Polymer exemption notification in Korea before enactment of K-REACH

1.) Two laws to comply with when it comes to polymer exemption notification before January 1, 2015 (enactment of K-REACH)

Regulation Name	Responsible Gov’t Body
Toxic Chemical Control Act (TCCA)	Ministry of Environment (MoE)
Occupational Safety and Health Act	Ministry of Employment and Labor (MOEL)

2) Polymer exemption criteria under each law: If a polymer satisfies conditions from both laws, then in compliance with TCCA, submission of polymer exemption notification only to Korea Chemicals Management Association (KCMA) is required since submission to KCMA equally exempts the polymer from the requirements under OHSA.

TCCA	Every monomer of the polymer is Korean existing chemical and number-average molecular weight(Mn) of the polymer is higher than 1000; and
	Monomer is not Toxic Substance
OSHA	Every monomer of the polymer is Korean existing chemical and number-average molecular weight(Mn) of the polymer is higher than 1000; and
	Polymer does not produce cation; it is not carcinogenic, mutagenic, reprotoxic or other characteristics harmful to the human health; it is not one of the Administration subject listed; and it satisfies one of the below: 1. Does not dissolve in water or in organic solvent, and does not contain Sodium, Magnesium, Calcium or other metals. 2. If dissolved in water or in organic solvent, then a component with less than 1,000 molecular weight should be more than one percent. And if Mn is less than 1,000, then the polymer should not contain carbon to carbon double bond, carbon to carbon triple bond, carbon to nitrogen double bond, carbon to nitrogen triple bond, aziridine group, epoxy group, sulfonate group, hydrazine group, phenol hydroxyl group or fluorine group

If a polymer does not satisfy both the TCCA and OSHA criteria for exemption, then following TCCA exemption criteria (as mentioned in my post three days ago) has to be considered.

- A polymer that is not enlisted in Korea Existing Chemical List (aka a new chemical) is considered to be an existing chemical thus liable for exemption if its monomers (whether these monomers are new or existing chemical), excluding those with content ratio lower than 2%, result to a existing chemical.

- Block polymers whose blocks are not new chemicals;

- Graft polymers whose stem and branch sections are not new chemicals;

- Non-ionic polymers whose number average molecular weight is greater than 10,000

However, OSHA only states two criteria for polymer exemption, as mentioned above, a polymer that does not satisfy these two criteria is considered as a new chemical under OSHA and has to be registered to Ministry of Employment and Labor.

Therefore, a careful analysis and identification of exemptions are necessary in the polymer exemption notification.