For chemicals already in use in another country with review process similar to the Philippines, an abbreviated form may be used to submit data. Industry welcomes the abbreviated scheme for notification of chemicals that have been accepted in other countries. Furthermore, we request that the authorities make no distinction between substances listed on other inventories and those that have been notified. Polymers are high molecular weight compounds that do not cross biological membranes and are generally considered to be safe. For this reason, under U.S. law the review period on notifications of new polymers is 21 days rather than 90 days.
Industry recommends a simpler data set in line with practices in other country.
Section 15 of RA 6969 already requires the submission of a greater amount of data than is required in may other countries. More data are required if the chemical has not been reviewed in another country or if the manufacturer or importer cannot adequately document the safety of the new chemical used elsewhere. If additional data are required, RA6969 will effectively prevent the introduction of new and safer technology in the Philippines. Experience has shown that some submissions have been under review for nearly 4 years. This change would be consistent with the review mechanism in the U.S. Industry also requests that DENR impose a review period of 20 days for abbreviated notifications and 21 days for polymers.