BRAY, Mr Ian, Divisional Assistant National Secretary, Maritime Union of Australia

KEANE, Mr Gary, National Official (Retired), Maritime Union of Australia

[15:20]

CHAIR: Welcome. I invite you both to make a brief opening statement before the committee asks questions.

Mr Bray : We thank the committee for initiating the inquiry in the first place and realise that it was the death in Western Australia that began the inquiry, but the problems in safety regulation in the maritime industry are much deeper. Our union has represented seafarers in the maritime industry for over 100 years and continues to represent workers across most sectors of the maritime industry: ferries, tugs, maritime construction, bunker barges, coastal trading vessels, dredging and the offshore oil and gas industry. Historically the maritime industry was one of the first sites for safety and labour regulation, due to the incentive for shipowners to cut corners for profit and the tragic loss of life when things go wrong. We have now come full circle, with sections of the maritime industry doing their best to remove as much regulation as possible. AMSA's Statement of regulatory approach describes its philosophy as:

Be non-prescriptive where possible, leaving choice to those who bear the responsibility for the outcome.

This leaves the choice with vessel owners. What about the safety of the passengers and the crew? The key problems for our union are the deregulatory approach to regulation, the lack of safety analysis and approach, the lack of resources, the approach to consultation and the legislative framework.

When we talk about the deregulatory approach to regulation, we're dealing with a number of areas, particularly the governance of AMSA through marine orders. Marine order 504, which is the safety management systems to determine vessel crewing, is under review. MO 47, the concept of penalty for operators of offshore installations, has been removed. I wish to bring to the committee's attention at this point that marine order 47 was brought about after the Key Biscayne, which was an offshore mobile drilling unit, was caught in a cyclone and capsized in 1983. There was an inquiry into the Key Biscayne at that particular time, and it was ascertained through that inquiry that there the reason there was loss of life—and it could be reduced incredibly—was that there was no marine crew on board with the capabilities or skill sets to man the lifeboats, or probably life rafts, on the rig. Marine order 47 instilled through the legislative framework that there must be marine crew on board these drilling units when they are in tow and not attached to the seabed. Now we have come full circle since 1983 and we want to review, and possibly put at potential risk again, workers on these drilling units when they're under tow.

AMSA is risking their reputation by lowering the inspection frequency for small passenger vessels from annually to five-yearly, proposed by marine order 31; continuing unnecessary exemptions to remove seafarers' rights, such as the government vessel exemption; making regulations to allow civilian nuclear powered vessels in Australia; and allowing Australian vessels to trade with PNG with only domestic qualifications. The recent draft of MO 505 to overhaul qualifications maintains two incompatible systems and has no correspondence with STCW. Instead of using the opportunity to streamline and simplify training and qualifications, include internationally recognised fishing qualifications, such as New Zealand has done, and provide for a progressive and safer regime, AMSA has simply cobbled together decades of exemptions and endorsements to reduce the level of qualifications required for most domestic seafarers.

There is a lack of safety analysis and approach. We believe that there is a safety crisis in the domestic commercial vessel industry, with a rate of fatalities that is between six and 18 times higher than the national average for Australian industries: 13 people died on DCVs in 2016-17 and nine people in 2017-18. We have not seen AMSA develop any measures to address this DCV safety crisis. We believe that one cause of the safety crisis is vessels operating with too few crew and with too little training. Qualifications designed for small inshore vessels are being used on large vessels operating up to 200 nautical miles offshore. In inshore waters, people are working in hazardous environments without enough training and backup from the WHS systems. Under the higher standards of the Navigation Act jurisdiction there has been about one fatality every four years, across very hazardous industries. In four years about 40 people died on DCVs. We believe also that there is a lack of resources and that funding has not kept up with the number of vessels they are required to regulate. In one particular address I note that the CEO, Mick Kinley, recognised this as a problem in determining that 10 per cent of the budget was allocated towards DCVs, domestic commercial vessels, but it was taking up 90 per cent of the resources.

There are problems with the approach to consultation. There has been a selective approach. There is no union involvement in the DCV industry reference group, despite multiple requests. In the recent round of MO 5 consultations in Townsville, one hour was scheduled and AMSA reps had to leave early. What we found is that they have just done a round of consultations in various parts of the country. They are allocating one hour to consult with industry, and in particular cases they have cut short that one hour because they had to meet plane flights to return to wherever it is they came from.

