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Recently, Thailand Department of Industrial Works (DIW) released the long awaited national inventory of existing chemical substances through a webpage where the industry can search their substances. Although the webpage isn’t functional yet due to technical problems, the inventory still drew a lot of attention from the industry. ChemLinked received many questions from our viewers and we would like to answer some frequently asked questions for the convenience of our subscribers.
Q: How can we notify our substances into the inventory of existing substances?
A: At present there are mainly 3 ways to nominate a substance:
Nominate through the nomination system of Annex 5.6 to the Hazardous Substances Control Act (HSCA). This notification is mandatory if the substance meets the hazard criteria of Annex 5.6. The online notification link is: http://haz3.diw.go.th/hazvk/
Registration and license system under HSCA. This is for substances that meet the hazard criteria in the List of Hazardous Substances of HSCA.
Consultation through DIW. Some enterprises consult DIW about their substances for CBI or other issues. When they do so, DIW keeps the record in their own database. This database is merged into the inventory of existing substances.
Q: What about the substances with no hazard properties under Annex 5.6 criteria? Are there ways to notify them?
A: Even if your substances don’t meet the hazard criteria of Annex 5.6, you can still notify them through the Annex 5.6 online notification system. And DIW recommends the industry to do so.
Q: Do we have to disclose 100% chemical composition to DIW for the notification?
A: DIW doesn’t require 100% composition for the notification of Annex 5.6. You only need to submit the information on the SDS of the substance. However, DIW accept 100% composition if the enterprise is willing.
Q: Do we have to conduct the risk assessment for hazardous substances?
A: ChemLinked reported before that the proposed Thailand’s REACH-like regulation system would adopt risk assessment requirements like EU REACH. However, DIW hasn’t compiled a Substances of Very High Concern (SVHC) list yet. So currently there’s no need for risk assessment of hazardous substances. When the inventory of existing substances is finalized and the REACH-like regulation is implemented, we believe that enterprises will need to conduct risk assessment of SVHCs.
ChemLinked will follow further regulatory updates in Thailand’s chemical management system. This FAQ column will be appended upon receiving additional questions that we think are of interest to our viewers.
