Summary Report LTD/1225

Urea, N,N'-bis[3-(dimethylamino)propyl]-, polymer with 1,1'-oxybis[2-chloroethane]

Rhodia Australia Pty Ltd (ABN 24 050 029 000) of 352 Ferntree Gully Road, Notting Hill, VIC, 3168 has submitted a limited notification statement in support of their application for an assessment certificate for Urea, N,N'-bis[3-(dimethylamino)propyl]-, polymer with 1,1'-oxybis[2-chloroethane]. The notified polymer is intended to be used as a component of a coating for metal electroplating. Coating formulation and coating application will occur in Australia. Up to 90 tonnes of the notified polymer will be imported per annum for each of the first five years.

ASSESSMENT OF PUBLIC, OCCUPATIONAL HEALTH AND SAFETY AND ENVIRONMENTAL EFFECTS

Hazard Assessment

Based on the available data, the notified polymer is not classified for acute toxicity as a hazardous substance in accordance with the NOHSC Approved Criteria for Classifying Hazardous Substances. Classification of other endpoints in accordance with the NOHSC Approved Criteria for Classifying Hazardous Substances was not possible from the data provided.

Occupational Health and Safety

There is Low Concern to occupational health and safety under the conditions of the occupational settings described.

Public Health

There is Negligible Concern to public health when used in the proposed manner.

Environmental Effects

The notified polymer is highly toxic to fish, however, the chemical is not considered to pose a risk to the environment based on its reported use pattern.

RECOMMENDATIONS

Control Measures

Occupational Health and Safety

• Employers should implement the following safe work practices to minimise occupational exposure during handling of the notified polymer as introduced:
  
  - Avoid skin and eye contact
   

• Employers should ensure that the following personal protective equipment is used by workers to minimise occupational exposure to the notified polymer as introduced and/or in the final coating product:
  - Coveralls (as introduced/final coating product)
  - Impervious gloves (as introduced/final coating product)
  - Eye protection (as introduced)

Guidance in selection of personal protective equipment can be obtained from Australian, Australian/New Zealand or other approved standards.

• A copy of the MSDS should be easily accessible to employees.
   

• If products and mixtures containing the notified polymer are classified as hazardous to health in accordance with the NOHSC Approved Criteria for Classifying Hazardous Substances, workplace practices and control procedures consistent with provisions of State and Territory hazardous substances legislation must be in operation.

Environment

• The following control measures should be implemented by end users to minimise environmental exposure during use of the notified chemical:
  - Do not allow material or contaminated packaging resulting from spills to enter drains, sewers or water courses.
  - Use in controlled environment with no drains in the immediate area.
  - Spent dipping baths must not be released to the sewer.\

Disposal

• The notified chemical should be disposed of by incineration or to landfill in accordance with State/Territory waste disposal regulations.

Emergency procedures

• Spills or accidental release of the notified chemical should be handled by containment to prevent run-off sorbed onto an absorbent material (soil, sand or other inert material). Collect and seal in properly labelled containers for disposal. Do not allow material to contaminate ground, groundwater or waterways. Prevent product from entering drains or stormwater system.

Secondary Notification

The Director of Chemicals Notification and Assessment must be notified in writing within 28 days by the notifier, other importer or manufacturer:

Under Section 64(1) of the Act; if
- the use pattern of the notified polymer changes in such a way as to result in release of the polymer to the aquatic compartment.
or

Under Section 64(2) of the Act:
- if any of the circumstances listed in the subsection arise.

The Director will then decide whether secondary notification is required. Given the high toxicity of the notified chemical to fish, if there will be release of the notified polymer to the aquatic environment from a change in use pattern, then daphnia and algae tests with measured concentrations and a chronic daphnia study will be required to be submitted.

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