There are problems with the legislative framework. Responsibility is split between the DCV Act and the Navigation Act. I just want to draw your attention here: imagine if passenger planes flying between Perth and Sydney were subject to different safety regulations to a plane flying from Sydney to Bangkok, that if Virgin could do their risk assessments and decide that one pilot was sufficient, that a steward or stewardess didn't need to do safety training and have first aid certificates, that the plane needed to be inspected thoroughly only every five years or that they could hire a pilot with a recreational licence and no experience other than with a single-engine Cessna. It sounds ludicrous, yet this is the case with commercial vessels in Australia. Responsibility is split between AMSA and the WHS regulators. AMSA say they are not a safety regulator; state safety regulators say they're not maritime regulators. There's a clear gap in the understanding, hence leading to some of the confusion amongst not only the employers but also the workers, who have a duty of care to themselves, their workmates and their colleagues on board the vessels. That's a significant problem.

We thank the committee. It's an important crossroads with respect to maritime safety in Australia, and we appreciate the attention and assistance in trying to improve the situation. I want to close by quoting from one part of AMSA's right of reply to the Maritime Union's submission to this inquiry, which reads:

AMSA's proposed consultation on the marine orders is consistent with the policy statement by the Deputy Prime Minister on the National System for Domestic Commercial Vessel Safety. Specifically, that AMSA engage with industry on a range of important matters including:

the most efficient and effective ways to deliver services to industry

opportunities to reduce costs to industry without compromising safety and

ways to reduce administrative burden so industry can get on with the job.

Those words are quite reasonable—to diminish red tape and to diminish duplication—but here's the point: it says, 'Opportunities to reduce costs to industry without compromising safety', and we do not think that that has been achieved.

CHAIR: Thank you. Mr Keane, do you wish to make a statement?

Mr Keane : No, but we can take any questions. Probably the only other thing I would say is that, when we talk about the consultation process that was undertaken with some of the reviews with the marine orders, it wasn't just that the public consultation had a short time frame—and, as Ian said, some of those were cut short; we don't think the actual initial consultation process was in line with what the original COAG decision was when it went to a national law. There was never an intention to diminish or drop the standards of safety. Yet, when it went to a national law, the states had different levels of regulation and safety. At this round of reviews, the consultation process for the 505, for example, went to those states that originally had the lower standards. This is for domestic commercial vessels. It went to Queensland, the Northern Territory and Western Australia. Sydney Harbour and Port Phillip bay down in Melbourne—Sydney Harbour alone has more domestic commercial vessels on it than the rest of the country put together—weren't consulted. The operators in that area weren't consulted at all.

Senator STERLE: Because their standards are higher?

Mr Keane : They were at the time that they were going over to the national law. We think AMSA are walking away from the safety aspects of what they should be doing. When the national law was imposed, it wasn't the intention to totally deregulate the industry, and at the moment that's exactly where we're seeing this going—and it's going down to the lowest common denominator. We have no argument against them getting rid of duplication or red tape where they can, but it should never be at the expense of safety, especially in an industry that has a terrible history of deaths and injuries.

Senator BROCKMAN: I'll kick off with a question that I think goes to where you're coming from. I have absolutely no idea what the answer to this is. When you indicated that deregulation has caused an increase in the level of risk, was that borne out by the evidence? Have we seen an uptick in accidents and deaths?

Mr Bray : It's funny because one of our arguments was going to be that one thing that would improve the system would be to make uniform the two sets of qualification streams that AMSA is responsible for. While they're separated, you have a comparison with one system, which is the Navigation Act system, where there are relatively few injuries—probably one death every four years as opposed to 17 times the national average under the DCV model. That's an alarming statistic. Unfortunately, the statistics are relatively new. We don't have a historical database which we can rely on for evidence going back. Who knows? It may be that the mortality rate was the same before records were being kept. But I do think the way to improve it is safety—the uniformity of the qualification stream. The original concept was tinnie to tanker, so regardless of what area you worked or what vessel you worked on there was a pathway for you. But that also meant that the pathway was there so the qualifications could be improved on. If a worker wanted to attempt to better themselves or up their career path, they were in the same qualification stream.

Senator BROCKMAN: Okay.

CHAIR: I might go to Senator Patrick.

