Priority Existing Chemical



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q)Recommendations


This section provides the recommendations arising from the priority existing chemical assessment of MMT. Recommendations are directed principally at regulatory bodies and importers and formulators of MMT and MMT products. Implicit in these recommendations is that best practice is implemented to minimise occupational and public exposure and environmental impact.

q.1Recommendations for regulatory bodies

q.1.1NOHSC


MMT (as Mn) is currently listed in the NOHSC List of Designated Hazardous Substances (NOHSC, 1999b) with no classification.

In accordance with the NOHSC Approved Criteria for Classifying Hazardous Substances (NOHSC, 1999a), MMT is classified “Hazardous” with the following risk phrases:



  • R26 – Very Toxic by Inhalation;

  • R28 – Very Toxic if Swallowed;

  • R24 – Toxic in Contact with Skin;

  • R48/23 – Toxic: Danger of Serious Damage to Health by Prolonged Exposure Through Inhalation.

The following safety phrases are also recommended for MMT:

  • S36 – Wear Suitable Protective Clothing;

  • S38 – In Case of Insufficient Ventilation Wear Suitable Respiratory Equipment.

It is recommended that this classification for MMT be adopted by NOHSC as part of their process for updating the List of Designated Hazardous Substances (NOHSC 1999b).

q.1.2National Drugs and Poisons Schedule Committee


Given the acute toxicity profile of MMT and the potential for consumer exposure to products containing MMT, it is recommended that the NDPSC consider scheduling of MMT in the Standard for the Uniform Scheduling of Drugs and Poisons. A copy of the final report will be forwarded to the NDPSC for their consideration.

q.1.3Tasmanian Department of Primary Industries, Water and Environment


This report notes a pilot study of atmospheric particulates conducted prior to the use of MMT in automotive fuels that cites elevated atmospheric manganese levels in Launceston, Tasmania at certain periods compared to other cities. Given the potential for the combustion of MMT in automotive fuels to add to atmospheric manganese levels, a copy of this report will be forwarded to the Tasmanian Department of Primary Industries, Water and Environment for their consideration.

q.2Recommendations for MMT importers and formulators of MMT products

q.2.1Hazard communication – MSDS


This assessment found that MSDS for products containing MMT did not conform to the requirements of the NOHSC National Code of Practice for the Preparation of Material Safety Data Sheets (NOHSC 1994b). In order to ensure conformity with this code, it is recommended that importers of MMT review their MSDS for compliance and pay particular attention to the following points:

  • risk phrases and hazard information should be updated to reflect the hazard classification in Recommendation 17.1.1;

  • MSDS should carry correct hazard statements;

  • emergency telephone numbers should be included; and

  • the Australian exposure standard for MMT should be listed with an explanation for skin notation; and

  • only ingredients relevant to the product should be included.

A sample MSDS can be found in Appendix 3.

q.2.2Hazard communication – labels


This assessment found that labels for MMT products did not conform to the requirements of the National Code of Practice for the Labelling of Workplace Substances (NOHSC 1994a) or the Australian Dangerous Goods Code. In order to ensure conformity with these codes, it is recommended that importers of MMT review their labels for compliance and pay particular attention to the following points:

  • risk phrases and hazard information should be updated to reflect the hazard classification in Recommendation 17.1.1;

  • safety phrases should be included as noted in Recommendation 17.1.1;

  • contact details of the local supplier should be included;

  • hazard category or signal words should be included; and

  • labels should be attached to product containers.

q.2.3Packaging


It is recommended that all consumer products containing MMT be packaged in containers with childproof closures.

To prevent backflow and spillage of MMT by consumers when using aftermarket MMT products, it is also recommended that all consumer products designed to be added directly to fuel tanks should be enclosed in containers with spouts of sufficient length to ensure good insertion of the spout into the fuel filler.

If products containing multiple shots of additive are produced for consumer use, it is recommended also that where possible these should be packaged in containers with a measuring capacity or ideally with an automatic measuring and dispensing capacity. Appropriate consideration of the light sensitivity of MMT would also be required.

q.2.4Emergency procedures


Any spills of product containing MMT should not be allowed to enter stormwater, sewers or natural waters.

r)Secondary Notification


Under Section 64 of the Industrial Chemicals (Notification and Assessment) Act 1989, the secondary notification of a chemical that has been assessed under the Act may be required where an introducer (manufacturer or importer) of a chemical becomes aware of any circumstances that may warrant a reassessment of its hazards and risks. In the case of MMT, specific circumstances include:

  • use of MMT in bulk transport fuels other than LRP;

  • the manufacture of MMT has begun in Australia;

  • additional information has become available to the introducers as to adverse health and/or environmental effects of MMT;

The Director (Chemicals Notification and Assessment) must be notified within 28 days of the introducer becoming aware of any of the above or other circumstances prescribed under Section 64(2) of the Act.



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