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Shanghai Steps up New Chemicals On-site Inspections

Random on-site inspection for new chemical substances will be stepped up to cover general enterprises that manufacture, use or import chemical substances.

Recently, Shanghai Municipal Bureau of Ecology and Environment announced to start the new chemical inspection under its purview in September.

For businesses, including domestic manufacturers, importers and representative agents that have registered new chemical substances, the focus will be placed on new chemical substances registered for (1) regular notification in 2020, (2) regular notification of hazardous chemical substances or hazardous chemical substances of priority environmental concern over the past five years (2016-2019), and (3) simplified notification (mainly for those imported for use or trade) in 2020.

It should be particularly noted that this time for enterprises manufacture, use or import chemical substances, on-site law enforcement and environmental supervision for new chemical substances will be initiated. At least one enterprise (1-2 substances) is subject to spot inspection. In this regard, the focus will be placed on finding out whether there is any chemical not listed on the Inventory of Existing Chemical Substances in China (IECSC) while hasn’t been registered. The official inspectors may require enterprises to provide a list of their chemical substances, or enter the enterprises' management system, or on-site check relevant materials about environmental impact assessments, safety assessments for substance comparison against the IECSC. 

In terms of the on-site inspections, priorities will be given to records kept by enterprises, information communication and disclosure (SDSs and labels), activities report, implementation of risk control measures, etc. The inspectors will focus on chemical exposure and see whether businesses have implemented the administrative management requirements and risk control measures specified in the registration certificates. In addition, the enterprises should also complete the hazardous chemical registration for new chemicals if they have hazardous properties and develop contingency plans accordingly.

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