China <Provisions on Physical Hazard Identification and Classification of Chemicals> (China SAWS Order No. 60) was enacted on July 17^th, and will be effective from September 1^st, 2013.

 

The Provisions will have tremendous impact to chemical industry.

 

Comparing to the draft version (www.randis.cn/html/ywb/Ewxhxpdj_258_143.asp), the enacted Provisions has no much difference on key points.

 

Key points:

0. Terminology

‘Chemical’ here refers to substance, compound and their mixtures.

‘Physical hazard identification’ means identification of hazardous properties including flammability, explosivity, causticity, combustion-supporting, self-reaction and reaction-in-contact-with water etc., through tests or judgment according to China  national or industry standards.

‘Physical hazard classification’ means assessment of physical hazard identification results or of referred data according to China national or industry standards, so to determine the physical hazard classification of the chemical.

 

1. Responsibility:

Chemical producers and importers in China are responsible for the hazard identification and classification of the manufactured/imported chemical products of which such classification and identification is needed.

 

2. Chemical scope:

2.1 Mixture of chemical product with one or more ingredients listed in ‘Catalogue of Dangerous Chemicals of China’ (remark by Randis: the new Catalogue is not published yet. It could still months’ time), and the physical hazard properties of the mixture product is not determined.

2.2 Chemical not listed in the ‘Catalogue’, and the physical hazards of the chemical are not determined.

2.3 chemical for scientific research or product development with annual manufacture/import quantity over 1 ton, and the physical hazards of the chemical is not determined.

2.4 Catalogue of chemicals of which the Physical Hazard Identification and Classification is exempted will be announced.

 

3   Procedure

3.1  Chemical manufacturer/importer submits application to Identification Institutes to be announced by SAWS.

3.2  Supporting materials and chemical sample be provided to the Identification Institutes.

3.3 Identification reports (should include the 16 GHS physical hazards and other needed properties e.g. vapor pressure, self-ignition temperature, stability and reactivity, etc.) from the Institutes should normally be issued within 20 working days.

3.4. Chemical manufacturer/importer should compile Hazard Classification Report based on the Identification Reports.

3.5. Chemical manufacturer/importer should then submit the Hazard Classification Report to NRCC for assessment and verification.

3.6  If the chemical product is classified as Hazardous Chemical, the SDS and Safety Label should be prepared, and the Hazardous Chemical should be registered to NRCC. 

 

4  Penalty

In breach of this Provisions, the company may face penalty of upto 30k RMB.

 

Problems: if a chemical product (not listed in Catalogue of Dangerous Chemicals of China ) is classified by the manufacturer/importer based on available data or literature or classification results of other countries (e.g. EU Harmonized Substances), is the chemical product still regarded as ‘physical hazard properties of the chemical product is not determined’, and then at least a Hazard Classification Report shall be prepared to NRCC for assessment and verification?

The answer today is: yes.

The cost for the identification and assessment/verification? Not known yet.

 

 

Want an English version of the Provisions at reasonable price?

Please contact us at frankwang@randis.cn