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Measures on the administration of hazardous chemicals registration (a.k.a SAWS Order 53) has come into force on Aug 1st, 2012, which stipulates that all the chemicals listed in the Catalogue of hazardous chemicals should get registered. SAWS Order 53 is not only limited to chemicals in the Catalogue, hazard identification for chemicals of uncertain hazards should be arranged by the registering companies by designating some accredited testing institutes. Chemicals determined to be hazardous need to be registered as well. To standardize the identification and classification work of physical hazards of chemicals, China SAWS drafted the “Measures on the management of physical hazard identification and classification for chemicals” and consulted the public prior to Jan 4th, 2013.
On 11th and 12th Apr, NRCC hosted a seminar on SAWS Order 53, Dr. Zhang hongzhe from the NRCC explained the recent developments on the formulation of the “Measures on the management of physical hazard identification and classification for chemicals” in the following aspects:
Categories of chemicals to be identified and classified
Chemicals listed in the Catalogue of Hazardous Chemicals, which are found to possess new hazard properties;
Chemicals with no less than one constituent listed in the “Catalogue of Hazardous Chemicals”, but the physical hazard of the entire chemicals is uncertain;
Chemicals not listed in the Catalogue of Hazardous Chemicals and with uncertain physical hazards;
For the purpose of scientific research and product development, chemicals with to-be-determined physical hazards, with annual production over 1 ton/year.
The physical hazard identification and classification of the last case was not considered in the consultation draft. The NRCC has consulted the suggestion from the Association of International Chemical manufacturers (AICM) to include this scenario at present.
Serial Identification
NRCC has taken into account of the vast varieties of products involved in the paint and printing ink industry. Potentially huge obligation load will be on the industry if hazard identification and classification has to be performed for each type of product with uncertain hazards. Thus, companies of products sharing similar use, constituent, and physical hazard would be allowed to apply for serial identification with the designated identification agencies.
Data sharing
Data sharing could be the solution to alleviate the companies’ obligation budget by avoiding the unnecessarily duplicate tests. Referring to the REACH Regulation model, manufacturers or overseas suppliers or importers of same chemicals could jointly commission one identification organization to conduct the physical hazard identification or designate one member to be responsible for the work. The hazard identification data and the report generated could be shared among the different members. Due to the affordability of the physical hazard testing, data sharing principle would only apply to explosives, self-reactive substances and mixtures, organic peroxides, according to the consulation draft. Wider applicability of the data sharing procedure might happen for all the chemicals. However, the physical hazards of the chemicals are majorly determined by the intrinsic property as well as the appearance and status. The flammability and self-heating property of the same chemical could be drastically different. i.e. cobalt naphthenate in powder is easily flammable while the in bulk form it is non-flammable; sodium nitrate in powder is oxidizer, but in particles, it does not possess oxidizing property. To justify the cases above, sharing physical hazard data could only be valid for chemicals of the same constituent as well as the same appearance and status. Thus, product sameness should be guaranteed by the companies prior to the application of data sharing principle.
Could testing result and relevant data source be used for physical hazard classification?
One of the most frequently asked questions is whether the physical hazard identification and classification could be exempted if hazard classification of the products could be referred from the public database source from EU or Japan, if that products concerned is not listed in the Catalogue of Hazardous Chemicals. Dr. Zhang expressed that companies could submit the classification information from the public database in the classification report with the data source appended, however, it is still up to the review outcome of the NRCC. Another concern is focused on chemicals of uncertain hazards with the physical-chemical testing data generated from overseas testing institutions. As expressed by Li, yuncai from the NRCC, part of the physical-chemical testing could be exempted with the testing data obtained from overseas testing institutions if the original testing report as well as the qualification certification document could be provided.