Senator PATRICK: I want to follow up the questions I asked the previous witness about complexity. We've now had a couple of witnesses—one in Western Australia and one here in Brisbane—who have suggested that, when the national law came in, a degree of complexity issues entered into the fray. Your opening statement indicated that, in some sense, responsibility is being directed back to the operator, perhaps at the expense of safety. I'm trying to reconcile. Is it your view that things would become more complex, or do you find that the consistency is more complex but also less effective?

Mr Keane : It depends on the state. Mr Kavanagh spoke earlier about two sets of certificates where one had existed previously. One existed in Western Australia. To my understanding, in New South Wales there were always two certificates. So how that stuff worked out varied from state to state. Some of what would have come over into the national law would have duplicated some of the higher standards, but we don't believe it duplicated enough of the higher standards.

In answer to Senator Brockman's question before about whether there has been any marked diminishing or increase in accidents or whatever: there is a large number of accidents across the board. In this industry, the more deregulation you give to allow operators to set the standards without a regulated process, the more dangerous it becomes. I can give you an example. In the Working Boats magazine, which is an AMSA publication, there was an article on the Spirit of Kangaroo Island which spoke quite glowingly about the vessel, the operation and everything it does. When the vessel was regulated by the South Australian government, the vessel was required to comply with the International Maritime Dangerous Goods Code. Along with segregated different classes of cargo to reduce the risk of a catastrophic event, one of the rules of the IMDG Code is that no more than 25 passengers can be carried at the same time as dangerous goods. Since AMSA overtook the regulations of the DCB fleet, there has been no requirement for the vessel to comply with the IMDG.

Chris Ha, the SeaLink compliance manager, boasts in the article that the vessel can transport up to 244 passengers along with road tankers full of LPG, diesel and petrol. The company has also decided that additional crew to manage the combined risk of hundreds of passengers and dangerous goods is not worth the additional cost. I think that answers your question; in fact, it is not what could happen but what has happened. In one move you've taken 25 passengers and increased them to 244 and are still carrying explosives and other potentially very dangerous cargoes on that same boat. That's not what the international code was put in place for. The international code minimised those numbers of people intentionally.

Senator STERLE: So nothing would stop PNL or someone saying, 'We might cut this cruise ship in half and in the other half cart LNG or LPG and fuel. Are we serious? Sorry; I know you're serious. I'll wait my turn.

Senator PATRICK: In that instance, doesn't it get covered by the survey certificate? Surely the survey certificate goes, to some extent, to the purpose of the visit?

Mr Keane : AMSA would now allow it to increase their numbers.

Mr Bray : Under the new system, all the company would need to do is identify its own safety case, tick off on its own safety case and put it to AMSA. It's likely to be approved.

Mr Keane : There were some basic issues raised about part of the recommendations around the review of 505 at some of the earlier consultation meetings with the industry that half the people in the room were absolutely aghast at, such as the idea of taking medical certificates out of the general purpose training, for example. When that was raised, each of the people in the industry who were in the room said: 'Hang on a minute. That means that if you're on a ferry the only bloke who'd have the actual medical, St John's training would be the skipper, and he's driving the boat. It doesn't make sense.'

Senator PATRICK: But you say that the ability to do this is the result of the change to the national law. Is that what you're attributing this to?

Mr Keane : No. The change to the national law really changed the structure of regulated Australian vessels and domestic commercial vessels and has allowed far greater access for vessels to become domestic commercial vessels and then come under the lesser requirements that pertain under the law as opposed to international standards.

Senator PATRICK: Okay. Thank you.

Senator STERLE: I have been working closely with the MUA for about 28 years, would you believe? We were a lot younger, then, Mr Bray, weren't we? I just wanted to get that out, because I've been an absolute champion of Australian shipping, Australian seafarers and Australian stevedores. I want to touch a little bit on a couple of things. We talk about 505. When we start talking about rolling back the certificate of competence, gentlemen, what could be the dire consequences? I'm not thinking this will be the next Hollywood movie, but where are we actually taking this nation? What path are we taking our nation down when we think it's a good idea to water it down? Have you had any feedback on that? Can you shine a light on that?

