National Council of Self Insurers
CHAIRMAN	SECRETARY	
Darryl Turner	Gem Riegels	
Manager	Manager Workers Compensation	
Self Insurers of South Australia	Pacific National	
136 South Road	Level 12, 2 – 12 Macquarie Street	
TORRENSVILLE  SA  5031	PARRAMATTA  NSW 2150	
Telephone: (08) 8234 9522	Telephone:  (02) 9893 2763	
Fax:  (08) 8234 9533	Fax:  (02) 9893 2773	
E mail:  sisa@sisa.net.au	Mobile:  0404 048 763	

28 January, 2004

National Workers Compensation and OHS Inquiry
Productivity Commission
PO Box 80
Belconnen  ACT  2616

Dear Sir / Madam

RE: NATIONAL COUNCIL OF SELF INSURERS RESPONSE TO THE PRODUCTIVITY COMMISSION INTO NATIONAL WORKERS COMPENSATION AND OH&S.

The National Council of Self Insurers (NCSI) is largely supportive of the recommendations made in the Interim Report of the Productivity Commission.

The NCSI is particularly supportive of those recommendations specific to the establishment of a national self insurance framework for companies currently self insured, or insured in multiple jurisdictions.

Self insurance, which requires the direct accountability for management of Occupational Health Safety and Welfare, and Workers Compensation, should be encouraged in the interests of sustainable business development in Australia. 

The maintenance of a competitive position in the global marketplace is a real consideration in long-term strategic planning for all self-insured companies.

A properly constructed national self insurance framework would lead to greater efficiencies, offer significant savings to companies operating in more than one state and contribute to the ability for companies to compete in the global marketplace.

The preferred option of the NCSI is for an increase in choices for employers operating in more than one state such that they can choose from:

•	Access to national self-insurance under a modified Comcare framework, or :

•	A national framework involving mutual recognition, and consistency in licensing and audit requirements to satisfy self-insurance capability.

Consistency in these areas would reduce the costly and duplicative processes involved in satisfying the requirements of multiple regulators, whilst allowing self-insured companies to continue to operate within their state based legislative frameworks.

The NCSI does not support the existing Comcare scheme as a vehicle for a national self-insurance option.  However we understand that Comcare may provide a regulatory framework