Registration of Hazardous Chemicals and Interpretation of SDS Difficulties-Questions and Answers Collection of Xinanrun Network Seminar

Release time:

2019-12-23 11:19

On December 17, 2019, Xin Anrun (the consultation invited senior hazardous chemicals expert Han Pinxin teacher to explain the regulatory framework of hazardous chemicals and the key points of SDS label compilation. The seminar was full of dry goods, including the general situation of regulations and policies, compliance points and the sorting out of new policies. The key points and difficulties of SDS and label compilation were also explained one by one. I believe everyone has gained a lot. This small compilation has now sorted out the on-site questions for your reference, and a series of tweets on this topic will be launched one after another. Our company will continue to hold similar seminars in the future. Remember to pay attention to the public number "Frontier of Chemical Regulations" to obtain information in the first place. You can also send the keyword "Join Group" to join the hazardous chemicals and SDS exchange group.

1. Where is the source of Chinese SDS standard required for import inspection?

In the "Announcement on Issues Concerning the Inspection and Supervision of Imported and Exported Hazardous Chemicals and Their Packaging" (AQSIQ Announcement No. 30), it is clearly mentioned that Chinese safety publicity labels and Chinese safety data sheets (SDS) are required.

2. Hazardous chemicals are classified as hazardous chemicals according to the determination principle and belong to category 9. In this case, the purchase of dangerous goods from domestic suppliers does not need to be added to the registration certificate of dangerous chemicals, right?

First of all, the concept is confused, nine categories are the classification of dangerous goods, the classification of dangerous chemicals is 28 major items, 81 small items. If you are importing, you need to register, production also needs to be registered, and domestic procurement does not need to be registered.

Domestic procurement of products belong to the ninth category of dangerous goods, need to confirm the qualification of domestic suppliers, domestic suppliers are purchased from domestic factories, he bought and sold this product will also do dangerous goods registration, then how to determine the second dangerous chemicals is registered?

This is actually a traceability problem. Your supplier is equivalent to a middleman. When purchasing in China, he should ask his upstream for relevant qualification certificates, but it may involve the issue of trade secrets. He may not be willing to share the information of this qualification certificate, so that the supplier can provide qualification certificates that hide some information, which can also reduce his own risks.

4. How to confirm the qualification of hazardous chemicals

The shipper must provide whether the goods are dangerous goods. The determination of dangerous goods is mentioned in the domestic road transportation safety management measures. There are two methods. The first is to find a third party to do transportation identification to identify whether the goods are dangerous goods and which category it belongs. The second is to make a statement, stating what kind of goods the goods are, their transportation number, danger category and packaging category. However, the current regulatory standard is still uncertain. If it is strict, a third party is required to make an identification. If it is not strict or the carrier is allowed to supervise, it is OK to make a statement. Foreign enterprises usually do it themselves or find a consulting company to make a classification.

5. Do you need the qualification of hazardous chemicals from suppliers?

In terms of rights, you can find the supplier to confirm whether there is a license and whether it has been registered, otherwise you can refuse to purchase the supplier's goods.

6. The substance is a mixture, and the composition of the mixture has a precursor and hazardous chemicals with a content of less than 10%, and a substance that is susceptible to explosive and hazardous chemicals. Then this substance as a whole belongs to precursor and hazardous chemicals, is it susceptible to explosive?

For explosive-prone hazardous chemicals, the regulations stipulate that the content of explosive-prone hazardous chemicals in the mixture above industrial grade is explosive-prone hazardous chemicals. For example, if the content of hydrochloric acid is above 36%, it is explosive-prone hazardous chemicals. However, the supervision of this area is not very clear. In the later period, some departments should give specific requirements and explanations on the content. Currently, it is basically explosive-prone hazardous chemicals that contain explosive-prone hazardous chemicals.

There are no clear provisions in the laws and regulations on dangerous chemicals, but the products contain dangerous chemicals, which are generally considered to be dangerous chemicals. For example, the content of 10% is not large, but the total amount is very high. A large number of dangerous chemicals can be purified, and the risk still exists. Therefore, mixtures containing hazardous chemicals are generally considered to be hazardous chemicals.