Mr Bray : We are as dumbfounded as you are. I think there is an opportunity in all of this. They are currently presiding over two systems—the Navigation Act and the national law. They should streamline it as much as possible and benchmark it to the system, or the systems, that are proven to be effective and to work. You don't have to throw the whole lot out and start again. If one system is appropriately treating people and appropriately holding in place the systems that keep the workplaces safe and enforce compliance not only from the company that is the employer but from the workers themselves that operate on these vessels in a safe way, you can take that and enhance it and make it uniform across to the system that has the gaps. So, in effect, you could establish one qualification stream, one career path and one system that everybody can consistently work to and understand and learn from without crossing from the national law to the Navigation Act, which is causing confusion. Then they could apply more resources to the education and training that is required to make those people who are struggling—and I refer to Mr Kavanagh's comments previously about the known cowboys in the industry—face greater scrutiny, because they'd have the resources to do it. There are two systems there. One's working and one's not up to scratch. The question for them, I guess, is: what do they intend to do to make it more compatible?

Senator STERLE: The thing is, Mr Bray, you don't have to be Einstein up the front here to work out that you guys and the industry sit on many boards, panels and conferences and you all have to try to remember which one you're under at the time you're sitting in the same room. What's industry's view on that? Are they joined at the hip with you guys or are they running off on another tangent?

Mr Bray : We obviously have differences from time to time, but there is equal concern amongst employers and employer groups around the lack of training, for example. I can't speak on their behalf but I can quote what their concern is, and that is MIAL, which is the Maritime Industry Australia Ltd. It represents the Australian shipowners. They've identified that the national law system is probably leading to a future de-skilling of Australia because, under the national law, with the certification that's held, you'll get no marine surveyors from it and you won't get your pilots from it—they guide the bigger ships into the ports. It has actually primed the industry to de-skill itself, which means we won't have the skills or capacity to bring these ships in, so we'll have an ineffective maritime function.

Senator STERLE: I have had conversations with the MUI, the maritime unions and MIAL, and with the shipowners. For the rest of the committee it poses an interesting question, one that has been made very clear to me over the years, which is: before Defence takes ownership of a ship, who does all that work? Is there an answer? Before they hand over to Defence, before Defence actually takes the ships, who does all that work leading into it?

Mr Bray : We do.

Senator STERLE: We'll talk about it. I think it's important that you get this out. I know you do, because we've spoken about this. So, if we haven't got a merchant navy—hello!

Mr Keane : TK has done the crewing for quite a few vessels over the last couple of years when they're basically in the process of being run in or being tested. Our guys go on board and do those safety inspections. When they're going on board they have a requirement for minimum crewing, they have a requirement for minimum standards—they have all those requirements that sit there as part of the STCW compliance. That goes away for anything that's now declared a DCV. Basically, we don't think the current system for regulating DCVs is fit for purpose. It needs a complete overhaul based on keeping crew and passengers safe and providing a clear and consistent way forward to the next generation.

Senator STERLE: What I'm saying for my committee colleagues is that while some sectors think it's a good idea to down-skill our merchant navy—the nursery, for want of a better term—all these skippers and masters and engineers are bred on domestic shipping. It's pretty simple. So I can't see, colleagues, where the intelligence is. What are we going to do—import foreign seafarers to do all the training on our defence ships? Anyway, that's just something that I—

CHAIR: Are you done?

Senator STERLE: No, I'm just warming up.

CHAIR: You're just warming up. Would you mind if I—

Senator STERLE: No, I will wait. I'm mindful of the time.

CHAIR: Thank you.

Senator STERLE: When we start talking about the demise of the Australian shipping industry, I grow another leg!

CHAIR: I can see that.

Senator RENNICK: On recommendation No. 7, when you say you think there probably should be more resources made available to AMSA, can you quantify that? Do you have any idea how undermanned they are?

Mr Bray : In terms of the appropriate resources, I think there are two parts to that. One is appropriate resource allocation, and I go back to my opening statement where we said that 10 per cent of the budget is allocated to DCV but 90 per cent of the resources are spent there. That's a question for AMSA and a challenge for AMSA to work out appropriately. So too is determining the better resources. We think that if you have a look at the two systems, have a look at—and genuinely have a look at—streamlining them to one set of qualifications rather than a qualification stream, and one set of compliance issues, that would alleviate some of the duplication and free up some of the resources. But we think that one part of the additional resources would then be in managing the regulatory regime and all of the marine orders, and the other part of it would be the compliance inspectorate. There is an over-reliance by AMSA on using other regulatory bodies as an inspectorate, and we think that that's a—

Senator RENNICK: What bodies are they?

