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NRCC Annual Report of HC Registration 2011

NRCC has released an Annual Report on its review of the Hazardous Chemicals Registration work in 2011 and 2012 prospective plans

Early this month, the National Registration Center for Chemicals (NRCC) of China SAWS has released its annual report, summarizing the hazardous chemicals registration work completed by the registration center during 2011 and in the meantime outlining a prospective plan for the 2012.

According to the report, in 2011, the NRCC and local registration offices have achieved breakthroughs in their hazardous chemicals registration work, which the NRCC attributes to the guidance and support offered by the State Administration of Safety Work (SAWS). On Dec 31st 2011, the NRCC had issued registration certificates to 22,447 hazardous chemical enterprises in 31 provinces/cities (not including importers, as importers are exempted from registration under the 2002 version “Measures for the Administration of Hazardous Chemicals Registration”, but will be included under future revised “Measures”); the first-time registration success rate is 99.3%. A dynamic database for hazardous chemicals in China has also been established.

Review of the hazardous chemicals registration work in 2011

Upon review of 2011, the NRCC has achieved the following:

  • Accomplished the first-time registration of hazardous chemicals;

    The current situation is a transition - the revised “Measures for the Administration of Hazardous Chemicals Registration” will soon be released and the 2002 “Measures”are still in effect.

    • Information on 8000 registering companies was validated

    • Information of 40,000 chemicals were registered

    • Registration certificates were issued to validated enterprises

  • Provided technical and information support for hazardous chemicals safety supervision, accident response and rescue;

    The NRCC has developed the “hazardous chemicals data application system based on GIS” through the use of an electronic geographical information platform based on GoogleEarth. Information such as hazardous chemicals registration data, emergency resources and accident cases will be incorporated into the GIS. The system will allow you to browse, search and statistically analyze the relevant information on hazardous chemicals and enterprises involved in manufacturing, usage, storage, etc. in a simple and rapid manner.The GIS also allows searching and display of the environment surrounding accidents.

    This could be a potentially powerful approach, which strategically facilitates data collection through registration and achieves the ultimate goal of data sharing. Intrinsically, this approach would provide a valuable information platform, which also indicates the substantial efforts to upgrade the hazardous chemical management system.

    Recently, registration offices in Beijing, Liaoning, Jiangsu, Shanghai and Xinjiang provinces/cities has developed data systems to provide technical information on the safe supervision of hazardous chemicals in their corresponding districts.

    Apart from software development, the NRCC also provides information on enterprises and chemicals as the knowledge base for the revision of chemicals safety supervision policies, accident prevention, and response/rescue measures.

  • Revised the “Measures for the Administration of Hazardous Chemicals Registration”.

    Based on a study referring to hazardous chemicals regulations in other countries, in particular the US regulations and the “Registration, Evaluation, Authorization and Restriction of Chemicals” (REACH) in the EU, the “Measures for the Administration of Registration Hazardous Chemicals Registration” in China is being revised to take into account China’s practical situation.

The advanced chemical management system will benefit the establishment of a sophisticated hazardous chemicals supervision system in China.

A brief analysis of China's hazardous chemicals enterprises conducted by the NRCC

From this analysis, the characteristics of hazardous chemicals enterprises were found to include location in populated areas, production of high tonnage volumes and small size.

These characteristics could possibly lead to high risks to human health and the environment as location in populated areas and high production tonnage could indicate severe damage if accidents occurred, while small enterprises tends to lack appropriate rescue procedures to deal with in serious accidents.

This analysis once again validates the focus on hazardous chemical management in recent years by the NRCC, State Administration of Work Safety (SAWS) and other relevant authorities in China.

Potential Issues with Hazardous Chemicals Registration

  • Delay in certificate renewal process

    This is due to the lack of necessary measures to restrain manufacturing if certificate renewal fails.

  • Registration data not fulfilling the requirement of safety supervision

    Currently, the registration data is compromised with problems such as being incomplete, inaccurate, not compliant with standards, inappropriate emergency telephone number (about 5,000 emergency telephone number were checked in 2011, most of which did not fulfill relevant requirements), etc. This lack of data quality may affect the level of safety supervision.

    The fact that the majority of registration data does not fulfill the relevant requirements is due to the lack of professional staff with expertise and insufficient understanding of China GHS. Quality inspection of SDSs will be stringently enforced by the NRCC to improve the implementation of China GHS in the future. 

NRCC Prospective Plans for 2012

Considering the issues mentioned above, the NRCC has outlined corresponding measures. 

  • Start preparations for the registration of hazardous chemicals, especially imported hazardous chemicals this year.

    Please note that foreign companies should be especially concerned with hazardous chemicals registration.

  • Conduct a thorough analysis on the registration data to make full use of the data collected

    In order to make full use of the registration data, the following two systems are expected to be further improved in 2012.

    • “Hazardous chemicals data application system based on GIS”;

    • “Statistical analysis system on hazardous chemicals registration information (Official version)”.

  • Reinforce validation checks of registration information

    Focus on the issues such as inaccurate registration data, non-compliance with standards.

    Please note that companies should pay close attention to information submitted, in particular the company’s location (longitude/altitude), fixed capital, sales profit, production volume and capacity, chemicals named according to standards.

  • Become actively involved in the registration certificate renewal for enterprises with expiring certificates and issuing certificates for newly registered enterprises

    In 2012, registering enterprises need to compile/update an SDS and label according to “Safety Data Sheet for chemical products- Content and Order Sections” (GB/T 16483-2008) and “General rules for preparation of precautionary label for chemicals” (GB 15258-2009), and submit registration to be qualified for certificate renewal and issue.

Please note that updating your SDS and label in line with the two national standards (GB/T 16483-2008 and GB 15258-2009) and timely renewal of the certificate is important.

  • Coordinate with SAWS to conduct a specialized inspection and survey on the registration of hazardous chemicals.

    The specialized inspection will focus on some key issues, such as insufficient/inaccurate data, SDS/label not compliant with updated national standards, untimely certificate renewing, etc.

According to the prospective plans proposed by the NRCC, 2012 will be a year with a heavy workload of hazardous chemicals registration work. Meanwhile, 2012 is also a pivotal transitional period, considering that the revised “Measures on Registration of Hazardous Chemicals” is about to be released and much revision work is expected.

A large portion of the NRCC’s work in 2012 will be dedicated to ensuring complete, accurate, and updated registration information is being collected, since registration data serves as the basis for the management of hazard chemicals. Some initial steps have already been made to build the database platform to strategically manage the information. Still, further improvements in the data collection procedure and software developments are both urgently needed to contribute towards a safer and cleaner environment in China.

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