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paulw71  
#1 Posted : 30 April 2014 15:31:04(UTC)
Rank: Super forum user
paulw71

As the amendments, changes, and in some cases removal of certain pieces of health and safety legislation in the past 18 months continue. I would be interested in the views of the forum as to whether the actual consultation process serves any purpose.
I appreciate that if the views of industry professionals where heeded then it would be/is valuable but I cannot help but feel the consultation process is now more a case of just going through the motions when essentialy changes or removal of certain legislation is allready fait accompli regardless of the feedback received.
Can anyone actually specify any proposed changes to legislation in recent years that has not been implemented to to consultation feedback from a specific industry ?

Regards
jay  
#2 Posted : 30 April 2014 15:47:43(UTC)
Rank: Super forum user
jay

It is probably a fact that not much changes from the formal consultative document, but one has to know how the formal consultative document itself is compiled. In many cases, there is an informal pre-consultation with industry bodies and/or the various HSE committees such as CONIAC etc to sound out the so called red lines etc and what options to include. Last , but not least, if the consultation is essentially about transposing an EU Directive, there in not much or rather any room for manoeuvre, except the content of the AcOP and Guidance material.

The response from a professional body is likely to carry more weight than any individual in their own professional capacity. My personal view is that few of us take the time to robustly engage in the consultation, not only by responding to the yes/no questions, but supplementing them with convincing rationale and backed by compelling evidence ( i.e the evidence is not anecdotal)

There is no doubt that ultimately, the top level policy, including regulatory, is "directed" by the government of the day.

Stedman  
#3 Posted : 30 April 2014 19:49:14(UTC)
Rank: Super forum user
Stedman

I am somewhat sceptical about the consultation process simply because of the huge cost and delay (as well as any political embarrassment) if legislation has to be altered prior to it being signed off by the minister concerned. I suspect the CDM 201X Regulations have already been thoroughly market tested and been through a thorough pre-consultation process before the official consultative document was ever published.

The useful aspect of the consultative process is that we are already aware legislation before it is published and in my case I can now start the planning process of re-inventing my career yet again!
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