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China SAWS Publishes The Measures for The Administration of Physical Hazard Identification and Classification of Chemicals for Consultations.

4 Dec 2012, The State Administration of Work Safety(SAWS) of China publishes draft measures for the administration of physical hazard identification and classification of chemicals for consultations. The deadline for public comments is 4 Jan 2013.

The measures provide clarifications about how to determine whether registration is required for a chemical product(substance or mixture) that is not listed in the Catalogue of Hazardous Chemicals.

The draft measures require manufacturers and importers(companies) to carry out physical hazard identification and classification at SAWS-approved institutions for chemicals with unknown hazard properties and submit identification and classification report to the National Registration Centre for Chemicals(NRCC). If chemicals are confirmed as hazardous, companies must prepare SDSs and labels and register such chemicals within 6 months.

The measures has also set detailed requirements regarding the qualifications and application procedure of qualified hazard identification institutions.

Definitions of Chemicals with Unknown Hazard Properties

The following categories of chemicals are defined as chemicals with unknown hazard properties:

  • chemicals listed in the Catalogue of Hazardous Chemicals, for which new physical hazard properties have been discovered;

  • mixtures containing more than one physical hazardous component listed in the Catalogue;

  • For a chemical that is not listed in the Catalog but with unknown physical hazard hazard properties;

  • For a newly developed chemical product that lacks physical hazard information.

Obligations of Manufacturers & Importers

The measures impose the following new obligations on manufacturers & importers of chemicals in China:

  • carrying out physical hazard identification and classification at SAWS-approved institutions for chemicals with unknown hazard properties and submitting classification report 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 within 6 months;
  • 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.

Reference

CIRS's Comments & Interpretation

  • The draft measures is promulgated in accordance with the article 22 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 catalogue.
  • It is not necessary to ask SAWS-approved institutions to carry out hazard classification for all chemicals. If sufficient data is available to prove that a chemical is not physically hazardous, such chemical will be exempt from hazard classification.
  • We can predict that transitional period will be given once the measures enter into force. Firstly, the list of approved labs is not available yet. Secondly, online registration system needs further improvement before it can be used for HazChem registrations for importers.

If you have more questions, please contact:

  • Mr Yunbo Shi, CIRS China Office
    11F Building 1, Dongguan Hi-Tech Park, 1288 Chunbo Road, Binjiang District, Hangzhou 310052, China
    Tel: +86-571 8720 6555 | Fax: +86-571 8720 6533
    Email: yao.feng@cirs-reach.com