The Nanotechnology Industries Association (NIA) has provided comments to Proposal for Regulatory Reform of Industrial Nanomaterials’, published as part of a public consultation by the Australian Government, Department of Health & Ageing – National Industrial Chemicals Notification Scheme (NICNAS) in November 2009.

On the topic of ‘Definition of ‘Nanomaterials’’, the NIA noted that ‘clarification is required on the terms ‘intentionally produced, manufactured or engineered’ and ‘specific properties or specific composition’.Moreover, the definition should be practical and implementable in the regulatory context, within which it is being proposed, and it should be flexible to change, in order to specifically accommodate the developments of definitions in the aforementioned international fora.’

Regarding the proposed ‘NICNAS notification categories (Permits and certificates)’, the NIA alerted the authorities that ‘the specific necessary characteristics used to uniquely describe nanomaterials, differ significantly between materials and with application, and over-generalised mandatory requirements for the measurement and notification of unnecessary physical-chemical endpoints can cause enormous economic burden [on the notifier]. In turn, the proposed administrative exclusion from self-assessment (on the basis of the uncertainty concerning their hazard) and subsequent plans for the hazard status of the nanomaterials and the risk posed by the notified uses to be assessed by NICNAS may pose an enormous workload on the authorities.’

Comments were submitted within the format required by NICNAS, but a full reproduction of all comment can be downloaded here (NIA PDF document).