“The Catalog of Hazardous Chemicals 2015” has been Implemented
original article from CIRS
“The Catalog of Hazardous Chemicals 2015” (“Catalog 2015”) was published on 9 March 2015 and came into force on 1 May 2015. In the meantime, “The Catalog of Hazardous Chemicals 2002” and “The Catalog of Toxic Chemicals 2002” were both abolished.
“Catalog 2015” has reduced the total entry number from 3962 (3823 entries for hazardous chemicals and 335 entries for toxic chemicals) down to 2828. An in-depth interpretation by CIRS expert Ms. Grace Ma is made below on how enterprises comply and what influence will be made to the enterprises.
Registration of Hazardous Chemicals
“Measures of Registration of Hazardous Chemicals Management” came into force on 1 August 2012. According to the “Catalog 2015”, enterprises should, first, check if the products are included in the “Catalog 2015”. If the products are included in the “Catalog 2015”, a registration of hazardous chemicals shall be made.
If the products are not in the “Catalog 2015”, according to the SAWS Order 53 and relevant identification methods, the following works shall be done:
- Enterprises have the relevant data of the products: the physicochemical, toxicological or eco-toxicological data shows that the products belong to hazardous chemicals. A registration of hazardous chemicals shall be made by the enterprises.
- Enterprises do not have the relevant data of the products: if the products are similar to hazardous chemicals, an identification of hazardous chemical shall be made by the enterprises. The identification includes physical hazards, hygienic hazards and environmental hazards.
- Please note that enterprises need to appoint a lab to do the identification of hazardous chemicals. For physical hazards identification, according to SAWS Order 60, enterprises can appoint a lab that is certified by SAWS to do the identification. For hygienic and environmental hazards identification, the labs certified by relevant authorities will also be required to carry out the identification.
Environmental Administration Registration of Hazardous Chemicals
According to MEP Order 22, enterprises that manufacture or use hazardous chemicals are required to do the Environmental Administration Registration of Hazardous Chemicals. If the hazardous chemicals are included in the List of Priority Hazardous Chemicals for Environmental Management (84 chemicals), enterprises are required to appoint a third-party agent to do the environmental risk assessment.
Enterprises that manufacture, use or import/export hazardous chemical have the obligations to do the Registration of Hazardous Chemicals (SAWS Order 53) and Environmental Administration Registration of Hazardous Chemicals (MEP Order 22) if the products fall into the related catalogs. The catalogs that are needed to be checked by enterprises are: The Catalog of Hazardous Chemicals 2015, List of Priority Hazardous Chemicals for Environmental Management, List of Toxic Chemicals Restricted from Import or Export and List of Physical-Hazards-Only Substances that Are Exempted from Environmental Administration Registration of Hazardous Chemicals.
License System for Hazardous Chemicals
Licenses for handling hazardous chemicals include: Operating License, Production License, Safe Use Permit and Transportation License, which are regulated under the Catalog of Hazardous Chemicals 2015. If the chemicals are listed on the catalog, the enterprises will be required to apply for the related licenses according to the certain activities.
It is noted that for transportation, if the chemicals are classified as hazardous chemical, it does not mean that the chemicals are dangerous goods. The requirement for application of Transportation License will be related to the List of Dangerous Goods. For import and export of hazardous chemicals, certain packing requirement shall be fulfilled as well as the requirement for SDS and GHS.
GHS and SDS
Chemical manufacturers or suppliers have the responsibilities and obligations to fulfill the GHS and SDS requirement, especially for hazardous chemicals. So far, the Guidance for the Catalog of Hazardous Chemicals has not been published yet, so the information of UN Number of Hazardous Chemicals and Chemical Classification are still unknown.
After the release of the Guidance, enterprises, when doing Registration of Hazardous Chemicals, Environmental Administration Registration of Hazardous Chemicals and Authoring SDS and Labels, can refer to the information provided by the Guidance to fulfill all the related requirements.
Highly Toxic Chemicals
Significant changes have been made for the highly toxic chemicals. The entry number has been reduced from 335 (the Catalog of Toxic Chemicals 2002 (abolished)) down to 148 (Catalog 2015), in which 140 chemicals were in the Catalog of Toxic Chemicals 2002 (abolished) and 8 chemicals were newly added. 160 chemicals in the Catalog of Toxic Chemicals 2002 (abolished) are no longer regarded as highly toxic chemicals and are regulated as hazardous chemicals under “Catalog 2015”. There are 35 chemicals from the Catalog of Toxic Chemicals 2002 (abolished) not included in the “Catalog 2015”.
Enterprises that used to or will manufacture, distribute, store, use or transport highly toxic chemicals shall refer to the “Catalog 2015” to do the highly toxic chemical safety management.
CIRS recommends that enterprises that manufacture, use, import, distribute or transport hazardous chemicals to refer to the “Catalog 2015” and other related catalogs and lists that mentioned in the contents above to do the relevant hazardous chemical registrations and management. Relevant licenses and certificates shall be acquired before any hazardous chemical related activities. GHS, SDS and Labeling requirements shall also be fulfilled.
As a leading regulatory service provider in China, CIRS is able to provide enterprises tailored regulatory services according to different chemical substances.
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