Opened 5 weeks ago
Closed 5 weeks ago
#116 closed enhancement (wontfix)
AICIS changes on 6 Sep 2024
| Reported by: | Mike Dewhirst | Owned by: | |
|---|---|---|---|
| Priority: | low | Version: | 3.x |
| Keywords: | surface teatment nano changes | Cc: |
Description
https://www.industrialchemicals.gov.au/updates-and-corrections
6 September 2024
Record keeping for exempted introductions – chemicals resulting from non-functionalised surface treatment of listed chemicals
Removed the following two bullet points under 'Nanoscale - records to demonstrate one of the following':
it doesn’t meet the definition of ‘not soluble’. We’ll accept a study report (OECD test guideline 105 or 120) showing the solubility of the chemical in water is greater than or equal to 33.3 g/L; or the dissolution rate is greater than 70%.
the introduction of the nanoscale portion of the chemical is incidental to the non-nanoscale portion. We’ll accept a justification for this.
This has not been removed from the nano section of the page (https://www.industrialchemicals.gov.au/business/reporting-and-record-keeping-obligations/record-keeping-obligations-exempted-introductions/record-keeping-exempted-introductions-highest-indicative-risk-very-low) but rather, as indicated, from the non-functionalised surface treatment of listed chemicals section.
When building Chemintro it was judged that the software to manage "non-functionalised surface treatment of listed chemicals" - other than offering it as a selectable circumstance to qualify categorisation - should be built when user(s) requested it. That has not happened yet.
It is our opinion that this particular AICIS change to record keeping requirements has been made because nano particle hazards are unlikely to be a consideration in such surface treatment and the two bullet points have been removed as being redundant.
Accordingly we have noted the change but not adjusted the software.
