NICNAS Agency IPS Plan
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The National Industrial Chemicals Notification and Assessment Scheme (NICNAS) is an agency subject to the Freedom of Information Act 1982 (FOI Act) and is required to comply with the Information Publication Scheme (IPS) requirements. This agency plan describes how NICNAS proposes to do this, as required by s 8(1) of the FOI Act.
NICNAS is the Australian Government’s regulatory scheme for industrial chemicals established by the Industrial Chemicals (Notification and Assessment) Act 1989. It is headed by the Director of NICNAS who reports directly to the Parliamentary Secretary for Health and Ageing.
As a prescribed authority as defined in s 4 of the Freedom of Information Act 1982 (FOI Act), NICNAS is also an agency under the Act and therefore required to develop its own agency plan independent of the Department of Health and Ageing.
The agency plan describes how NICNAS proposes to implement and administer its IPS entry in respect of its own information holdings, by addressing:
- the establishment and administration of the NICNAS IPS entry
- information architecture
- information required to be published
- other information to be published
- IPS compliance review.
NICNAS recognises public sector information is a national resource managed for public purposes. Where appropriate, NICNAS aims to proactively disclose its information holdings commensurate with its role in providing information regarding the safe use of industrial chemicals in Australia.
The purpose of this agency plan is to:
- assist NICNAS in planning and developing its IPS entry point
- facilitate public consultation about that contribution
- show what information the agency proposes to publish, how and to whom the information will be published and how NICNAS will otherwise comply with the IPS requirements (s 8(1)).
NICNAS’s objectives are to outline appropriate mechanisms and procedures to:
- manage its IPS entry
- proactively identify and publish all information required to be published (s 8(2))
- proactively identify and publish any other information which may be suitable for publication in-line with FOI principles (s 8(4))
- review and ensure on a regular basis that published IPS information is accurate, up to date and complete (s 8B)
- ensure that published IPS information is easily discoverable, understandable, machine-readable, re-useable and transformable
- ensure conformance with the Web Content Accessibility Guidelines (Version 2) (WCAG 2.0)
- allow for continual improvement of NICNAS’s IPS entry using community feedback and compliance review processes
- ensure NICNAS’s IPS entry reflects best practice in IPS management.
Establishing and administering NICNAS’s IPS entry
The Program Head, Compliance & Enforcement is designated by NICNAS as the officer responsible for leading NICNAS’s compliance with the IPS – the NICNAS IPS Leader.
(a) Establishing NICNAS’s IPS entry by May 2011
NICNAS has prepared an IPS project plan for tasks required for its IPS entry, including:
- NICNAS goals in relation to the IPS
- a timetable for achieving those goals
- how NICNAS will achieve those goals (i.e. tasks to be completed and responsibility for each goal).
NICNAS has developed an IPS information register. The IPS information register records details of documents and information required or permitted to be published under s 8(2) and 8(4).
(b) Administering NICNAS’s IPS entry from May 2011
NICNAS will establish an internal working group to consider and finalise the IPS documents to be included in NICNAS’s IPS entry. This group will include representatives of all Programs and the Program Heads of the Compliance and Enforcement Program and Business Management & Communications Program.
To complete the IPS information register NICNAS will:
- review documents published on the NICNAS website (www.nicnas.gov.au) and identifying those documents that will form part of the NICNAS IPS entry
- identify potential IPS documents (including those not already published on the NICNAS website)
- review NICNAS’s current document management procedures to align with IPS administration
- compile a set of hard copy IPS documents that are not published on the NICNAS website and are not available electronically
- identify and review any IPS documents that are not accurate, up to date or complete.
The IPS information register will ultimately conform with accessibility requirements (WCAG 2.0 - see Objectives on page 2), through:
- describing the format of all IPS documents currently published on the NICNAS websites
- containing a link to an alternative format of an IPS document (preferably an RTF (rich text format) version), where the document is only available in Portable Document Format (PDF) on the NICNAS website
- containing a link to an RTF version and, if available, a searchable PDF for IPS documents that are not on the NICNAS website
- identifying any other issues that may affect publication of an IPS document on the NICNAS website.
From May 2011 each Program area of NICNAS will be responsible as required, for day to day tasks associated with complying with the IPS. Coordination of the Agency’s IPS will be undertaken the Program Head, Compliance & Enforcement Program.
NICNAS will publish in the IPS section of its website a list of any IPS documents that are impracticable to publish online and give details of how a person seeking access to any of these documents will be able to arrange access.
The list of documents will include indicative charges that may be imposed for making that information available and an explanation for the charge. These charges will be consistent with charges in the Freedom of Information (Charges) Regulations 1982 (which generally apply to access requests under Part III of the FOI Act).
IPS information architecture
NICNAS will publish its IPS entry on its website in accordance with the timetable at Annexure A (except where this is impracticable).
The IPS entry will be published on the NICNAS website (www.nicnas.gov.au) under the following headings:
- NICNAS IPS plan (ss 8(2)(a)
- NICNAS organisational information (ss 8(2)(b) and 8(2)(d))
- NICNAS role, functions and operational information (ss 8(2)(c) and 8(2)(j))
- NICNAS annual reports and responses to requests from Parliament (ss 8(2)(e) and 8(2)(h))
- Routinely requested information and disclosure log (ss 8(2)(g) and 11C)
- NICNAS Consultation arrangements (s 8(2)(f))
- NICNAS FOI and IPS contact details (s 8(2)(i))
- NICNAS business priorities and business plans (s 8(4))
- NICNAS finances (s 8(4))
- Submissions by NICNAS (s 8(4))
- NICNAS operational reviews (s 8(4))
- NICNAS legislative reforms (s 8(4))
To ensure that the NICNAS IPS entry (and individual IPS documents) is easily discoverable, understandable and machine-readable, NICNAS will:
- publish an IPS icon on the homepage of its website, which links to the IPS section of the website
- design and publish an IPS section on its website
- wherever possible, provide online content in a format that can be searched, copied and transformed
- update the sitemap on its website, to help individuals identify the location of information published under ss 8(2) and 8(4)
- provide URL addresses to the sitemap and agency plan from the NICNAS entry on www.directory.gov.au
- ensure the IPS entry is captured by the NICNAS website search function
- use existing mechanisms to notify subscribers of new publications or developments to the NICNAS IPS entry as soon as reasonable practical
- establish a feedback channel for seeking and responding to community feedback about whether NICNAS’ IPS entry (and individual IPS documents) is easily discoverable, understandable and machine-readable.