Mr Bray : The WorkSafes. They'll have various MOUs with various safety regulators around the coast. We see that as more of a reactionary than a proactive process. If there were compliance and they did what they did in a previous life, when they were just operating the Navigation Act, we would say that they were more proactive in getting out and inspecting these vessels and issuing improvement notices before things went wrong rather than dealing with whether to prosecute or not after something went wrong. We feel that those resources would be better utilised upfront in a proactive measure to mitigate some of those risks.

Senator RENNICK: The previous witnesses are, I think, pushing a safety management system. What's your view on that?

Mr Keane : It's interesting that they're pushing safety management. I went to a consultation for the fishing industry with local fishermen at Jervis Bay the other day. They sat there and spent a considerable amount of time with the guys. The people who were representing AMSA were quite good. They were very patient with the guys and went through how to do a risk assessment and how to do the safety management systems. One of the guys in the room said: 'Mate, this is all good, but the blokes you have in this room are the only guys who are actually concerned with safety. What are you going to do with the cowboys? They're not going to be here. They're not going to learn that.' Safety management systems are quite good and it's about common sense. We agree with it across the board, but it must be underpinned by decent regulation. There really isn't an industry in the country now that doesn't do some risk assessment for everything they do, but there should be some minimum standards that they have to comply with. That example—

Senator RENNICK: The issue with the safety management system is that it's not compulsory.

Mr Bray : It's not and it doesn't do anything. It's not until after the event when something goes wrong and they have to prosecute. The Spirit of 1770 is a prime example. That guy was prosecuted for using his phone rather than the radio, because it was written that way in the SMS. It's ludicrous; it's madness. But that's what these guys will be facing when they're just learning how to do this. That was for guys who were fishing inshore—basically not going more than a mile or two out, like a lot of lobster divers and that sort of thing. There are the regulations—and remember: they have to do their own systems. Compile that out when you go onto trading vessels—proper commercial vessels that are carrying cargo. If they're allowed to have their own minimum safety standards or are allowed to take somebody on board who's done a three-day course to become a GPH and, all of a sudden, they can work 200 miles out to sea—that was never the intention of the GPH course, but that's what's going to come out of some of this. It's quite funny that, when we're talking about doing risk assessments and safety management service, I want to know who's done the risk assessment on making some of these changes from AMSA's position, because we don't see any data that backs up any need for these changes. They're deregulating the industry and dumbing down our qualifications.

Senator RENNICK: If that safety management system covered what you recommend on page 50—minimum vessel crewing, minimum seafarer qualifications and vessel area of operations—would that be better? Maybe every ship has a safety management system and you could put those three things in there.

Mr Keane : Yes.

Mr Bray : It would be a really good start as a safety base to work from.

Mr Keane : We think there are some complications with this where they're trying to appease the fishing industry and not overregulate what they do. There's an ability to split that off. I think we mentioned that in the submission. We're not adverse to that. But, once you're talking about a DCV that's carrying cargo or an oceangoing vessel, they have to have those minimum requirements as a regulation.

Senator RENNICK: Thank you.

Senator BROCKMAN: On the same area, this committee is trying to tackle what you brought up in passing, Mr Bray, in your opening statement: the role of CASA and the airline industry. But we hear—this committee in particular pretty constantly hears—from the general aviation sector that the level of regulation is actually strangling them and general aviation is in decline as a result. Do you have any views as to whether a more prescriptive regime would actually potentially weaken the sector rather than strengthening it?

Mr Keane : You'd have to ask: would any of the people that are raising those concerns agree to dumb down the training for their pilots? A couple of us went before the Productivity Commission and we were talking to them about general stuff and how the act has gone since it was implemented—they had to do their own review. We raised then some of the issues that we've raised here today. One of the people on the committee that came out of the industry said, 'We would not consider that if it were the aviation industry.' He said that could not be considered in the aviation industry. Yet we do it every day on vessels that are carrying passengers, carrying equal numbers—all that sort of stuff. So, to answer your question, I don't think dumbing down any part of the training or dropping qualifications can benefit any industry particularly.

Senator BROCKMAN: No. I wasn't talking about qualifications in particular. I was talking about the level of oversight, the level of bureaucracy and the level of box-ticking that inevitably comes with increased regulation.

