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On 7 April, Taiwan MoL issued a draft list of 580 chemical substances, which are designated as priority management chemical substances under OSHA. All stakeholders are invited to comment during the public consultation period before 24 April, 2015.
This is the first batch of priority management chemical substances, designated according to Regulation of Priority Chemical Substances Designation and Handling Management (hereafter referred to as the Regulation). The Regulation is promulgated based on Article 14 of Taiwan OSHA, which requires the manufacturers, importers, suppliers, or employers to report relevant handling information of priority management chemicals to the MoL.
The draft list includes 123 chemical substances of CMR, Category 1. The other 457 chemical substances all possess physical hazards or health hazards. The final list is expected to be effective upon public announcement on 31 May, 2015.
Please note that the priority management chemical substances designated by the MoL under Taiwan OSHA are different from the priority chemical substances to be screened out by the EPA for existing chemical phase II registration under the Taiwan TCSCA. The former will be managed on a permission basis, while the latter will require chemical registration. Generally speaking, chemical registration is required to obtain sufficient data for further evaluation and assessment, after which the substance can be categorized into the existing inventories/lists managed by different authorities and controlled under the corresponding handling permission/licensing system. Based on this understanding, the priority management chemical substances under OSHA may be excluded from the existing chemical phase II registration under TCSCA. The priority chemical substances list subject to existing chemical phase II registration under the Taiwan TCSCA is expected to be published by the end of 2017. As we know, the MoL prioritizes assessment of physical and health hazards, while the EPA is mainly focused on the environmental hazards associated with chemicals. Priority management chemical substances designated by the MoL as having insufficient data to define environmental hazard evaluation and risk may still require registration under TCSCA.
The definition of “priority chemical substances” as used by the TCSCA does not correspond to the same definition under Chinese regulations.
Below is the comparison between the two kinds of substances.
English Name | Chinese Name | Legal Basis | Regulation for Implementation | Competent Authority | Designation criteria | Compliance Obligations |
Priority management chemical substances (Direct translation of the Chinese name) | 优先管理化学品 | Article 14 of Taiwan OSHA | Regulation of Priority Chemical Substances Designation and Handling Management | Taiwan MoL | 1. Hazardous chemicals that are listed in Article 29 Paragraph 1 subparagraph 3 and Article 30 Paragraph 1 subparagraph5 of Taiwn OSHA (i.e. Attachment 1 of the Regulation) 2. According to the CNS 15030 classification, chemicals that are Class 1 carcinogens, Class 1 germ cell mutagenicity or Class 1 toxic for reproduction-----123 substances of the draft list belong to this kind 3. According to the CNS 15030 classification, chemicals with physical hazard or health hazard that meet the maximum operation amount (threshold) stipulated in Attachment 2 of the Regulation----457 substances of the draft list belong to this kind | Handling information should be reported to the MOL annually, including: —Basic information of the handler (Attachment 3 of the Regulation) —Handling information of priority management chemicals (Attachment 4 of the Regulation) —Others if necessary |
Priority chemical substances (Pithy paraphrase of the Chinese name) | 应完成《新化学物质及既有化学物质资料登录办法》附表六既有化学物质标准登录的既有化学物质 | Article 7-1 of Taiwan TCSCA | Regulation of New and Existing Chemical Substances Registration | Taiwan EPA | Based on the information collected from the existing chemical phase I registration (required for all existing chemical substances above 0.1 t/y) under the Taiwan TCSCA, if the substance volume is large and designated of highly hazard or lacking specific data for further evaluation, it will be probably designated as a priority chemical substance subject to the Phase 2 registration. | Existing chemical phase II registration should be complied with (See Existing chemcial registration specified in TCSCA Chempedia) |
