By Weisin Chai
Followed by the first Supplementary Existing Substance Nomination (SECN) in 2012, to achieve the completeness of the future National Chemical Substance Inventory (NCSI) and considering the rights and interests of the industries, the Taiwan Occupational Safety and Health Administration (OSHA), Ministry of Labor (MOL) will be launching the Second Supplementary Existing Substance Nomination (SSECN) from June 1, 2014 to July 31, 2014.
The SSECN is applied to substances which were manufactured, imported, handled, used or sold in Taiwan between January 1, 1993 and December 31, 2011. Since the purpose of SSECN is the inclusion of substance information in NCSI, any substances which have been published on the draft NCSI are exempted from the SSECN. The draft NCSI is available through the Chemical Substance Nomination and Notification (CSNN) website. Other exempted substances include the following:
- A substance or a polymer which is naturally occurring without further physical and chemical processing
- A polymer that is applicable to the 2% Rule
- Chemical substances accompanied in the machines and equipment for test-run purposes
- Inseparable intermediates from the chemical reaction in the reaction vessel or production process
- Mixtures (Reminder: the chemical substances in the mixture need to be nominated)
- Manufactured articles
- Chemical substances under customs supervision
- Chemical substances for national defense purposes
- Incidental reaction products or impurities without intended commercial purpose
Industries are encouraged to take the opportunity to participate in the nomination not only to complete the NCSI, but also to avoid having to do the New Chemical Substance Notification (NCN) later. NCN will most likely begin in 2015. According to Article 13 of the Occupational Safety and Health Act, manufacturers or importers of chemical substances not included on the NCSI are obligated for NCN. NCN requires the submission of a safety assessment report. For high risk substances, the risk management measures are needed as well.
On May 6, 2014, the OSHA released guidance and documentation of frequently asked questions of SSECN on the CSNN website. In general, the direction of SSECN is very close to the first SECN.
These are some summarized steps for participation of SSECN:
- Determine if the chemical substances are within the scope of SSECN
- Determine if the chemical substances are exempted substances
- Determine if the chemical substances are listed on the NCSI
- Download the SSECN tools
- Determine if data protection is needed
- Collect and confirm the completeness of the nomination dossier, application forms and supporting documents
- Submit electronically the nomination dossier, application forms and supporting documents to the Taiwan National Chemical Substance Registry (NCSR)
- Print, sign/stamp and mail a hardcopy of the nomination dossier, application forms and supporting documents to NCSR
- If required by the NCSR, industries are given one opportunity to amend or supplement any missing information in the nomination. The corrections shall be completed within 30 days from the date of notice.
The nominator must prepare the following nomination information:
- The company information such as name, address, telephone and fax numbers
- Chemical information such as CAS numbers, English/Chinese chemical names or other chemical synonyms
- Average annual tonnage of substances
To learn more about the requirements and the nomination tool in SSECN, readers may refer to the CSNN website.
Latest news of the Second Supplementary Existing Substance Nomination (SSECN)
Second Supplementary Existing Substance Nomination (SSECN) Guidance and Frequently Asked Questions
Draft National Chemical Substance Inventory (NCSI)
Taiwan Occupational Safety and Health Act