On 17 July 2013, The State Administration of Work Safety (SAWS) of China published its Order No.60 - the measures for the administration of physical hazard identification and classification of chemicals. The new regulation entered into force on 1 September 2013.
The measures require manufacturers and importers(companies) to:
- Carry out physical hazard identification and classification at SAWS-approved institutions/labs for chemicals (substance and mixtures) with unknown hazard properties; and then,
- Submit identification and classification report to the National Registration Centre for Chemicals (NRCC).
If chemicals are confirmed as hazardous by NRCC, companies must prepare SDSs and labels and register such chemicals.
What is 'Chemicals with Unknown Hazard Properties' ?
The following categories of chemicals (substances and mixtures) are defined as chemicals with unknown hazard properties and required physical hazard identification & classification:
- For a chemical product that contains more than one component listed in the Catalogue(and the overal physical hazard of the mixture is undetermined);
- For a chemical product that is not listed in the Catalog but with unknown physical hazard properties;
- For a chemical product that is used for R&D purpose with volume above or equal to 1t/y(if the physical hazard is undetermined).
Note: SAWS will publish a Catalogue of chemicals exempt from hazard identification and classification in the future.
New Obligations under SAWS Order No.60
- carrying out physical hazard identification at SAWS-approved institutions for chemicals with unknown hazard properties, preparing hazard classification report and submitting it to NRCC;
- preparing SDSs & labels for chemicals which have been confirmed as hazardous by NRCC;
- registering chemicals which have been confirmed as hazardous according to SAWS's order 53;
- building chemical safety management file including hazardous properties of chemicals with known physical hazards, identification and classification reports and the name and quantity of chemicals that have not been assessed.
- The measures is promulgated in accordance with the article 21 of SAWS's order 53 - The Measures for the Administration of Registration of Hazardous Chemicals. The article 22 says that for chemicals with unknown hazards, companies shall ask SAWS-designated organizations to conduct hazard classification and register those chemicals that have been confirmed as hazardous. This will allow the authorities to ask companies to conduct hazard classification and register chemicals that are not yet included in the Hazardous Chemical Catalog 2015.
- It is not necessary to ask SAWS-approved institutions to carry out physical hazard identification for all chemicals. If companies have sufficient data to prove that a chemical is physically hazardous or is non-hazardous, it is not necessary to pay SAWS-approved institutions to do physicochemical tests and issue hazard identification report(mainly test report). However, companies may need to prepare their own hazard classification report based on existing data and ask NRCC to verify it.
- The biggest change in Order No.60 is that R&D chemicals will be exempt from hazard identification and classification if the volume is below than 1t/y; Because of this rule, R&D chemicals(<=1t/y) that are not listed in the Catalog will also be exempt from HazChem registrations;
- It is not clear how SAWS is going to handle chemicals that are not listed in the Catalog but have health and environmental hazards. We expect to have more detailed guidance in the future.
More Regulations on China Hazardous Chemical Management, please click here.
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