Tall Bennett Companies

Public submissions to the review of the National Industrial Chemicals Notification and Assessment Scheme.

Page last updated: 20 March 2012

PDF printable version of Tall Bennett Companies submission (PDF 45 KB)

Tall Bennett Companies

We are a small company (only employ 5 people) with a high focus on R+D. There is only a limited amount of our resources that we can afford to expend on issues such as this (sorry).

a) Example 1 - We had aimed to undertake NICNAS required testwork for one molecule of interest to at least one Australian mine. We gave up when the costs became prohibitive (from memory, they were heading towards $30k….that’s not including NICNAS fees….with main costs being for toxicity trials).

b) Example 2 – Attached is an ‘edited’ extract from one R+D program, in which a sample of another non-NICNAS molecule was trialled against the NICNAS approved product already in use. As you will see, from this single investigation, the economic benefit (if the mine site could change) was calculated as more than $40 million per year.

In both above cases, the product is intended to be used at a remote site (and therefore not come into contact with the public). The majority of the product, when used at the mine site, is ‘consumed’ by the valuable mineral concentrate - which is then shipped to overseas smelters. Some small quantity would end up in the tailings dam at each site.

Our conclusion, for these and other new molecules resulting from our R+D, is that we should focus our efforts on offshore mine sites which are not inhibited by Australian regulations (NICNAS).

Hope this is helpful….and sorry that we don’t have the resources available to make a more extensive submission.

Regards,
Lex Tall