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Updates: On December 21, 2022, by Notification of MOI B.E. 2565 (2022), the updated List of Hazardous Substances was officially released, which took effect on December 22, 2022.
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Thailand’s Department of Industry and Works (DIW) recently issued a circular to announce the adoption of draft amendments to the List of Hazardous Substances (hereinafter referred to as the List) under the Hazardous Substances Act B.E. 2535 (1992). Compare with the draft amendments notified WTO for comments in early 2022 (CL news), which were mainly proposed to facilitate the proper control measures for certain concerned substances in line with the Stockholm Convention on Persistent Organic Pollutants, there are no significant changes in the official version. ChemLinked summarized the major updates of the List. Details see below.
Updates in Annex 5.1 of the List (Regulated by the DIW)
Adding 8 perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds as hazardous substances. They are classified as Type 3 or Type 4 due to specific conditions.
Entry | Chemical name | CAS No. | Hazard type | Specific conditions for Entry No. 526 ~ 533 |
No. 526 | Perfluorooctanoic acid (PFOA) | 335-67-1 | Type 3 | These 8 substances are classified as Type 3 hazardous substances only if their uses falling under any of the following exemptions stipulated under the Stockholm Convention, i.e., 1) Photolithography or etch processes in semiconductor manufacturing; 2) Photographic coatings applied to films; 3) Fire-fighting foam for liquid fuel vapor suppression and liquid fuel fires (Class B fires) in installed systems, including both mobile and fixed systems; 4) Fire-fighting foam for liquid fuel vapor suppression and liquid fuel fires (Class B fires) in installed systems, including both mobile and fixed systems; 5) Manufacture of polytetrafluoroethylene (PTFE) and polyvinylidene fluoride (PVDF) for the production of: a. Industrial waste heat exchanger equipment; or b. Industrial sealants capable of preventing leakage of volatile organic compounds and PM2.5 particulates ; 6) Production of high-voltage electrical wire and cables for power transmission; and 7) Manufacture of fluoroelastomers for the production of O-rings, v-belts and plastic accessories for car interiors. |
No. 527 | Ammonium Perfluorooctanoate | 3825-26-1 | ||
No. 528 | Sodium Perfluorooctanoate | 335-95-5 | ||
No. 529 | Potassium Perfluorooctanoate | 2395-00-8 | ||
No. 530 | Silver Perfluorooctanoate | 335-93-3 | ||
No. 531 | Perfluorooctanoyl Fluoride | 335-66-0 | ||
No. 532 | Methyl Perfluorooctanoate | 376-27-2 | ||
No. 533 | Ethyl Perfluorooctanoate | 3108-24-5 | ||
Entry | Chemical name | CAS No. | Hazard type | Specific conditions for Entry No. 534 ~ 541 |
No. 534 | Perfluorooctanoic acid (PFOA) | 335-67-1 | Type 4 | For Entry No. 534 ~ 538, if their uses are outside the abovementioned scope of specific exemptions for Entry No. 526 ~ 530, they are classified as Type 4 hazardous substances, with exceptions of: 1) Being present as impurity with the concentration ≤ 0.0000025%; or 2) Being present in polytetrafluoroethylene (PTFE) micropowders produced by ionizing irradiation or by thermal degradation with the concentration ≤ 0.0001% w/w. |
No. 535 | Ammonium Perfluorooctanoate | 3825-26-1 | ||
No. 536 | Sodium Perfluorooctanoate | 335-95-5 | ||
No. 537 | Potassium Perfluorooctanoate | 2395-00-8 | ||
No. 538 | Silver Perfluorooctanoate | 335-93-3 | ||
No. 539 | Perfluorooctanoyl Fluoride | 335-66-0 | Type 4 | For Entry No. 539 ~ 541, if their uses are outside the abovementioned exemptions for Entry No. 531 ~ 533, they are classified as Type 4 hazardous substances, with the exception of being presented in impurity with the concentration ≤ 0.0001% w/w. |
No. 540 | Methyl Perfluorooctanoate | 376-27-2 | ||
No. 541 | Ethyl Perfluorooctanoate | 3108-24-5 |
Changing the hazard type of benzyl cyanide (CAS No. 140-29-4) from Type 1 to Type 3.
Entry No. 247 | Chemical name | Previous hazard type | Updated hazard type |
Benzyl cyanide | Type 1 | Type 3 |
Updating the condition (adding concentration limit) of triethanolamine (CAS No. 102-71-6).
Entry No. 202 | Chemical name | Updated condition |
Triethanolamine | Adding condition - “Only concentration > 30% w/w”, under which the chemical will be regulated. |
Updates in Annex 4.1, 4.2, 4.3 of the List (Regulated by the FDA)
Updating the more specific conditions* of 23 listed hazardous substances regulated by Thailand’s Food and Drug Administration (FDA).
* For 21 entries (Entry No. 18, 31, 39, 41, 47, 51, 52, 74, 75, 94, 109, 110, 111, 137, 138, 152, 168, 173, 189, 208, and 209) listed in Annex 4.1 and Entry No. 3 listed in Annex 4.2, adjusting their conditions to "In products used in household or public health activity with purposes for inhibiting, preventing, controlling, destroying rodents". For Entry No. 4 listed in Annex 4.3, adding condition as "Except bleaching products containing enzymes as active ingredients and not containing synthetic chemicals as active ingredients" |
Adjusting the name of Entry No.1 in Annex 4.3 to “Products used in household or public health activity with purpose for inhibiting, preventing, controlling, destroying rodents” and adding detailed exemption conditions**.
** "Except products being under one of the following conditions: Product containing essential oils from plant or animal as active ingredients. Product mainly containing plant parts which may be processed such as cutting, grinding, chopping, slicing. Product containing substances derived from plant or animal through the process of boiling, fermentation, extraction, combustion or any other processes without the addition of other substances intended to cause a chemical reaction as key ingredients. However, the products under 1, 2 and 3 must not contain any synthetic chemicals as active ingredients." |
Updates in Annex 3.1 of the List (Regulated by the DOLD)
Adding chlorpyrifos (CAS No. 2921-88-2) as Type 4 hazardous substance regulated by Thailand’s Department of Livestock Development (DOLD) with specific condition, i.e., "In active ingredients or products containing active ingredients intended for preventing, destroying, controlling insects or animal pests (except parasites living in animals)".
Obligations
For industrial enterprises, the following points shall be paid more attention to:
For substances that are prescribed as Type 3 hazardous substances, manufactures, importers, exporters or processors, who have been in relevant business before the effective date of the amendments, shall submit an application for a license within 30 days since the effective date. The application for registration must be submitted within the same period if any hazardous substance requires registration.
For substances that are prescribed as Type 4 hazardous substances, manufactures, importers, exporters or processors, who have been in relevant business before the effective date of the amendments, shall comply with the order of competent official within 180 days since the effective date.
