The "Measures for the Environmental Management of Hazardous Chemicals Registration (Trial)" which will be effective on 1 Mar 2013, stipulated that the manufacturers and downstream users of hazardous chemicals of prior environmental concern (HCPEC) should develop environmental risk assessment (ERA) and submit the ERA report when applying for the environmental management registration of hazardous chemicals.
The ERA report could be prepared by a third party agency and the agency will be responsible for the conclusion of the ERA report. Ms. Hong Wang, an expert from the Chinese Research Academy of Environmental sciences (CRAE) confirmed that supporting documents for preparation of ERA report over HCPEC have been drafted and technical opinions are being collected from the MEP. Final issuance is expected next year.
The key objective of developing the ERA report is to determine which level of supervision should be imposed on the HCPEC companies. Under the supporting document, risks of the HCPECs will be rated as “extremely high risk”, “high risk”, “medium risk” and ”low risk”. Meanwhile, the capability of risk controlling of the HCPEC companies will be assessed and graded as level I, level II, level III and level IV. The supervision level over the HCPEC companies will be determined by both the risk assessment outcome and the management capability of the companies through the evaluation matrix (see the figure below), which is considered as a novel strategy uncommonly adopted in other countries. Generally, the supervision level will be ranked as “general environmental risk”, “medium environmental risk”, ”higher environmental risk”, “significant environmental risk”. The higher the risk is, the more supervision the company would receive from the local environmental authorities.
Figure.Procedure of Environmental Risk Assessment on HCPECs
