PDF printable version of Lanxess Pty Ltd submission (PDF 52 KB)
Lanxess Pty. Ltd. (wholly owned subsidiary of Lanxess AG.)
Phone: (02) 8748 3925
Mobile: 0418 264 377
Unit 1, 31 Hill Rd
Homebush Bay NSW 2127
PO Box 6365
Silverwater NSW 2128
Review of the National Industrial Chemicals Notification and Assessment Scheme (NICNAS)
Part 8—Other reforms—use of foreign schemes/ international assessments (Options F1-F2)
Australian manufacturers need prompt and straightforward access to new (often greener and more efficient) chemical and polymer technologies as a key component in their quest for survival in what is widely acknowledged as a critical time in Australian manufacturing. Only those manufacturers with a significant "knowledge" component will survive in a high labour cost and high compliance cost country.
NICNAS should accept assessments by nominated foreign-country assessment authorities. This will result in significant improvements in productivity and reduced costs for importers and therefore the Australia-based manufacturers that require industrial chemicals and polymers as local manufacturing raw materials.
Concerns around the risks under such an arrangement can be managed through ensuring that only countries known to have an acceptable assessment program and with similar (or lower) appetite for risk to Australia.
In terms of new chemicals, a large majority of those proposed for new import to Australia originate from leading edge technology companies based in countries with already stringent regulatory regimes, e.g. the USA and the EU. The strength of the EPA (US) and REACH (EU) schemes in place in these countries are unlikely to pose significant risks to Australia if their approvals are recognized in some integrated manner.
Through this step alone, it is envisaged that a significant administrative and assessment workload could be eliminated with minimum risk, enabling NICNAS to focus on other aspects of their role (existing or yet-to-be defined).
Depending on the number of new chemicals and polymers that would fall within this proposal, there is also an opportunity for a significant reduction in the overall cost of operating the Australian chemicals assessment scheme. This should be passed on to Australian manufacturers through reduced costs of registration of new chemicals.
The detailed submission provided by the Plastics and Chemicals Industries Association (PACIA)
[Due to confidentiality, the next section is not provided.]
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A full list of all 2012 submissions can be viewed at June 2012 submissions to the review of NICNAS