At the International Chemical Regulation REACH Workshop, Hangzhou 2012, Mr Guo Zongzhou, the NRCC speaker in charge of the HC registration, claimed that the NRCC has already drafted a supporting document for the identification and classification of chemicals’ physical hazards, which is formulated to assist the registration of chemicals with unidentified hazard properties.
The management of chemicals with uncertain hazard properties has become one noticeable adjustment to the new “Measures for the Administration of Hazardous Chemicals Registration (SAWS Order 53)”. Mr Guo clarified the term “chemicals with unidentified (uncertain) hazard properties” as follows. They are subject to potential HC registration under the SAWS Order 53.
Chemicals included in the C&L Inventory (Catalogue of Hazardous Chemicals) but with unidentified hazard properties;
Chemicals not included in the C&L Inventory, but which are found to have newly discovered hazards.
Other chemicals to be will be defined in the future official guidances.
According to Article 22 of the SAWS Order 53, potential registrant should appoint a state-certified agency to conduct the hazard identification for chemicals with uncertain hazard properties. The draft on the identification and classification of chemicals’ physical hazards has just been released on 3 Dec 2012 and the final version is expected early next year. Two other concrete guidelines on the identification testing methods and the qualification assessment for certified identification institutions are right on the way. Hopefully, these supporting measures plus the long-awaited C&L Inventory will display a clearer roadmap for the affected companies undertaking the HC registration.
Q&A Session
Concerns centering on the to-be-registered chemicals were widely raised in the wake of the 30-minute presentation. Several questions touched upon the hazard identification of articles, preparations or chemical mixtures that may have potential hazard properties (such as toxicological or environmental hazard characteristics) but are not included in the C&L inventory. Mr. Guo suggests potential registrants keep close watch on the release of the NRCC guidance document.
Q: Most of our products are mixtures (or preparations) which share similar components with only differences in the content proportion. Shall we arrange HC registration for them? And how shall I fill out their physic-chemical data if necessary?
A: Mixtures containing one or more component substances that are listed in the Inventory with known physical hazards are required to carry out physical hazard identification and classification. When identified to be hazardous by the NRCC evaluation, they are subject to the HC registration. As to how to provide the corresponding data, for whatever mixtures, preparations, or articles, we will publish a technical guidance on the practical issues (See Chemlinked news on Sep 29), such as how to conduct the registration and what tests to be performed.
Q: You mentioned the hazard identification for hazardous chemicals. I see that the SAWS is currently working on the standard with regard to physical hazard identification of chemicals (See Chemlinked news on Dec 7). How about the hazards other than physical hazards?
A: SAWS is only responsible for compiling the identification and classification standard of chemicals’ physical hazard. However, identifications of environmental hazards and toxicological properties of chemicals are governed by the China Ministry of Environmental Protection (MEP) and the Ministry of Health (MOH), respectively.
Other highlighted topics in Guo’s speech include the clarification of registering manufacturers, registration timeline, registration content, procedure duration, required documents, post-registration obligation and legal liabilities.
Q: If our business involves the refinement of a hazardous chemical product, Shall I register the product as the HC manufacturer?
A: If your product turns to be a high-purity hazardous chemical after the purification, you will be considered as a “HC manufacturer”. Otherwise, if you repackage the hazardous chemicals or dilute them with non-hazardous solvents for the purpose of sale or use, you are not defined as “a HC manufacturer”.
Q: Shall I acquire a HC registration certificate for my hazardous chemical products imported prior to the enforcement of the SAWS Order 53 (1 Aug 2012)?
A: No, you are only required to register products imported after August 1, 2012. However, if you are still importing or plans to continue the imports, the HC products need to be registered.
