Submissions to the 2012 Review of the National Industrial Chemicals Notification and Assessment Scheme - Nalco Australia Pty Ltd

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: 19 September 2012

PDF printable version of Nalco Australia Pty Ltd submission (PDF 94 KB)

Nalco Australia Pty Ltd
Norman L.Taylor
Snr Regulatory Affairs Specialist
02 9392 3566
0413 186 424

2 Anderson St
Banksmeadow NSW 2019

Summary

The New Chemical Notification assessment process in Australia is quite restrictive and places many unnecessary burdens on Industry. The New fee structures for Certificate categories gives Australia one of the most expensive new Chemical Notification Schemes in the World. Unlike many other world schemes eg EU’s REACH where substances at the High Risk end are targeted, NICNAS has an unnecessary emphasis on low risk substances eg Self-assessment categories, PLCs. We had a past case of a PLC polymer that took 9 months to approve due to extended questioning from the Environmental assessment group. An EIP had been granted earlier in this case. NICNAS’s Notification scheme should focus on high risk substances.

Often new chemistries particularly are not introduced in Australia due to cost and time factors making them unattractive for commercialization. Such substances in many cases have been assessed in US or Canada. However, the MAN (Mutual Acceptance of Notifications) between Canada and Australia has only led to a discount in notification costs, NICNAS still does their own assessment. US EPA system not an approved foreign scheme. but their assessment process would be highly favoured for adoption eg PLC category.

NICNAS should be able to use overseas assessments to fast track their decision for safe introduction of a chemical into Australia. Do PLC’s really need to be assessed at all? There should be an exemption category for PLCs where the monomers are existing, and for salt variations of listed polymers.

Consideration of other schemes used in the region eg Japan for quantities up to 10tons/yr not biodegradable/not persistent should be considered.

It is a concern NICNAS is embarking on a review of existing substances when major players on the chemical use stage have established schemes already in place. EU’s REACH for new and existing chemicals sees ~150,000 substances registered and under review. USA’s Challenge Program in co-operation with Canada and Mexico targeted High Production Volume chemicals (>10 tons/yr) and has been in progress since 1998 . The US Program expects to have risk assessments completed this year. In Japan, there are approx. 7000–8000 substances already being monitored and a proposed 1000 new substances that will be PACs–Priority Assessment Chemical Substances. With the substance risk assessment data from these major Global Chemical users being generated, NICNAS’s efforts for Australian existing chemicals cannot be seen as a significant contribution to global knowledge. In addition, as already highlighted from the abovementioned schemes massive amounts of chemical toxicity testing have been completed or are still in progress. If Australia targets 3000 substances over the next four years then the toxicity testing costs for much of this will be passed onto Industry.

The detailed submission provided by the Plastics and Chemicals Industries Association (PACIA) is supported.

Examples where new chemistry, innovation and technologies are not being introduced in the Australian Market

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