Exempt Your Polymers from Notification (A Strategy)

Why submit notification to a toxic chemical inventory if it’s not required? In many cases, low-concern polymers are exempt from notification, but details in the regulations vary from country-to-country. It’s worthwhile to know the different criteria so your company can decide whether it wants to take the exemption or not, said Jeffrey Hafer, senior scientist at Critical Path Services.

For instance, in the EU, all polymers are exempt, but in the Philippines, polymers are exempt if less than 2 percent of the reactants are listed on the inventory. China, Japan and South Korea explicitly exempt graft and block polymers from being listed if the individual graft or block components are listed. In the United States, polymer exemption is ‘self-actuated.’ “As long as you’re low-concern, the world is very happy place to be,” said Hafer.

Given the particular differences, Hafer suggested a multi-step “Notification Strategy” regarding polymers:

• Establish nomenclature and conduct a thorough inventory search.
• Explore alternatives. Hafer suggested training research-and-development teams on the polymer-of-low-concern (PLC) criteria, so they know which chemistries won’t trigger a new polymer notification.
• Archive and periodically update PLC documentation for every polymer and product.
• If the polymer isn’t a PLC, develop a “roadmap” for global notification. First determine the data requirements and timing. In the U.S. specifically, if inhalation exposure is possible then you’ll need to generate data on particle size/aerosol size and/or exposure data.
• Gather as much exposure and release information as possible for manufacture and use.

For more information, Hafer referred attendees to EPA’s “TSCA Polymer Inventory Representation Guidance,” “CAS Inventory Expert Service,” “TSCA Polymer Exemption Guidance Manual” and “USEPA Environmental Polymer Assessment.”