List of Accredited Testing Institutes for Physical Hazard Identification in China to be Released in Early 2015

According to China’s Measures on Physical Hazard Identification and Classification for Chemicals (SAWS Order 60), chemical manufacturers and importers should use accredited testing institutions to identify the physical hazards of chemicals meeting any of the following conditions:

1. The chemical consists of one or more ingredients listed in China’s Inventory of Hazardous Chemicals, and its physical hazards are uncertain as a whole.

2. The chemical doesn’t contain any ingredients listed in China’s Inventory of Hazardous Chemicals, and its physical hazards are uncertain as a whole.

3. When a chemical with uncertain physical hazards is produced/used for the purpose of scientific research or product development and the annual tonnage exceeds 1 ton.

4. The chemical is listed in China’s Inventory of Hazardous Chemicals but found to have new physical hazard(s).

The Order has been in force since September 1^st, 2013, but its implementation has been hindered due to lack of supporting documentation. Relevant documentation templates, the test guidelines and qualification criteria of the testing institutes were published this year, leaving the list of the accredited identification institutes as the final missing piece of the puzzle. According to the NRCC, the drafting of the name list was finished in October and the final release by SAWS is expected next January or February.

In addition to conducting the tests, testing institutes are also responsible for issuing the identification report to the chemical companies and reporting to SAWS before the Jan 31^s  of each year about the chemicals identified in the previous year. Whether a serial identification (see Note) can be applied to a group of chemicals should be jointly decided by the chemical company and their testing institute.

SAWS Order 60 can be implemented once the list of accredited institutions is made public, though without the publication of two other important chemical lists including the Inventory of Hazardous Chemicals (read latest update) and the List of Chemicals Exempted from Physical Hazard Identification, the pre-screening process used by chemical companies to find out if the chemicals/products they utilize are subject to hazard identification obligations may be more convoluted.

 Note: Serial identification here means the physical hazard identification for chemicals with similar composition and usage and of no significant differences in physical hazards.