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On Sep 27th, 2018, Shanghai Environmental Protection Bureau (SEPB) held a conference and announced that SEPB would immediately initiate the 2018 program of new chemical inspection and evaluation. (上海市2018年新化学物质跟踪控制检查专项评估工作方案).
After the meeting, many chemical enterprises in Shanghai received notice on requirements to provide the following materials before Oct 12th, 2018:
A scanned copy of the annual report of new chemicals in 2017 (the enterprise should be the holder of the registration certificate);
A scanned copy of the registration certificate for the new chemicals in the simplified general notification and regular notification acquired in 2017 (the enterprise should be the holder of the registration certificate);
A scanned copy of the registration certificate for the new chemicals in the regular notification acquired from 2013 to 2016 (the enterprise should be the holder of the registration certificate);
A scanned copy of the compliance statement with the company stamp.
New chemical monitoring, inspection, and evaluation in Shanghai was first carried out in Apr 2017. The work program started relatively late in 2018 and was expected to be completed in October. Based on this timeline it is likely that fewer enterprise will be inspected compared to the number in 2017, however this doesn’t equate to a reduced compliance burden. According to our information, the inspection this year will be stricter than before. Compared to the simple verbal warning issued to violators in 2017, in 2018 violators will be subject to harsher penalties.
Not all the enterprises that received the notice and were requested to provide materials will be subject to the on-site inspection. SEPB will review the submitted materials and determine the inspected enterprises based on their own rules and standards. The inspection will mainly focus on the new chemicals for which an enterprise have acquired a registration certificate of regular notification during 2013~2017 (classified as new hazardous substances or hazardous substances with priority environmental concern), and new chemicals for which the enterprises have acquired registration certificate of simplified general notification.
The content list of the on-site inspection hasn’t be issued by SEPB. Based on the inspection in 2017, we expect that the inspection will focus on assessing registration certificates, all kinds of reports (annual report, activity report for the first time, activity report for every time), the amount of new chemicals with activities (whether it exceeds the notified amount) based on the storage records and the import/export ledger, hazardous information communication (labels and SDSs), emission of the new chemicals with priority environmental concern, and the risk control measures (including the employee protection, emergency program, waste disposal, etc.).