Mr Bray : As a seafarer—and I spent 19 years on various vessels in various parts of the industry—I would say that we can always look at improving the bureaucracy and the efficiencies around red tape. There's no issue with that. One of the things that I remember seafarers largely complained about when they were at sea was that they had their job to do and then they had to do the paperwork. Those functions were getting more and more overbearing and it was leading to issues in relation to fatigue. So in fact those bureaucratic processes and the paper shuffling were in themselves placing a greater burden on safety.

However, having said that, seafarers were professional in every standard, in every way. I wouldn't say that they behaved that way 100 per cent of the time, but in their life on board a ship, when they went to sea, they knew that the best lifeboat was the ship that they were on and not the lifesaving apparatus that you were reliant on. In that way, they went about their roles diligently. If you asked a seafarer back then, they would tell you that, yes, they had the shits with the bureaucratic processes—no doubt. But, if you said to them, 'Let's go after efficiencies and erode some of the safety standards or conditions or the professionalisms under the qualification', you would have got kick-back and concern.

I will give you this example. I left the Aurora Australis in 1996. I had spent five years on there. That's the icebreaker that goes down to Antarctica. Three of those crew members were in my bridal party when I married my wife. I left the ship and they sailed and it caught fire on that next trip. They had to fight the fire. It was an engine room fire. They spent 24 hours fighting the fire because the fuelling process for the fire was a split fuel hose. So the fuel was spraying out and they couldn't get down to shut the fuel off, so it was just spraying out and melting the ship, down there at sea. They got the fire out eventually—someone got in and risked their life and shut the fuel down—and they had to rebuild two melted engines to get back to sea. One of the things that they all said in the debriefs was: had they not been trained and had the safety systems in place on that ship, it wasn't only the crew that was facing loss of life; there were 109 expeditioners on board at that particular time.

I can only go back to those work colleagues of mine, who are my friends in personal life as well. They say to us that it was a time when the investment in training, knowledge and process actually worked. They never want to have a second go at trying it, but it worked at the time and it didn't fail them then. Our job, and our obligation, is to make sure that it doesn't fail for a future cruise in those particular circumstances.

CHAIR: Perhaps one more question, Senator Brown. I'm just conscious of time.

Senator CAROL BROWN: Yes, I can see that we're coming up to four o'clock, but I want to ask about this: you talked about exemptions when you were talking about Marine Order 505. How does that work? Do exemptions cover the whole marine order?

Senator STERLE: I'm keen to follow this up in our shipping inquiry too.

Mr Keane : Yes, and this comes back to Senator Brockman's issue earlier. This part of the reviews isn't complete. There are some proposals in there that may not get through or may get through—whatever. But the proposals themselves, which diminish the standards, to us are a concern across the board. This has been stated in some of the consultation processes: the exemptions have been given out, in our view, too easily across many of the 505s and all of the marine orders at different times.

The intention there, as part of this review, was to take what we think already aren't sufficient regulations down to the level of the exemptions that were given. They've given those exemptions on specific grounds, but now you just take the standard down to that level from the outset, across the board for everybody. Why have them in the first place? With the exemptions themselves, there are obviously some aspects of them that are necessary. The grandfathering was mentioned before. We think that's overdone to a certain extent. It just keeps getting rolled. But, to us, the idea of taking a marine order down to the level of what an exemption has given in the first place is an example of where that stuff's heading.

Mr Bray : If I might add something, a lot of these exemptions are given to various employers around the country on the basis that they can't comply with the requirement, so they're exempted. Then they want to see the exemptions included in the whole regime. So we've gone from a position where the majority of operators are complying and there are a few who can't meet those compliance issues, so they get exemptions, to saying, 'Well, everybody's exempt, so therefore there is no compliance issue; no-one needs to comply with anything.' So it's a race to the bottom.

Mr Keane : Again, there's been no risk assessment. There's no data that we've seen that says that AMSA itself has done a risk assessment on what the requirements for those are.

Senator CAROL BROWN: Just on that, you've said before that you haven't been able to see any risk assessment by AMSA, but are you aware of any study that AMSA has commissioned on safety in DCVs?

Mr Bray : No.

Senator CAROL BROWN: Nothing at all?

Mr Bray : No.

Senator CAROL BROWN: Have they commissioned any study into any—

Mr Bray : Not that we're aware of. Again, the reviews are taking standards that we think are already too low down much lower.

CHAIR: Thank you for your time and the evidence you've given this afternoon.

Proceedings suspended from 16:03 to 16:14