Chemical assessed as a polymer of low concern (PLC): work out if you need to submit a specific information requirement (SIR) form

Understanding the SIR terms of listing for PLCs

Each SIR term of listing will include text indicating that a person manufacturing or importing (introducing) this chemical must tell us if the polymer is imported or manufactured by them in a form that does not meet the PLC criteria. They must tell us in writing within 28 calendar days.

Sometimes, as well as the mandatory requirement to meet the PLC criteria, there are additional obligations described in the SIR that you must check.

1. If the SIR only relates to the PLC criteria being met

For most chemicals that NICNAS assessed as a PLC, this is the only requirement. The chemical will have met the specific PLC criteria at the time that it was assessed under NICNAS, but a chemical may not always meet the PLC criteria. For example, the amount of low molecular weight species in the polymer may have changed due to differences in manufacturing processes. 

If the only requirement, is about the PLC criteria being met you don’t need to have access to the assessment report for the chemical. Instead, you must check if your chemical meets AICIS’s PLC criteria. You may need to contact the chemical supplier or manufacturer to help with this. Our interactive PLC SIR decision tool can also assist.

Outcome – PLC criteria met 
If the chemical is introduced in a form that meets PLC criteria, you do not need to submit information to us about the chemical introduction.

Obligations: You must keep a record about the basis of the decision to not submit information to us about the introduction. For example, this could be a record of correspondence with the chemical supplier confirming that the chemical meets the PLC criteria.

Outcome – PLC criteria not met (or you’re unsure) 
Submit information to us about the introduction if any PLC criteria are not met or if you are unsure. 

> Submit the SIR form ‘Chemical assessed as a PLC’ in AICIS Business Services. The form will also ask you to confirm that no other additional specific information requirements apply. Before you do, check out our guidance on completing this form.

2. If the SIR includes other requirements along with the PLC criteria being met 

For some chemicals that NICNAS assessed as a PLC, the SIR relates to more than just meeting the standard PLC criteria. For example, the SIR may include other circumstances when information must be provided to us, such as if there are certain changes to use or exposure scenarios. You will need to compare your own introduction circumstances with the circumstances described in the SIR.
These other requirements/circumstances may be included as part of the SIR term of listing. There may also be a link to the NICNAS public assessment report from the Inventory chemical record which you’ll be able to open and check. 

If the CAS number and/or chemical name is protected information, then the other requirements/circumstances won’t be disclosed in the Inventory chemical record. They can be found in the NICNAS public assessment report. However, there will not be a link to the NICNAS assessment report from the Inventory chemical record because of the protected information. You will need to search for the chemical assessment report You can try to locate the report using a trade name or report identifier if you have it.

If you found a NICNAS report for your chemical
- You must check whether the chemical meets the PLC criteria.
- Obligations ‘Under Section 64(1) of the Act’ transitioned to SIRs under AICIS. Check under the heading ‘secondary notification’ in the NICNAS assessment report. You need to give us the information if a change in any of these circumstances has occurred in relation to your introduction.
-  Disregard the requirements ‘Under Section 64(2) of the Act’. These didn’t transition to SIRs under AICIS.

Outcome – I need to tell you about a change in circumstances, or I’m unsure if I need to
You’ll need to tell us about how they apply/what your circumstances are. 

Next: Submit the SIR form ‘Chemical assessed as a PLC’ in AICIS Business Services. The form will also ask you to confirm whether or not the introduction meets PLC criteria. Before you do, check out our guidance on completing this form.

Outcome – I do not need to tell you about a change in circumstances
If your chemical is introduced in a form that meets PLC criteria and there is no change in any of the circumstances mentioned in the SIR, you do not need to submit information to us about your chemical introduction. 

Obligations: You must keep a record about the basis of the decision to not submit information to us about the introduction. For example, this could be a record of correspondence with the chemical supplier confirming that the chemical meets the PLC criteria and a record of no change in any circumstances mentioned in the SIR.