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Organization :
Ministry of Employment and Labor
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Regulation :
Occupational Safety and Health Act
Grievance
(Background)
As the Occupational Safety and Health Act was amended, starting from Jan. 16, 2020, companies shall submit material safety data sheet (MSDS) to the MOEL before importing or manufacturing any substance subject to MSDS preparation. Yet, if a person submitted or changed MSDS before the enforcement date of the amendment, the one is granted for a grace period, up to five years.
The pre-announced Enforcement Rule of the act described that imported mixture containing chemical substances has a certain condition to meet to be regarded as an exemption.
(Grievance)
It was suggested to use the import volume in deciding the grace period, in consideration of the supply chain structure of chemical substance or mixture. In addition, it was requested to expand the scope of applying the grace period to include raw material suppliers, as there is concern about confusions over new amendments.
Resoultion and Results
(Resolution)
The OFIO conveyed this grievance in written format to the MOEL and asked to consider the supply chain structure of chemical substance or mixture containing chemicals.
(Result)
Manufacturers for intermediate product will be considered to have fulfilled the system if they submit MSDS of their product as required in the previous version of the act, within the grace period.
