On September 26th, 2013, the much-awaited Inventory of Hazardous Chemicals (draft version) was published by State Administration of Work Safety (SAWS) for open consultation.
The release has echoed Dr. Liu’s statement on Chemcon Asia on Sep 10th (See Chemlinked news: Progress of China's Inventory of Hazardous Chemicals Unveiled at ChemCon Asia 2013). All the speculations from the stakeholders have been settled down. The recurring delay of the inventory really stirred up confusion over how to fulfill obligations under Decree 591, especially the HazChem registration under SAWS Order 53, considering that the inventory is the essential basis guiding the substantial registration work in the visible future.
Inventory of hazardous chemicals (2013 draft) could be searched at Chemlinked toolbox.
China Chemical Inventory Search
� input chemical name or CAS#Format of the Inventory and Major Revision
The draft version of the inventory consists of 2,936 entries, even smaller in size compared with the rumored 3,400 (see Chemlinked news: Unexpected Policy U-turn Set to Downsize the Catalogue of Hazardous Chemicals). What’s worth mentioning is that an entry may be a pure substance or a mixture. Instead of UN numbers, CAS numbers are adopted.
Previously, the NRCC officials claimed that a “Guidance-like” document would be prepared to help the industry to comply with the registration obligation (see Chemlinked news), which was later confirmed by Dr.Liu in his Chemcon presentation.
In line with the above predictions, the draft inventory provides the definition of hazardous chemical substances as well as the principle of classification in compliance with the fourth edition of UN GHS. An added column of special notes shows whether a chemical is hyper toxic or not, judging from its LD50 (median lethal dose) as stated in the draft inventory.
Hazard categories:
1. Physical hazards
Explosives: Unstable explosives, Division 1.1~1.4;
Flammable gases: Category 1, Category 2, Chemically unstable gases category A~B
Aerosols: Category 1;
Oxidizing gases: Category 1;
Gases under pressure: Compressed gases, Liquefied gases, Refrigerated liquefied gases, Dissolved gases
Flammable Liquids: Category 1~3;
Flammable Solids: Category 1~2;
Self-reactive substances (and mixtures): Type A~E;
Pyrophoric liquids: Category 1;
Pyrophoric solids: Category 1;
Self-heating substances (and mixtures): Category 1~2;
Substances (and mixtures) which on contact with water emit flammable gases: Category 1~3;
Oxidizing liquids: Category 1~3;
Oxidizing solids: Category 1~3;
Organic peroxides: Type A~E;
Substances corrosive to metal: Category 1;
2. Health hazards
Acute toxicity: Category 1~3;
Skin corrosion/irritation: Subcategory 1A~1C, Category 2
Eye effects (Serious eye damage and eye irritation): Category 1, Subcategory 2A~2B;
Sensitization: Respiratory sensitizer subcategory 1A~1B, Skin sensitizer subcategory 2A~2B;
Germ cell mutagenicity: Subcategory 1A~1B, Category 2
Carcinogenicity: subcategory 1A~1B, Category 2;
Reproductive toxicity: Category 1A~1B, Category2, Additional category;
Target organ systemic toxicity (TOST) - single exposure: Category 1~3;
Target organ systemic toxicity (TOST) - repeated exposure: Category 1~2;
Aspiration hazard: Category 1;
3. Environmental hazards
Acute aquatic toxicity: Category 1~2;
Chronic aquatic toxicity: Category 1~3;
Hazardous to the ozone layer: Category 1.
Difficulty in Releasing the Inventory
The current edition of Catalogue of Hazardous Chemicals came into force in 2002. With State Council Decree 591- Regulations on the Control over Safety of Hazardous Chemicals replacing its predecessor Decree 344, the Inventory is subject to major changes. Stipulated under Decree 591, the revised inventory needs to be consulted among 10 ministries under the State Council. The previous recurring delay of the draft release could be attributed to the conflict among a large number of ministries involved in the discussion. (See expert article: Catalogue of Hazardous Chemicals: Resolving the Current Impasse)
After public consultation, to be closed on Oct 31st, the draft has to go through the expert evaluation before the official version released.
Current Status of the Registration Work
Since the release of the SAWS Order 53 and the launch of the online registration system from July (see Chemlinked news), no substantial registration work has been accomplished.
To break the deadlock, Shanghai has initiated the registration work regionally. However, SAWS is still struggling in its efforts to come up with feasible identification methods for potential physical hazards. Even with the 2013 draft version published, more efforts are needed to pave the road for implementation of the physical hazard identification and classification (PHI&C). Besides, the identification of potential health hazards and environmental hazards, which are still under development, will be overseen by two other Chinese departments. (See Chemlinked news: Shanghai Kicks off the Hazardous Chemicals Registration)
Chemicals Used as Pesticides
Chemicals marked with asterisk marks (*) in the draft inventory will be subject environmental management registration under MEP Order 22 when they are used as pesticides. The good news is that they can be exempted from applying for other relevant licenses from SAWS. As pre-warned by the officials of Institute for the Control of Agrochemicals, Ministry of Agriculture (ICAMA) (see Chemlinked news), malathion is included in the draft inventory with no surprise. Some other export-oriented pesticides are listed as well, chlorpyrifos and acephate for instance.
