Submission tips for new chemical notifications
Last update 19 June 2017
Once you have familiarised yourself with how to notify a new chemical to NICNAS, these tips will help you prepare your assessment application and avoid unnecessary delays.
If you are unsure you have sufficient information to support your application, contact NICNAS before submitting it.
NICNAS cannot begin an assessment without a chemical identity—this is critical.
Identifying chemicals can be challenging, particularly for polymers. To ensure NICNAS can verify chemical identity, provide:
- the Chemical Abstracts Service (CAS) name and number, or
- a copy of the CAS report from the CAS Inventory Expert Service if only a CAS name is available (that is, CAS has not yet assigned a CAS number), or
- the IUPAC (International Union for Pure and Applied Chemistry) name if the CAS name is not available, or
- where the notified chemical is not a 'pure chemical', as complete a description of the chemical as is practicable.
The assessment will not begin until all required fees have been paid.
See fees and charges for details and information.
If you are paying from a foreign bank you are responsible for covering all bank charges and fees required for getting the exact $AUD to NICNAS.
Based on use scenarios and import volume, describe the occupational health and safety, public health and environmental effects in as much detail as possible for each notification category, including all potential exposure and release scenarios from 'cradle to grave'.
Before you submit your notification, also check you have:
- described the personal protective equipment used and controls in place for each stage of occupational use
- clarified the chemical concentration during each stage of use
- demonstrated you have considered all categories of workers and end users
- ensured the sum of all the environmental releases equals the volume introduced (quantity in = quantity out).
No matter which assessment category you apply for, the information you provide should cover all potential uses of the chemical. Therefore, the introduction volume—as well as occupational, public and environmental exposure—should cover all foreseeable uses of the chemical. This will avoid you having to apply for a secondary notification for a new use, introduction volume or exposure scenario.
Ensure you determine the correct assessment category. Notification under the wrong category is a common cause for delay in processing applications. Two problematic categories are the commercial evaluation chemical (CEC) and the self assessment PLC category (SAPLC).
As the notifier, you need to reasonably justify why the chemical is needed for evaluating its commercial viability. The Act (see Legislation and regulations) states that you need to provide:
"… a written explanation why the quantity of the chemical that the applicant seeks to introduce under is the permit is reasonably needed for effective commercial evaluation of the chemical."
It is not enough to state on your application that the chemical is needed to increase production volumes. An example of a valid justification for a commercial valuation chemical permit could be a new ingredient in ink for industrial printing processes.
You need to provide a signed agreement -commercial evaluation permit form (from end user to NICNAS) indicating the end users will abide by any relevant permit conditions. Additional users can submit the same form after the permit is issued.
Note: A CEC permit is never issued for a chemical in a consumer product—this would require every end-user to sign a CEC agreement before using the product, which is not possible.
You must ensure a polymer meets the PLC criteria and have on hand test reports for data such as molecular weight (MW), physico-chemical properties and available toxicity studies. You do not need to provide test reports with your self-assessment application.
For the self-assessment PLC (SAPCL) category, you must hold all relevant data.
If a third party holds the data you will not be able to use the self-assessment option, and will need to submit under the PLC category instead.
If you are unsure what should be included in the risk assessment sections of the Application for Assessment Certificate Polymer of Low Concern (PLC) self assessment (Form 1), review examples of our PLC assessment reports.
You can talk to a NICNAS New Chemicals Assessor by phone (+61 2 8577 8800) or contact us to discuss issues before you submit your application.