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On November 30th, 2020, at the CRAC-HCF 2020 Virtual Forum [1] by REACH24H, Mr. Chen Jun, an official from the National Registration Center for Chemicals (NRCC) of the Ministry of Emergency Management (MEM), unfolded a roadmap of the reform of the registration framework regulating hazardous chemicals and relevant businesses. Mr. Chen Jun had also previously responded to comments on the proposed revisions to the Implementation Guidance of the 2015 Inventory of Hazardous Chemicals as seen here.
China has been practicing the registration management of hazardous chemicals for nearly a decade. According to the Regulations on the Control over Safety of Hazardous Chemicals (State Council Decree No. 591) [2], enterprises that manufacture or import hazardous chemicals should register the hazardous chemicals with the authority for the registration of hazardous chemicals under the State Council. The system primarily aims to ensure the safety of workplaces involving hazardous chemicals, and prevent and reduce hazardous chemicals-related accidents.
Mr. Chen stressed that besides the inherent risks of chemicals, increased attention should be paid to the risks of accidents which could occur in the manufacture, use, etc. of such substances. With risk management at the core, a system requiring the registration of risks of both chemicals and chemical enterprises will be put in place.
According to Mr. Chen, the future endeavors will be dedicated on the following four aspects.
1. Clarify the Scope of Chemicals Subject to Registration Requirements
At present, hazardous chemicals registered are largely those listed in the Inventory of Hazardous Chemicals (2015)[3], and there are a lot of hazardous chemicals left unregistered on the market, which makes it hard for regulators to get a full grasp on the information concerning chemical risks and undermines the effectiveness of policies, emergency responses and workplace safety regulation.
In response, the authority is planning to further clarify the scope of chemicals subject to registration requirements, so that all chemicals which meet the criteria of hazardous chemicals must be registered.
2. Expanding the Scope of Chemical Enterprises Subject to Registration Requirements
Under the existing system, some high-risk chemical enterprises are not subject to registration management. As such, the authority is currently working to enhance the control of major hazard installations by imposing registration requirements on enterprises which engage in the operations of hazardous chemicals and constitute any major hazard installation. The arrangement was introduced earlier in 2019 to facilitate the building of monitoring and early-warning systems for workplace safety risks related to hazardous chemicals, but it was impracticable because of the absence of legal basis.
Considering that enterprises which use hazardous chemicals are prone to risks and accidents, such businesses are expected to be subject to registration requirements as well.
3. Make Registration Contents More Risk-based
The information on major hazard installations and hazardous processes are crucial to safety regulation and emergency responses in the sector of hazardous chemicals. Therefore, in specifying registration requirements, the authority is considering to mandate the submission of safety assessment reports, information on major hazard installations, and other information which are closely related to important safety risks and safety regulation.
4. Improve the Regulatory Mechanism of Registration
To ensure effective regulatory practices in the sector of hazardous chemicals, the authority will enhance law enforcement by, in particularly, tightening the management of registration changes, and make public enterprises which deliberately conceal or falsify any information to be registered.
Mr. Chen added that, drawing on international experience, efforts are under way to explore the establishment of an annual reporting system for enterprises, so as to ensure the accuracy and timely update of relevant information.
