Exempted and Reported record keeping amendments

[Mike Dewhirst]

1. An eligible INCI name has been added to the mix of permissable names if CAS and IUPAC names are not known. No change to the software is required beyond updating the help-text.

2. If none of the above is known to the introducer then we need a name in Chemical Identity Holder (CIH) field who has (>10kg) provided or is expected to (<=10kg) provide identifying information to the Executive Director.

3. If the annual volume is <= 10kg we also need a note indicating the basis of the expectation that the person named will give the identifying information to the Executive Director if requested.

The records being kept are actually in the Chemintro Data report.

Thus, in the absence of a CAS number, the only two changes to the software will be to:

Produce a Chemical identity holder: Basis of expectation note for Reported or Exempt where the Chemical identity holder field is not blank and the annual volume is <= 10kg. The user can defeat the note if desired by adding "Not applicable" to the note title.

and

Under all circumstances it will be an error if all three of CAS, IUPAC and INCI names are blank and the Chemical identity holder field is also blank.

If there is a CAS number and the three fields are blank it will be anomalous but not an error. CAS number appears to satisfy AICIS requirements.