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Since the open consultation of China’s Draft Inventory of Hazardous Chemicals concluded on Oct 31st, 2013, there has not been any official release informing the public when the final version will be issued.
In a seminar held by the National Registration Center for Chemicals (NRCC) at the end of February 2014, Director Li Yuncai detailed the reasons for the current deadlock. According to Director Li, the 10 competent authorities involved in compilation of the inventory engaged in interministerial discussions a week ago focusing on the progress of the Inventory. Major disagreements concerning the addition of nickel salts, cobalt salts and chemicals that can be used as active ingredients of pesticides into the inventory were encountered.
It is acknowledged that excessive intake of nickel and cobalt poses severe risks to human health. Long-term exposure to nickel salts may even cause an increased risk of cancer. It is suggested that such chemicals deserve to be kept in the inventory and earmarked for enhanced supervision. However opponents feel the hazardous properties do not present a significant risk. It would also be challenging for the authority to supervise these chemicals through all stages in the supply chain and clearly link cause and clinical effect, with an epidemiological significance great enough to warrant inclusion of these substances into the inventory.
A major consideration in compilation of the inventory is making sure regulatory compliance doesn’t smother growth in the industry. The balancing act between regulating to reduce environmental and social impact of industrial chemicals and ensuring economic and financial development is key, and with multiple ministries protecting their respective interest’s agreement was never going to be easy. The agrochemical industry is a major concern for regulators and stakeholders. The draft inventory mandates "Environmental Management Registration of Hazardous Chemicals" under MEP Order 22 for chemicals with asterisk marks (*) which denotes those used as active ingredients of pesticides, and pproximately 140 chemicals fall into the scope. The Ministry of Agriculture is extremely wary of such a regulatory clause, which would significantly impact the pesticide industry and is arguing against its inclusion.
The inventory has been severely hampered through all stages of its development most notably seen in the large delays which halted the release of the draft inventory. According to the director of the NRCC, the Inventory should be officially published in the first half of 2014 however considering the current situation this is an optimistic prognostication.
It is worth noting that hazardous chemicals excluded from the Inventory of Hazardous Chemicals will be regarded as “chemicals with unidentified hazards” in China, thus subject to “Hazard Identification”. If the chemical is already classified under a different regulatory framework by a recognized, foreign competent authority, companies should submit the classification report to China’s competent authority (for physical hazard identification that is the NRCC) for review. If the classification result is not approved, the chemical in question still has to be tested, identified and classified.
The system of physical hazard identification is currently in development with several supportive documents of SAWS Order 60 recently released for consultation. In regards to health hazard identification and environmental hazard identification, the ball hasn’t even begun to roll.
