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In a recent closed-door meeting, China NRCC discussed with enterprises the revision of the Guidance for the Implementation of China 2015 Inventory of Hazardous Chemicals. The meeting analyzed major changes to be made to the Guidance (2015), discussed some suggestions from the enterprises, and outlined the revision schedule.
Since the issue of the Guidance (2015) NRCC encountered many problems. For instance, NRCC did not consult enterprises on including hazardous chemicals classification in the guidance prior to the release of the Guidance (2015), which brings some problems in the compliance practice. Enterprises also have a dispute over details in the Guidance (2015); they doubt whether the 70% principles is reasonable and enough to manage the risks.
NRCC aims to develop a list of highly hazardous chemicals with stricter lifecycle management on these listed chemicals. Controversies over some rules, such as the 70% principle, will be submitted to the internal meeting for further discussion.
In terms of re-assessment of the harmonized classification, the applicant will go through the following steps.
Request for re-assessment of the classification：Any individual or enterprises can request a re-classification of a hazardous chemical through a platform as long as they have sufficient hazard data.
The officials collect assess the requests.
The officials organize seminars to discuss the reassessment.
The officials further research on the reassessment requests.
The officials publish the results.
In the meeting, NRCC took suggestions and questions from the enterprise in attendance. The following issues were raised:
1.AICM suggests NRCC to further adopt CLP as a reference because CLP has strong data support (At present, China classifies carcinogenicity based on the list of carcinogens published by the IARC).
However, NRCC believes that it is not proper to adopt multiple classification standards at the same time.
2.If CLP is stricter than the current standard, can enterprises adopt CLP?
According to NRCC, the answer is “possibly yes”. NRCC believe it is a scientific way to do so. However, this approach is likely to pose supervisory issues for local work safety bureaus. NRCC will consider this suggestion and submit it for an internal discussion.
3.In the new Guidance, AICM suggest the NRCC to conduct an analysis on available data.
NRCC and other attendants strongly agree with the suggestion. Traceable data sources have always been contentious issues internationally. NRCC will strive to achieve it.
4.Is it possible to annually update the classification information and hazardous sheet of hazardous chemicals?
NRCC believes it as an ideal way to revise the classification information sheet.
The revision will follow these steps:
NRCC will construct a unified mechanism to collect information and to classify hazardous chemicals.
An information platform will be constructed.
Start to revise the Guidance
Set an adjustment mechanism of the Inventory
Start to revise the Inventory
To achieve a constant adjustment to the Inventory
