Exempted Introduction Chemicals & AICIS (formerly NICNAS):

Haztech Environmental is Still Concerned

Jeff Simpson’s 18th October 2018 Comments from:

Hazmat & Environment Notes August-October 2018

General Rules & Categorisation Guidelines – Comments

Comment a/: There is a lot of work to obtain and document information to meet the General Rules and Categorisation Guidelines, particularly for the Exempted Introduction Chemicals. I suggest that the costs to create and maintain these documents over time will be expensive and that the specialists (who I suggest will need to be specialised toxicologists) who can prepare them will need to be like Environmental Auditors, as they will need to be able to sign off that they have met the requirements. There is quite a significant liability for consultants to do this for other entities, that will only be realised when the Industrial Chemical Authority arrives to do a detailed audit, maybe several years after being prepared and there is no longer an association with the consultant.

Comment b/: I suggest a simplified approach be decided for the Exempted Introduction Chemicals where an abbreviated set of information is able to be provided by a lower level chemical specialist (such as qualified chemist) where the chemical name, the CAS No., the presentation of the chemical and the likely uses, are provided to the Authority AND the Authority is paid to keep track of these chemicals and then alerts the importers where an increased hazard of the Exempted Introduction Chemical decides a review is needed.

This then provides a simplified route of introduction, where the expertise of the Authority is paid for and utilised by the importer, particularly for small trading businesses that don’t have easy access to such specialist expertise.

Comment c/: As the data behind the Reports will normally be confidential, how does the Authority expect to obtain access to the confidential documentation behind the Exempted Introduction Chemical Reports? This information is typically held in highly protected databases (such as SAP). It is very unlikely that access by the Authority to the underlying data will be allowed.

Comment d/: We need to put in place an industrial chemicals system that can also be reasonably implemented by New Zealand under the TTMRA, so Australia & New Zealand can eventually be one system to introduce Exempted Introduction Chemicals.

Australia originally agreed to align its industrial chemicals management system with NZ by 2019. The proposed reforms have NOT addressed this in any way.

IF we are more pragmatic about our Exempted Introduction Chemicals, and then pay and rely on the Industrial Chemical Authority to track increases in hazards, this would move Australia to a lower cost system. NZ also needs to manage its “non-hazardous” chemicals.  Australia needs to put in place an industrial chemicals Exempted Introduction Chemicals system that can eventually be reasonably implemented by New Zealand to also manage its “non-hazardous” chemicals.

Comment e/: As a concerned specialist chemical regulatory consultant and also a concerned member of the community, we need an industrial chemicals system for Exempted Introduction Chemicals that will work for at least several decades, with minimum ongoing costs, whilst achieving proper management of ALL Exempted Chemicals in both Australia and NZ and capturing Exempted Introduction Chemicals that increase in hazard.

Request for Feedback: Please review my comments and contact me by email: Jeff.Simpson@haztech.com.au  or 0403 072 092.

I consider it is important for us all to alert Federal Parliament politicians to this issue so that it is recognised that AICIS (formerly NICNAS) must accommodate this issue.