The Shooting Industry Foundation of Australia (SIFA), recognises that:
- Under the Australian Constitution, the states and territories have primary responsibility for the management of firearms in Australia.
- The Commonwealth has responsibility for international and inter-state trafficking offences and the import and the export of firearms and firearm-related articles.
- Consultation typically occurs at a jurisdictional level; however, the Firearms and Weapons Policy Working Group (FWPWG) brings together firearm registry managers and policy representatives from all jurisdictions and is accountable for delivering national consistency in firearm regulation.
- The core of the regulatory challenges facing the Australian shooting industry is that firearms are viewed as an operational law enforcement matter rather than a matter of sensible and impartial industry regulation. This myopic approach shapes the regulators style and attitudes towards consultation.
- Prior to amending firearms regulation, Governments must conduct appropriate and genuine stakeholder consultation to understand the full impact of any proposed regulatory changes.
- Regulators must conduct themselves in a manner which is consistent with the Principles of Best Practice Regulation and the Regulator Performance Framework.
- SIFA will strive to make a constructive contribution to any stakeholder engagement process it is involved in.
- For SIFA to lend its support to proposed regulatory changes following a consultation process.
- The regulator must clearly articulate the risk to community safety that they are seeking to mitigate.
- The evidence of this risk must be provided in detail.
- SIFA needs to understand how the proposed process or provision and its administration / compliance monitoring and enforcement is intended to control / mitigate the risk.
- The consultation must assess existing controls already in place and consider their effectiveness. (i.e., often an activity / action is already illegal but existing compliance monitoring and enforcement is ineffective – addressing the shortfalls in regulator effectiveness may be a better approach).
- All alternatives must be explored and actively considered, and all red tape reduction tests must have been applied.
- If a risk demonstrably needs to be controlled, it is controlled once at the most effective point.