7. Diethanolamine belongs to eight categories of hazardous chemicals, which are only alkaline. After testing by a third party, the production factory has issued a certificate that non-hazardous chemical vehicles can be used for transportation. Can this be transported by non-hazardous chemical vehicles?

This is still a concept confusion. This belongs to the eighth category of dangerous goods. The eighth category of dangerous goods is corrosive. From the perspective of laws and regulations, it needs to be transported by qualified vehicles. If the traffic 617 and the road transportation management measures for dangerous goods are formally implemented in the later period, if the exemption conditions can be met, it can be transported by ordinary vehicles, but the packaging should be marked with relevant marks, and the liquid should also be marked with direction.

8. Hello, if the product contains 30% ethanol, which is a flammable liquid, but it is not displayed on sds because it does not exceed the limit of environmental and health hazards, but it is displayed on the label because it contributes to classification. Is this sds inconsistent with the label composition information and conforms to the regulations?

If it does not conform to the regulations, SDS and the label should be consistent. Although it is written in the regulations that some components may not be displayed in some cases, they cannot be displayed in SDS but in the label. This will cause problems during supervision. Therefore, such components are either displayed or not displayed to maintain uniformity.

9. Do you need to write all the composition information of msds components.

The provisions of the laws and regulations do not need to be fully written. If there is no harm, it may not be publicized. If there is harm but it does not reach the critical value, it may not be listed. In addition, does the list of harmful ingredients have to be written in full? From the perspective of China's compliance, it is possible to protect some trade secrets, for example, ethanol can be written as alcohols. However, in the actual supervision process, sometimes the company is not professional enough when doing some technical exchanges with the government, which leads to the government's lack of trust in the company. Government supervisors will worry that the company will falsely report and conceal, so they require 100% of the ingredients. Then the government will judge whether this SDS is correct and standard.

10. How hazardous chemicals are stored, controlled and classified.

The storage of this piece is controversial at present. If we look at the current Decree No. 591 of the Supreme Law on Hazardous Chemicals, which stipulates that hazardous chemicals must be placed in special warehouses, many places will now allow all products in the catalogue and meeting the 70% principle to be placed in hazardous chemicals storage warehouses. The existing laws and regulations are mainly based on 15603,17914,17915 and 17916. These regulations have been issued for a long time and are mainly aimed at inflammable, explosive, toxic (transdermal, imported, inhaled) and corrosive. By comparison, it will be found that the storage methods of hazardous chemicals such as carcinogenicity and reproductive toxicity are not clearly pointed out in the regulations, but the 15603 mentioned above may be updated in 2020, which may clarify this field and further improve the regulations. At present, supervision in many places is subjective. As long as it is not flammable and explosive, it will be placed in Class C if it fails to meet the standards of Party A, Party B and Party C. This is a current situation, which leads to the high cost of storage of hazardous chemicals in China and the lack of resources.

The principle of 11.70 per cent, can you expand it and introduce it.

The 70% principle is in the guidelines for the use of the catalogue of hazardous chemicals, which was first issued in 2015, and then the safety supervision department also issued the guidelines for use. this is mainly aimed at administrative license. if the substance is not in the catalogue or does not conform to the 70% principle, then there is no need to do production license, business license, can be directly produced and operated, but once in the catalogue, registration is required.

12. Does the explosive-prone management method exempt the storage and transportation of dangerous chemicals such as food additives, disinfectants and veterinary drugs from other regulations on the storage and transportation of dangerous chemicals?

No, the so-called exemption is not exempted in actual work, especially cosmetics. Cosmetics are not in the GHS category according to laws and regulations, but cosmetics are also composed of chemicals. Therefore, in many cases, the boundaries between cosmetics, food and chemicals are relatively vague. The current situation is that as long as the fields involving chemicals or hazardous chemicals are under supervision in China.

Has there been a reduction in the registration requirements for R & D samples in Order 13.60, Regulation and Enforcement?

At present, there is no specific amount requirement for registration in China. It does not mean that registration is not required if the amount is less than a certain amount. In principle, registration is required. Some scientific research institutions only produce a few milliliters and milligrams and have not registered. It may be that the supervision is not too strict, but from the perspective of regulatory compliance, registration is required.

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