On 22 March 2013, the MEP published four supporting document for environmental management registration of hazardous chemicals. The MEP promulgated the Order 22, “Measures for the Environmental Management Registration of Hazardous Chemicals (Trial)” on Oct 10, 2012. The HC companies should obtain registration certification for environmental management from the MEP and the companies of hazardous chemical of high environmental concern (HCPEC) are further required to conduct the environmental risk assessment. With its effectiveness on 1 March 2013, four supporting documents have been released to guide the practical registration work.
Document 1: “Application Form of the Environmental Management Registration for Manufacture and/or Use of Hazardous Chemicals”
The document contains general information about the applicant, neighboring environmental concerned areas and targets, the category, volume, labeling, hazard classification, use, use-pattern, SDS, emissions of particular chemical pollutants. Detailed instructions on how to fill the form are also provided;
Document 2: “Application Form of Alteration for Environmental Management Registration for Manufacture and/or Use of Hazardous Chemicals”
If the registrant alters its HC manufacturing/utilizing which are specified in the registration certificate during the validity of the certification, the registrant should apply for the registration alteration with 30 days upon occurrence of alteration:
The registrations for HCPEC companies are approved by the provincial competent authorities and the certificates are issued by the county authorities. If the HCPEC registrant 1.increases number of HCPECs’ categories; 2. relocates the production facility or other modification to the issuing body occurs, the registration procedure should be renewed instead of the alteration application ;
When no modification to the issuing body occurs, the HC companies and the following conditions are met: 1. Categories of increase; 2. Manufacture/Use quantity of Hazardous chemicals increases or 3. Activity type of the HCPECS is changed, the HC companies should additionally submit the “Application form of the environmental management registration for manufacture and/or use of hazardous chemicals”, but they only need to fill the information concerning the alteration. If the alteration involves new construction, re-construction or expansion of the HC facilities, the registrant should additionally submit the “approval documents of the environmental impact assessment report”;
If the categories or volumes of the HCs are decreased, it is only needed to apply for the registration renewal within 3 months prior to the expiration of the original certification;
Document 3: “Template of the Certificate for Environmental Management Registration for manufacture and/or use of hazardous chemicals”
The environmental management registration sticks to the principle of “one company, one certificate” and the original and the duplicate of the certificate bear the equal legal effect. The certificate specifies certain information such as general information of the registrant, category of the hazardous chemical, conditions of the manufacture and/or use of the hazardous chemicals, and supervision requirements for the registrants, etc.
Document 4: “Guidance for Compiling the Environmental Risk Assessment Report for HCPECs (Trial)”
The order 22 requires that the HCPEC manufacturing/use companies to conduct the environmental risk assessment (ERA) for their HCPECs and the assessment should be carried out by external competent evaluating agencies for the ERA. The ERA report should be submitted when the HCPEC companies apply for the environmental registration.
The ERA report is to determine which level of supervision is suitable to be imposed on the HCPECs. The supervisions level over the HCPEC companies will be influenced by both the risk assessment outcome and the companies’ risk controlling capability on their HCPECs. The environmental risk of the HCPECs is a combination of both the hazard gradation and the exposure level of the HCPECs while the risk control capability of the companies are determined by both the company’s internal status of environmental management and the sensitivity of environmental susceptible areas surrounding the companies. The guidance provides qualitative approaches to determine the above parameters.
