1.
The ACCC considers the status quo and proposes three options to improve the safety of button
batteries. Which is your preferred option and why do you prefer it to the others?
The ACCC considers the status quo and proposes three options to improve the safety of button batteries. Which is your preferred option and why do you prefer it to the others?
Option 3. It provides the most protection to reduce risk.
2.
What effect do you believe each of the proposed options will have in saving lives and reducing
severe injuries caused by button batteries?
What effect do you believe each of the proposed options will have in saving lives and reducing severe injuries caused by button batteries?
Each hurdle presented is another opportunity to reduce injury and save lives. Increased safety of secure battery compartments is essential, child-resistant packaging will stop child trying to get the battery themselves and increased warnings/instructions make carers more aware for the risks.
3.
Provide comment on the ACCC’s essential requirements for secure battery compartments,
child-resistant packaging and warnings and information. Are there any additional requirements
that should be included?
Provide comment on the ACCC’s essential requirements for secure battery compartments, child resistant packaging and warnings and information. Are there any additional requirements that should be included?
Some ideas of other requirements may be:
1. Reusable child-resistant packaging - in it's current format once a pack is opened it provided no further safety unless the carer packs it away securely from the child/ren
2. There is still some risk to hearing aid batteries and child visiting homes where they may be present. E.g. grandchild visit and grandparent dropped battery on floor and couldn't find it or they can't pick it up themselves and it was forgotten. Not sure what do be done in these cases but still poses a risk.
3. A secure child-resistant container to hold hearing aid batteries once used. Collected in one container and then returned a recycling facility or collection point.
4.
In relation to the requirement for secure battery compartments in which button batteries are only
accessible with the use of a tool, do you consider that the use of a ‘tool’ should include the use of a
coin? Why/why not?
In relation to the requirement for secure battery compartments in which button batteries are only accessible with the use of a tool, do you consider that the use of a ‘tool’ should include the use of a coin? Why/why not?
No. Too easy for them to be manipulated with something other than a coin or too easy for a child to see how to change it after seeing a parent/carer do it.
5.
Do you supply products that currently meet the essential requirements for secure battery
compartments, child-resistant packaging and warnings and information? If not, which
requirements do your products not meet and why?
Do you supply products that currently meet the essential requirements for secure battery compartments, child resistant packaging and warnings and information? If not, which requirements do your products not meet and why?
No, we are an industry association they represents sectors they use button batteries.
6.
Provide comment on the ACCC’s proposed information standard for warnings and information to
be made available at point of sale. Are there any additional requirements that should be included
for products sold online, or for unpackaged products supplied to consumers?
Provide comment on the ACCC’s proposed information standard for warnings and information to be made available at point of sale. Are there any additional requirements that should be included for products sold online, or for unpackaged products supplied to consumers?
Unsure.
Consultation Paper Questions 8 - 14
8.
Do you agree with the proposed exemption for hearing aid devices and associated zinc air
batteries? Please explain your reasons. (See section 5.2)
Do you agree with the proposed exemption for hearing aid devices and associated zinc air batteries? Why/why not? (see Section 5.3)
Not fully. Previously explained.
9.
Do you consider that any other categories of consumer goods should be exempt from any of
the proposed requirements? Do you have information and data you can provide to the ACCC in
support of your view?
Do you consider that any other categories of consumer goods should be exempt from any of the proposed requirements? Do you have information and data you can provide to the ACCC in support of your view?
No
10 .
What are the likely costs to implement each of the requirements (design changes, child resistant
packaging, labelling), and what do you consider is the likely effect on prices for consumers?
What are the likely costs to implement each of the requirements (design changes, child resistant packaging, labelling), and what do you consider is the likely effect on prices for consumers?
Unsure
11.
Do you think that all potential costs to business have been considered? Can you provide any
further information about the likely cost and impact of each of the options?
Do you think that all potential costs to business have been considered? Can you provide any further information about the likely cost and impact of each of the options?
N/A
12.
Provide comment on the transition period for the proposed options. (See section 7)
Provide comment on the transition period for the proposed options (see Section 7).
12 months is sufficient
13.
Provide comment on the principles-based approach to a mandatory safety standard. (See
section 7.2)
Provide comment on the principles based approach to a mandatory safety standard (see Section 7.2). A principles based approach: • Sets out safety principles that need to be met rather than specifying detailed standards • Incorporates external instruments for compliance tests only • Includes administrative guidance which provides examples of relevant clauses in external standards that are considered to comply with each requirement.
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14.
Provide any additional information or data that you think may be useful for informing the ACCC’s
recommendation to the Minister.
Provide any additional information or data that you think may be useful for informing the ACCC’s recommendation to the Minister.