To conform to WCAG 2.0, NICNAS will:
- ensure that all online information that is published under the IPS ultimately conforms with WCAG 2.0 in accordance with the timeframes in Annexure A
- state on the dedicated IPS section of its website that where a person requires an alternative accessible format of a document that it will be made available on request.
- publish any new IPS documents as soon as they are available for publication
- ensure that all information newly published under the IPS on the NICNAS website conforms with WCAG 2.0 subject to a small number of exceptions identified in Annexure A.
Information required to be published under the IPS
NICNAS will publish documents required to be published under the IPS (s 8(2)) in the IPS section of the website at www.nicnas.gov.au/ips.
NICNAS will publish these documents in accordance with the timeframe set out in Annexure A.
NICNAS will publish these documents under the following headings:
NICNAS IPS plan
NICNAS Organisational information
- This will include an organisation chart, the Agency Employment Agreement and information about statutory appointments.
NICNAS Role, Functions, and Operational Information
- This will outline the functions and decision making powers of the Director, NICNAS.
- NICNAS will also publish guidelines relating to these functions and powers. This includes the NICNAS Handbook.
NICNAS Annual Reports and Responses to Requests from Parliament
- This will include the NICNAS’ recent annual reports (2007-2008 to 2009–2010) tabled in Parliament.
Routinely requested information and disclosure log
- This will include information in documents to which the NICNAS routinely gives access in response to FOI requests and information published under s 11C of the FOI Act.
NICNAS Consultation Arrangements
- This will include information about how and to whom a comment may be submitted by members of the public, where the NICNAS undertakes public consultation on a specific regulatory proposal.
NICNAS FOI and IPS Contact Details
- This will include the name, telephone number and an email address for a contact officer, who can be contacted about access to the NICNAS’ information or documents under the FOI Act. NICNAS has established generic telephone numbers and email addresses for this purpose that will not change with staff movements.
Other information to be published under the IPS
NICNAS will publish on the IPS section of its website other information that it holds (in addition to the information published under s 8(2)), taking into account the objects of the FOI Act (s 8(4)).
NICNAS will publish these documents in accordance with the timeframe set out in Annexure A.
Other information will be published under the following headings:
NICNAS Business Priorities and Business Plans
- This will include corporate and strategic plans, assessments and reviews.
- This will include financial information relating to pay and grading structures, procurement procedures, tendering and high-level budgetary information.
Submissions by NICNAS
- This will include submission made by NICNAS to Parliamentary committees, the Productivity Commissioner, the Australian Law Reform Commissioner and other agencies.
NICNAS Operational Reviews
- This will include details of internal and external reviews of NICNAS operations.
NICNAS Legislative Reforms
- This will provide a summary of current legislative reform activities and a link to how members of the public can contribute (NICNAS Consultation Arrangements).
In addition, in the IPS section the NICNAS website will publish a link to other publications not covered by these headings, including fact sheets, speeches and guidelines. A list of documents that are not practical to publish online will also be provided.
IPS compliance review
NICNAS will review and revise this agency plan at least annually, which will coincide with NICNAS’ strategic planning process.
NICNAS will review the operation of its IPS from time to time and at least every five years, in accordance with the guidelines issued by the Information Commissioner about IPS compliance review.
NICNAS will adopt the following criteria for measuring its performance:
- agency plan – has NICNAS published a comprehensive plan for its IPS compliance?
- Governance and administration – does the NICNAS have appropriate governance mechanisms in place to meet its IPS obligations, including a sound information management framework?
- IPS document holdings – has NICNAS reviewed its document holdings to decide what information must be published under s 8(2) and information that can be published under s 8(4)? Is the NICNAS’ IPS entry accurate, up-to-date and complete?
- IPS information architecture – does NICNAS have a publication framework in place and has it taken the necessary steps to ensure that information in its IPS entry is easily discoverable and accessible?
- Agency compliance review – does NICNAS have appropriate processes, systems and resources in place to monitor and review its IPS compliance and to make necessary improvements to its IPS implementation?
Indicative timetable – IPS conformance
NICNAS will ensure, to the extent possible, that all IPS documents re available on its website and conform to WCAG 2.0 in accordance with the following timetable (subject to exceptions described below):
||Indicative IPS conformance date
||All documents required to be published under s 8(2)
||RTF, PDF and/or HTML
||1 December 2011
||Optional information published under s 8(4)
||RTF, PDF and/or HTML
||1 April 2012
The majority of documents listed on the IPS section of the NICNAS website will be converted into HTML to meet accessibility requirements. A small number of exceptions may apply to:
- PDFs made of images of scanned documents
- Documents that are out of date, but that are provided for historical reference (these will be supplied in the formats in which they are currently available)
- Charts, tables and forms (these can be supplied in accessible formats on request).
Where possible, documents covered by these exceptions will be published in two alternative formats.