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In early August 2020, the Chinese Ministry of Emergency Management (MEM) published a notice, announcing to solicit comments on the draft revision to the Guidance for the Implementation of China 2015 Inventory of Hazardous Chemicals (Trial) [1]. The consultation is set to end on August 31, 2020.
Since its publication, the 2015 Inventory [2] and its Implementation Guidance have played an essential role in the enforcement of chemical safety regulations, and served as fundamental guidelines for regulators, enterprises and the public to understand the hazards of hazardous chemicals. Nevertheless, some problems are identified in their implementation, thus necessitating the work to revise the existing arrangements. ChemLinked has summarized major changes made in the draft revision.
Adjustments to Regulatory Scope
In the 2015 Implementation Guidance, an enterprise which engages in manufacture and/or operations of diesel fuels is regulated as a hazardous chemical enterprise (unless the close cup flash point of every batch is higher than 60℃). The draft revision deletes this statement, and instead stipulates that automobile diesel fuels with a grade of -10# or above are not subject to the Inventory, while those with a grade of -20# or below are regulated as hazardous chemicals in the Inventory. This is aimed at keeping aligned with the national standard Automobile Diesel Fuels (GB 19147-2016), which requires that the flash point of automobile diesel fuels with a grade of -10# or above must not be lower than 60℃.
The management of mixtures meeting the 70 percent principle is further clarified. The draft revision provides that as long as any mixture meets the criteria of the 70 percent principle, it should be considered as a hazardous chemical listed in the Inventory. Meanwhile, it also specifies that the principle does not apply to entries with a standard concentration of less than 70 percent, such as formaldehyde solution, and those falling under Entry No. 2828.
Further guidance is given on practices concerning Entry No. 2828. The generic entry covers all preparations containing flammable solutions and with flash points below 60℃. The draft revision details that where any liquid with a flash point above 35℃ cannot achieve sustained combustion, the Entry No. 2828 rules do not apply.
A new addition in the draft revision states that, except where noted, solutions in the Inventory refer to aqueous solutions.
Changes Proposed for Classification Information Sheet
The 2015 Implementation Guidance lists 88 varieties under Entry No. 2828 for ease of reference, such as coatings, adhesives and printing ink. Given that many other products also fall under this entry, the draft revision adds four more items to it, including:
89. Other coatings containing flammable solutions (alias: Other paints containing flammable solutions)
90. Other adhesives containing flammable solutions
91. Other synthetic resins containing flammable solutions
92. Other products with a flash point of no higher than 60℃
Additionally, the draft revision also involves proposed changes made to the hazard classification of 88 hazardous chemicals in the Inventory, in the form of addition, deletion or modification. ChemLinked recommends that enterprises should carefully review the changes and submit feedbacks, if any, in a timely manner. As soon as the draft revision is officially approved, enterprises will need to update relevant hazard communication information, such as SDS and labels and hazardous chemical registration information.
