For public consultation: proposal to add condition of use on the AICS

On 1 March 2016, the National Industrial Chemicals Notification and Assessment Scheme (NICANAS) published a proposal that the importation or manufacture of Thioimidodicarbonic acid ((HO)C(O)NHC(S)(OH)), C,C’-dibutyl ester, which is listed on the Australian Inventory of Chemical Substances (AICS), be subject to a condition of use. The condition of use states that this chemical will only be used in an industrial workplace under highly controlled conditions.


CAS name CAS No. Molecular Formula Conditions of Use
Thioimidodicarbonic acid ((HO)C(O)NHC(S)(OH)), C,C’-dibutyl ester 39142-36-4 C10H19NO3S The chemical must only be used in an industrial workplace under highly controlled conditions


The reason for this proposal is that this chemical is considered to pose a significant risk to human health and the environment if it were made available for use by the general public. By placing the proposed condition of use on this chemical, any use of the chemical, other than for use in an industrial workplace, would require the chemical to be notified and assessed by NICNAS as a new chemical before introduction. Interested parties are invited to submit a statement describing the reasons why the proposed condition of use should not be included in the AICS for this chemical. The public consultation period closes on29 March 2016. This chemical is subject tosecondary notification conditions.


Thioimidodicarbonic acid ((HO)C(O)NHC(S)(OH)), C,C’-dibutyl ester, Chemical Abstracts Service (CAS) Number 39142-36-4, was assessed by NICNAS as a new chemical in 2007 for use under highly controlled conditions as a froth generating agent in the mineral processing industry. The chemical was listed on the AICS in 2012. The assessment report recommended the chemical be classified under the Approved Criteria for Classifying Hazardous Substances (2004). These classifications were equivalent to the following classifications under the Globally Harmonised System for the Classification and Labelling of Chemicals (GHS, 2003): a significant hazard to human health (Specific Target Organ Toxicant – Repeated Exposure (Category 1) – Causes damage to organs through prolonged or repeated exposure; Acute Toxicity (Category 4) – Harmful if swallowed; Germ cell mutagenicity – Suspected of causing genetic defects) a significant hazard to the environment (Aquatic Toxicity (Category 1)- Very toxic to aquatic life with long lasting effects).

The assessment report included a recommendation to the Director that, when the chemical is added to the AICS, its entry be annotated with the following condition of use: “The notified chemical should only be used for industrial purposes under highly controlled conditions”. This recommendation was not implemented at the time. Since the wording “industrial purposes” is potentially confusing given this chemical is an “industrial chemical” under the ICNA Act, the term “in an industrial workplace” is proposed.

NICNAS Chemical Gazette, 1 March 2016 ; ;