I can well imagine that there are probably many submissions that are based more on opinions, emotions and personal perspectives than those based on objective facts to support a position. That must be very tedious to try to wade through.
Since 2000, I have usually worked with a small, committed group of people to go through the proposed legislation, prepare comments and make submissions. We have made quite an effort to leverage our collective knowledge, skills and experience in order to make meaningful submissions. It's quite disappointing to have these disregarded by regulatory agencies and personnel who cannot be bothered to read and consider with similar commitment.
All the same, I aim to do whatever I can to ensure I am appropriately informed and understand the issues. I can't control what they do with my submission, but I also live by the maxim that 'Silence implies consent." We really don't have justification to complain if we have not spoken up. I remember when the Health and Safety Reform Bill Discussion Document was issued, and members of NZISM met to hear from a legal expert what the issues were. The lawyer asked the group (probably about 40 people) who had actually read all or part of that voluminous document, and only 4 of us raised our hands! Yet this legal framework was going to be a key influence on the direction, activities and expectations of our profession!
I know people are busy with their jobs, but we all have the same amount of time every day; it's all about what you value enough to prioritize it. When we were reviewing the MBIE Discussion Documents, the people in our group were all very busy with their jobs during the day, so I invited them to come to my house one evening per week, working through one chapter each week for five weeks. We sat at my dining room table and worked solidly for about 1 1/2 hours, then we would have a cup of tea and some of my baking as we wrapped things up. At the end of our process, we had each made an individual submission as well as a group submission, which we copied to Responsible Care NZ as well. My key point here is that we were all committed enough to make it happen.
In addition, the collaborative approach adds immense value because the group discussions and contributions from a greater variety of individual perspectives and experience mean that each person finishes up understanding existing and proposed frameworks far more comprehensively - including what they ARE and what they ARE NOT, which equips us to manage and lead much more effectively.
In addition, the collaborative group approach has also given us the opportunity to share the load so it is easier to get through it. When changes to the Hazardous Substances Regulations were proposed more recently, one of the group members invited us to join her at her workplace for discussions. We agreed to divide up the regulations amongst members, with different people taking responsibility for the various parts of the regulations. At that time, I was least directly involved in handling hazardous substances, so I offered to take minutes of all our discussions, thus involving myself more deeply with the dialogue. The minutes were then available to each member of the group so they could develop their own individual submissions as well as having the notes for future reference in their own business.
Meanwhile, I live in hope that we won't have to keep running into metaphorical brick walls with ineffective / inappropriate regulatory frameworks, and that one day someone is going to listen a little more carefully to suggestions, rather than just waiting until the political pressure that develops from a disaster spurs them into action!
I was pleasantly surprised to see WorkSafe / MBIE taking the initiative and using a world café type approach last year, where they presented the context, then operated 3 short sessions with small groups around tables, each table with a specific theme to explore. Each table was attended by a representative of WorkSafe or MBIE, who collated comments, summed them up and presented them back at the end of the interactive session, then was charged with taking those comments back to the office to include in their considerations. It was a big step in the right direction in terms of achieving meaningful feedback, getting people involved, and supporting people to understand more of the regulatory requirements.