SUBMISSIONS ON THE REVIEW OF THE ENVIRONMENTAL MANAGEMENT AND CO-ORDINATION (CONTROLLED SUBSTANCES) REGULATIONS, 2007

Natural Justice proposes several amendments to Kenya's 2007 Controlled Substances Regulations to strengthen the management of ozone-depleting substances. Key recommendations include requiring the list of controlled substances to be reviewed every 3 to 5 years, increasing transparency through the gazetting of licensing decisions and public access to registers, and enhancing accountability by reporting accidental disposals to the Ozone Secretariat and NEMA within 24 hours. The organization also advocates for the removal of exemptions for controlled substances, the introduction of monetary fines for illegal procurement, and the expansion of deposit bonds to manufacturers, exporters, and importers to prevent environmental damage.

• Natural Justice proposes that the Competent Authority review the list of controlled substances every 3 to 5 years to ensure the law reflects new scientific discoveries regarding substances harmful to the ozone layer.
• To align national lists with international standards, the organization suggests that the Authority consult with the Ozone Secretariat and the Secretariat of the Multilateral Fund for the implementation of the Montreal Protocol.
• The submission recommends a new requirement to report any accidental disposal of controlled substances likely to cause environmental harm to both NEMA and the Ozone Secretariat within 24 hours.
• Natural Justice advocates for increased transparency and public participation, proposing that licensing decisions be officially Gazetted and that the register of controlled substances be made a public document available for inspection.
• The organization argues against exempting any controlled substances from regulation, citing the global climate crisis and the precautionary principle.
• To increase deterrence, the submission suggests imposing monetary fines for illegal procurement of controlled substances and reviewing the general penalty of a fine up to Ksh. 350,000 or 18 months imprisonment, which it describes as "very lenient".

APA

Birgen, R. (2020). SUBMISSIONS ON THE REVIEW OF THE ENVIRONMENTAL MANAGEMENT AND CO-ORDINATION (CONTROLLED SUBSTANCES) REGULATIONS, 2007. Natural Justice. https://naturaljustice.org/wp-content/uploads/2020/05/NJ_NEMA_Review-of-EIA-Regulations-on-Ozone-Depleting-Substances_SB.2020_20_1.pdf

Chicago

Birgen, Rose. SUBMISSIONS ON THE REVIEW OF THE ENVIRONMENTAL MANAGEMENT AND CO-ORDINATION (CONTROLLED SUBSTANCES) REGULATIONS, 2007. Natural Justice, 2020. https://naturaljustice.org/wp-content/uploads/2020/05/NJ_NEMA_Review-of-EIA-Regulations-on-Ozone-Depleting-Substances_SB.2020_20_1.pdf.

Wikipedia

{{cite press release |last1=Birgen |first1=Rose |title=SUBMISSIONS ON THE REVIEW OF THE ENVIRONMENTAL MANAGEMENT AND CO-ORDINATION (CONTROLLED SUBSTANCES) REGULATIONS, 2007 |publisher=Natural Justice |date=6 March 2020 |url=https://naturaljustice.org/wp-content/uploads/2020/05/NJ_NEMA_Review-of-EIA-Regulations-on-Ozone-Depleting-Substances_SB.2020_20_1.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{birgen2020submissions, author = {Birgen, Rose}, title = {{SUBMISSIONS ON THE REVIEW OF THE ENVIRONMENTAL MANAGEMENT AND CO-ORDINATION (CONTROLLED SUBSTANCES) REGULATIONS, 2007}}, publisher = {Natural Justice}, year = {2020}, month = mar, url = {https://naturaljustice.org/wp-content/uploads/2020/05/NJ_NEMA_Review-of-EIA-Regulations-on-Ozone-Depleting-Substances_SB.2020_20_1.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }