Submissions to the 2012 Review of the National Industrial Chemicals Notification and Assessment Scheme - DIC Australia P/L

The Discussion Paper: Review of the National Industrial Chemicals Notification and Assessment Scheme (NICNAS)–June 2012 was released on 1 June 2012. Submissions were received betweeen 1 June and 27 July 2012. The comments received from this consultation process will be used to inform the government of stakeholder views

Page last updated: 20 August 2012

PDF printable version of DIC Australia P/L submission (PDF 77 KB)

DIC Australia P/L
Frederick Vale
Compliance Manager
03 9552 4560
03 9558 0155
0439 966 390
323 Chisholm Road
Auburn NSW 2144

Postal address:
42 Sunmore Close
Heatherton VIC 3202

Summary

The current process and cost involved with the registration of new chemicals is a major roadblock to the introduction of new technology into the Australian market.

In DIC Australia’s specific case we import printing inks from our oversea [sic] affiliates who are world leaders in printing ink technology particularly in the area of low migration products used for the printing of food packaging. With the ever increasing concerns with the contamination of food from external sources particularly packaging materials it is important that the printing inks used have the lowest possible potential for migration out of the printed images and the packaged food. These low migration inks involves the of high molecular weight materials that will be trapped fully in the ink matrix once it is cured. Generating toxicological and other data or sourcing it from third parties can be difficult and expensive making it uneconomic or viable to sell the inks in the Australian market. This is normally a duplication of a registration process that has already been carried out in other international bodies like Reach or Tosca.

Part 4—The regulatory framework for industrial chemicals (options A1—A3)

DIC Australia Preference—A1
There needs to be an overall regulatory framework governing the risk of industrial and other chemicals being imported into Australia. This also needs to recognize other similar entities around the work and establish a legal platform for exchange and recognition of their data and assesements [sic]

Part 5—New industrial chemicals (options B1-B6)

DIC Australia Preference—Combinations of B1, B2 &B4
Review the current volume thresholds and harmonize with other overseas bodies where possible and also consider new or expanded exemptions.

Options B3 & B5 would be a too bigger impost or cumbersome on industry and open to abuse. The proposal in B5 to remove materials from AICS is unacceptable unless a material has been found to be a severe potential hazard to human safety.

The confidentiality period of 5 years needs to be extended to 10 years in line with patent protection as it can take over five years to develop a new product range in the market place.

Part 6—Existing industrial chemicals (options C1-C6)

DIC Australia is not fully in favour of any of the options and particularly opposed to option C5.

The treatment of existing chemicals and PEC’s should be updated based on acceptable oversea data (e.g. Reach)

Part 7—Post-market monitoring and enforcement (Options D1-D3)

DIC Australia preference is option D1 as long as the documentation and reporting requirements on industry are kept to a minimum.

Part 8—Other reforms—release of information and confidential commercial information (Options E1-E2)

DIC Australia has not issue with the current release practices of information by NICNAS, but would prefer the confidentiality period increased as indicated in part 5.

Part 8—Other reforms—use of foreign schemes / international assessments (Options F1-F2)

DIC Australia Preference—F2
It is imperative that for new technologies to be introduced into Australia in a timely and cost effective manner that NICNAS accepts data and assessments carried out by internationally respected agencies and schemes like the EU Reach, US Tosca etc.

Part 8—Other reforms—chemicals in articles (Options G1-G2)

DIC Australia Preference—G2

Part 8—Other reforms—chemicals in cosmetics (Option H1-H2)

DIC Australia does not import any materials for cosmetics.

Part 8—Other reforms—Import and export of chemicals under the Stockholm and Rotterdam Conventions (Option I1-I2)

DIC Australia has no issue with the current situation.

Part 8—Other reforms—Governance—Committees (Option J1)

NICNAS stakeholder meeting are a good starting point for getting feedback on reforms.

Part 8—Other reforms—Governance—Relationship with the Department of Health and Ageing (DoHA) (Option K1)

This always needs to be an ongoing process.Return to top

A full list of all 2012 submissions can be viewed at June 2012 submissions to the review of NICNAS.