Thursday, April 9, 2015

[Polymer] Comparison of Polymer Exemption Conditions between K-REACH and KOSHA

There are considerable differences in polymer exemption conditions between K-REACH and KOSHA. Therefore, if business entity intends to get confirmation of polymer exemption, they should consider exemption conditions of both K-REACH and KOSHA. If a new polymer satisfies exemption conditions under K-REACH but does not satisfy those under KOSHA, and vice versa, business entity should proceed registration or apply for confirmation of exemption from registration under K-REACH and KOSHA respectively. However, if a new polymer satisfies exemption conditions under both K-REACH and KOSHA, business entity has only to apply for confirmation of exemption from registration under K-REACH, which covers counterpart under KOSHA. Please refer to the following table for details.

K-REACH
KOSHA
Ø  Polymer compounds with Mn10,000 whose molecular content of MW<1,000 is less than 5% and that of MW<500 is less than 2%
Ø  Polymer compounds with 1,000Mn<10,000 whose molecular content of MW<1,000 is less than 25% and that of MW<500 is less than 10% (Exception: polymer compounds whose monomers, which are new chemicals, hazardous chemicals and chemicals with hazard and risk or announced by MoE, exceed 2%weight)
Ø  Exception: Cationic polymer compounds (excluding polymer compounds only used in solid form and not dissolved or dispersed in water)
Ø  Polymer compounds, whose Mn1,000, which  do not make cation, whose monomers are neither new chemicals, prohibited substances, substances subject to permission nor hazardous substances subject to control and which satisfy one of the following two conditions
-       If insoluble in water or organic solvent, polymer compounds should not contain any metal, except sodium, magnesium, potassium or calcium
-       If soluble in water or organic solvent, molecular content of MW<1,000 in polymer compounds should be less than 1%. If polymer compounds Mn<10,000, the monomers should not include double bond between carbons, triple bond between carbons, double bond between carbon and nitrogen, triple bond between carbon and nitrogen, aziridine group, epoxy group, sulfonic acid group, hydrazine group, phenolic hydroxyl group, or fluorine group

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