New chemical substances and hazardous chemicals under the safety line training successfully held

Release time:

2021-06-07 09:57

In order to further publicize the latest policy on the registration of new chemical substances and the safety management of the use and storage of hazardous chemicals, and to assist enterprises in the registration of new chemical substances and the management of hazardous chemicals, on the afternoon of June 3, 2021, Xinanrun (Beijing) Consulting Co., Ltd. and Shanghai Chemical Industry Association successfully held offline training on the environmental management registration system of new chemical substances and the safety management of the use and storage of hazardous chemicals in enterprises.

The training was first explained by Mr. Zheng, who has rich experience in the registration of new chemical substances. Mr. Zheng introduced the environmental management registration system of new chemical substances in detail from four aspects: international control of new chemical substances, management of new chemical substances in China, introduction of management requirements of the Measures and suggestions for enterprises.

In addition, Mr. Jin, who has rich experience in the safety management of the use and storage of dangerous goods, was invited to explain the "Safety Management of the Use and Storage of Hazardous Chemicals in Enterprises". Mr. Jin first explained the causes of accidents of dangerous chemicals in detail, then explained the relevant laws and regulations of dangerous goods and dangerous chemicals, and finally made a specific analysis of fire emergency and disposal.

We listed some enterprises concerned about the registration of new chemical substances and hazardous chemicals management and other related difficulties are as follows:

Q1: When can the relevant activities be carried out after the filing declaration in the registration of new chemical substances under Decree 12 is filed in the system? If the filing materials are inaccurate, will the competent department of ecological environment have a notice?

Answer: After the filing materials are applied in the system, the system will automatically generate a filing receipt, and the applicant can carry out relevant activities. In the follow-up, the competent department of ecological environment of the State Council will organize its subordinate technical institutions for environmental management of chemical substances to conduct random spot checks on the conformity of the filing materials.

(1) If it is found that the filing materials submitted by the applicant do not meet the requirements or are not sufficient to judge whether they meet the filing conditions, the applicant shall supplement and correct the relevant materials at one time according to the requirements of the notice of correction. After the applicant submits complete, accurate and in line with the requirements of the correction materials, the competent department of ecological environment under the State Council reorganizes the compliance review.

(2) if it is found that the material for filing does not meet the requirements for filing and should apply for a regular or simple registration certificate, the competent department of ecological environment under the State Council shall cancel the filing. The applicant shall bear the corresponding legal responsibilities stipulated in the Measures, and apply for a new chemical substance environmental management regular or a simple registration certificate in accordance with the provisions of the Measures.

Q2: Under Decree No. 12, how do you need to record the post-event record management after the registration certificate is obtained?

Answer: researchers, producers, importers and processing users of new chemical substances shall, in accordance with the provisions of Article 39 of the measures, establish a new recording system for the activities of new chemical substances, truthfully record the activity time, quantity, actual use, implementation of environmental risk control measures and environmental management requirements, and information transmission to downstream processing users. Encourage the use of information technology, digital means to establish a new chemical activity record system.

In addition, if the applicant designates an agent, the agent in China shall perform the obligation to keep the activity records and data of the new chemical substance.

Q3: Do I need to file a series of new chemical substances developed in the laboratory?

A: Production refers to the production of new chemical substances through individual or combined chemical reaction processes based on raw materials, ingredients, etc.

Therefore, the laboratory's research and development of new chemical substances belongs to production and is required to be filed in accordance with regulatory requirements. If the new chemical substance produced is a non-isolated intermediate, it is exempted from registration.

Q4: Import and export of hazardous chemicals, as enterprises need what qualifications?

Answer: Import: A hazardous chemical registration certificate is required. If there are substances in the catalog, a hazardous chemical business license is also required.

Export: if it is a factory, it needs to register hazardous chemicals, if there are substances in the catalogue, it also needs a hazardous chemicals production license; If it is a trading company, it needs a hazardous chemicals business license. In addition, if hazardous chemicals involve relevant regulatory lists, such as substances in the list of controlled chemicals, additional relevant administrative permits are required.

Q5: I am a purchaser. Do I need a hazardous chemicals license to purchase hazardous chemicals and sell them to customers?

Answer: According to relevant laws and regulations, the purchaser is obliged to review the relevant qualifications of the supplier. At the same time, as a distributor, when selling relevant chemicals downstream, it should also meet relevant licensing requirements (for example, chemicals in the sales catalog should obtain a business license before they can be sold).

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