (to come from reserves)	182,654		Less Reform costs (to come from reserves)	182,661
TOTAL POSITION	-331,174		TOTAL POSITION	-147,389		TOTAL POSITION	93,757
Reserve position			Reserve position			Reserve position
Revised Estimated reserve for 30/6/2004	400,000		Revised Estimated reserve for 30/6/2004	400,000		Revised Estimated reserve for 30/6/2004	400,000
Net position at 30/6/2005 including reform activity	-513,823		Net position at 30/6/2005 including reform activity	-330,044		Net position at 30/6/2005 including reform activity	-88,904
Estimated reserves at 30/6/2005	-113,823		Estimated reserves at 30/6/2005	69,956		Estimated reserves at 30/6/2005	311,096

	No Increase to fees		Industry model
	Est Budget 04/05		Est Budget 04/05
Revenue	Increase	Price		Increase	Price
Company Registration Charges	0.00%	2,668,915		5.1%	2,805,030
New Chemicals Fees	0.00%	1,746,734		5.1%	1,835,818
New Chemicals Charges	0.00%	185,306		5.1%	194,757
Share of Govt appropriation	Fixed	120,000		Fixed	120,000
Other	Interest	90,000		Interest	90,000
Total Revenue		4,810,955			5,045,604
Expenses
Salaries	4.00%	3,224,142		4.00%	3,073,453
Admin Expenses		990,321			980,905
SLAs		1,110,315			1,110,604
Total Expenses		5,324,778			5,164,962
Surplus/(Deficit)		-513,823			-119,357
	Increase	Current Price		Approximate increase	New Price rounded to whole $
New Chemicals Fees
Standard Assessment	0.00%	12,741		5.1%	13,391
Limited Assessment	0.00%	10,672		5.1%	11,216
Polymer of Low Concern	0.00%	3,594		5.1%	3,777
Commercial Evaluation	0.00%	2,831		5.1%	2,976
Low Volume Chemical	0.00%	2,831		5.1%	2,976
Early Introduction Permit	0.00%	545		5.1%	572
Section 30 Permit	0.00%	6,175		5.1%	6,490
Application for Extension	0.00%	2,287		5.1%	2,404
2nd notifn other than PLC	0.00%	7,057		5.1%	7,417
2nd notifn is a synthetic PLC	0.00%	3,049		5.1%	3,205
Foreign Scheme - Std	0.00%	7,057		5.1%	7,417
Foreign Scheme - Ltd	0.00%	5,685		5.1%	5,974
Alternate State Law	0.00%	7,623		5.1%	8,012
New Chemicals Charges
Confidential Listing	0.00%	1,119		5.1%	1,176
Retain Confidential Listing	0.00%	1,511		5.1%	1,588
Holder of a Confidence	0.00%	504		5.1%	529
Variation of Data Requirements	0.00%	1,007		5.1%	1,058
Foreign Scheme	0.00%	5,237		5.1%	5,504
Exempt Information	0.00%	560		5.1%	588
Application to Vary Report	0.00%	560		5.1%	588
Company Registration
Lower Tier Registration	0.00%	1,007		5.1%	1,058
Upper Tier Registration	0.00%	7,497		5.1%	7,879
Admin registration charge	0.00%	336		5.1%	353

Table 3:        Proposed NICNAS budget for 2004-05.

REVENUE
New Chemicals Assessment fees
Certificates	1,604,621
Permits	231,197
Charges	194,757
Company Registration fees
Lower Tier Registration Charge	705,747
Upper Tier Registration Charge	2,099,283
Other Income
Interest	90,000
Government Appropriation	120,000
TOTAL REVENUE	5,045,604
EXPENSES
Employee	3,073,453
Supplier	560,165
Other corporate costs incl Depreciation	420,741
Corporate SLAs	1,110,604
TOTAL EXPENSES	5,164,962
Net result	-119,357
Less Reform costs (to come from reserves) *	184,140
TOTAL POSITION	64,782
Reserve position
Revised Estimated reserve for 30/6/2004	400,000
Estimated reserves at 30/6/2005	280,643
Revised Estimated reserve for 30/6/2004	400,000
Net reserves (which excludes reform)	64,782
Available reserves (if no reform activity)	464,782
R1 - LRCC	183,000
R3.1 - Foreign Scheme Canada (50%)	21,500
R3.2 - Foreign Scheme USEAPA (50%)	66,000
Revised Available reserves at 30/6/05	194,282
Misc income- AGS & late fees (not guaranteed)	60,000
Reserves if misc income is received	254,282

* Note: LRCC costing higher than estimated R1 costs due to allocation of corporate expenses