Changes between Version 7 and Version 8 of Ticket #29, comment 1


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Timestamp:
2022-12-07T21:50:10Z (2 years ago)
Author:
Mike Dewhirst

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  • Ticket #29, comment 1

    v7 v8  
    77For example, if the software did not independently detect mutagenicity, carcinogenicity or reprotoxicity then it can be accepted as not known by the introducer to be so. This is because the user can add such hazards and the software would thereby "know" such a characteristic exists.
    88
    9 The new Reported category of 10kg or less does not need to tick the boxes ticked for normal Reported category.
     9The new Reported category of 10kg or less does not need to tick the boxes ticked for normal categories.
    1010
    11 In particular, health and environment categorisation volumes are irrelevant - they are less than 10kg. Exposure and release factors are also irrelevant for such a small quantity.
     11In practice, health and environment categorisation volumes are irrelevant - they are less than 10kg. Exposure and release factors are also irrelevant for such a small quantity.
     12
     13The entire purpose of the new 10kg category is to relax information provision requirements which are so difficult for Australian introducers with taciturn overseas suppliers.
    1214
    1315
     
    1820If the risk is actually very-low, we might ignore REPORTED10KG and categorise as Exempted. The reasoning is that REPORTED10KG is then unnecessary and if used AICIS would need to be notified in future if volumes increased beyond 10kg.
    1921
    20 However, an introducer might opt for the REPORTED10KG simply to avoid having to obtain documentation potentially demanded by AICIS to prove the Exempted category.
     22However, an introducer might opt for the REPORTED10KG simply to avoid having to obtain documentation potentially demanded by AICIS to prove the Exempted category. The boxes which do need to be ticked won't keep the chemical out of the Assessed category if it is reviewed pre-introduction and AICIS detect or suspect a medium to high risk.
    2123
    22 We need a mechanism for the user to opt for REPORTED10KG.
     24We need a mechanism for the user to opt for REPORTED10KG. See Ticket #36
    2325
    24 In any case, if the chemical fails the set of rules for <= 10kg then it will be either Reported or Assessed.
     26In any case, if the chemical fails the set of rules for <= 10kg then it will be Exempted, Reported or Assessed.
    2527
    2628This puts the new hierarchy of categories as: