Polymer Exemption and Additional CCO/ PCL Public Consultation

The Department of Environment and Natural Resources- Environmental Management Bureau (DENR) held a public consultation in relation to the draft policies on the Exemption of Polymers from Pre- Manufacture Pre Importation Notification (PMPIN) process and additional Chemical Control Order / Priority Chemical List for GHS SDS and Labelling Requirements on July 26, 2017.

In the draft policy on the exemption of polymers from PMPIN, the polymers and polymeric reactions must meet any of the three criteria to be exempted from the PMPIN process:

1.) All of the its monomers/reactants must be listed in the PICCS and not in the Revised Priority

Chemicals List (PCL) under DENR Administrative Order No. 2005-27;

2.)Total percent of new monomers and other reactants (including crosslinking, chain transfer

agents, and post polymerization reactants) should be less than 2 percent (by weight);

3.) The low concern polymer shall fall into one of the categories;

a. Polymers that have:

– Number Average Molecular Weight (NAMW) equal to or greater than 10,000,

-Less than 5% of oligomers with MW lower than 1000 and less than 2% of

  oligomers with MW lower than 500, and

-An FGEW for cationic polymers of greater than 5000.

b. Polymers that have:

-NAMW equal to or greater than 1000 and less than 10,000,

-Less than 25% of oligomers with MW lower than 1000 and less than 10% of

  oligomers with MW lower than 500, and

-No reactive functional groups in excess of the levels specified.

In the afternoon session, 228 chemicals were presented as part of the proposed updated

list of CCO and PCL chemical. According to the report, only 12 out of the 387 chemicals under the current listing of CCO were classified as carcinogen by the IARC while only 20 chemicals under the PCL chemicals.