New category Reported 10kg

[Mike Dewhirst]

AICIS published new rules in late November for a Reported category for chemicals with an annual volume of 10kg or less.

The main effect is relaxation of the rigour surrounding provision of information; low volume being recognised as reducing absolute risk.

The chemical does need to be categorised as Reported 10kg.

Some extra characteristics are declared such as not containing Fluorine or being an inorganic salt and not being on the banned or restricted EU or USA lists of cosmetic ingredient lists.

These will give rise to specific tickets here.

This ticket will remain open as a summary of the changes until all work is done. Further study will result in edits hereto.

[Mike Dewhirst]

REPORTED10KG

Subsection 27(6) (new subsection relaxes rigour by using the word "known")

The word "known" implies that the person introducing the chemical would say so if the characteristic of interest to AICIS was known to exist.

For 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.

Program flow

The new rules start with the Reported category.

At that point, if the total volume is <= 10kg, auto-categorisation as REPORTED10KG should commence.

We need to examine precisely where to interrupt categorisation processing to call each of the methods mentioned below. Currently, the process simultaneously assigns hazards based on reference lists and/or chemical characteristics and writes the particular notes titled "Health (or Environment) info required for AICIS ..." for that portion of the categorisation. We may need to start that process with the total volume and keep parallel categorisation streams updated until one knocks out the other.

User initiation by selecting REPORTED10KG would be incompatible with current program flow which must calculate the category.

There are category user-selections of Commercial evaluation and Exceptional circumstances which are respected, but they bypass the categorisation software.

For REPORTED10KG category, the software must ensure:

Not (known) mutagenic or

Not (known) carcinogenic or

Not (known) reprotoxic or

For these three we need a new method which simply returns True if any of GHS hazards H340 or H341 or H350 or H351 or H360 or H361 are attached to the chemical.

If used in a cosmetic, must not be prohibited or restricted in cosmetics by EU or USA

For this we need a new is_banned_for_cosmetics() method which scans the index for a chemical (CAS and/or name and/or EC number) and if detected returns True if prohibited or restricted. There are chemicals on the EUR-Lex Cosmetics lists which are allowed with conditions. Some of those conditions may concern AICIS when/if the chemical is listed on the Australian inventory, the listing may carry similar conditions. There are similar lists for the USA. See Ticket #34

and

Not (known to be) a solid or a dispersion or

Physical state of 'Unknown' is already treated by the software as equivalent with 'Solid' and/or 'Dispersion' for nanoscale processing. See Ticket #30.

Not (known) to be nanoscale

Nano-material already has a selection 'Not known' which AICIS (and the software) treats as 'Yes' but without a study report on nano particle dimensions. See Ticket 28#comment:3 which implements this.

and

Not (known) to contain Fluorine or

We do need a has_fluorine() method which returns True if the molecular formula has a symbol 'F' or there is 'fluo" in the names. Returning False means it is not known to contain Fluorine. See Ticket #32.

IS known to be an inorganic salt

We already have element detection methods and organic/inorganic detection. See Ticket #33

and

Not (known) Persistent, Bioaccumulative and ToxicT

Already detected via CAS number search of the list of chemicals with high hazards for categorisation or the user has entered data including adding GHS H400 or H410 hazards.

Section 42A (relaxes rigour by using the word "reasonably")

Identification is identical with all other introductions. The difference is relaxed rigour in providing it - or not, if "reasonably practicable" to find out only when asked.

We will not need the MOU. Introducer can merely keep contact details of the person reasonably believed to know the information to provide to the Executive Director on request.

Section 46 - record keeping

We only need a useful link pointing to the AICIS record keeping checklist for REPORTED10KG.

Section 56A - specific records to retain

A relaxed rigour around the actual name of the chemical. Just retain the "known" names.

However, there is no relaxed rigour around knowing the product names and chemical volumes introduced.

We will need to review the Introduction Report to adjust output based on REPORTED10KG.

[Mike Dewhirst]

All sub-tickets of this ticket are now closed and so this ticket is now complete.