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Analysis of Document No. 1366 of Huan Ban Han [2011]
Release time:
2019-09-06 14:40
In the restless expectation, document No. [2011]1366 arrived as scheduled, which was caught off guard and aroused heated discussion. But this is also expected. Since the last batch of list supplement results was obtained in January 2011, no one has been approved for the list supplement in the past ten months. This is also a hint that our No. 12 document may be about to complete her own mission. Finally, on November 28, 2011, the sword of Damocles fell.
This brings us not only shock, but also thinking. It has been 15 years since the first supplement in 1996. From the manager's point of view, the list supplement is the most risky among all the current declaration channels for new substances. Due to the lack of the most basic data, many potential risks cannot be understood. This may be the manager's determination to close this door. The original intention. This door has been open for so long, coupled with the hints after the Spring Festival, we should not be unaware of it. Therefore, there is the above restless expectations;. Although the door to supplement the list has been closed, I think this may not be a bad thing, and chemical management will develop in a more perfect direction in the future.
China's new chemical substances are widely known as the Chinese version of REACH;, but REACH's management of existing chemicals is missing from our current Environmental Management Measures for New Chemical Substances, and perhaps Huan Ban No. 12 can be regarded as the management of existing chemical substances in the Environmental Management Measures for New Chemical Substances. However, after the revision of the "New Chemical Substances Environmental Management Measures", Document No. 12 can no longer adapt to the new management requirements. Therefore, Document No. [2011]1366 came into being. However, document No. 1366 should not only be regarded by us as the closing of the door to supplement the list, taking a ride of order No. 591 of the State Council, and the "Environmental Management Registration of Hazardous Chemicals" previously issued by the Ministry of Environmental Protection. Therefore, I personally understand that document No. 1366 is the transition from the management of new chemical substances to the management of existing chemical substances in China, and is a signal for the management of domestic chemical plants.
After next year's chemical inspection, I think the Ministry of Environmental Protection will issue a series of documents. At that time, in the face of the current situation that many chemical plants in China need to declare, will the Ministry of Environmental Protection have a series of documents to be issued? Will the revised version of Document 12 appear, and will it be the simplified declaration deleted by Decree 7 of the Ministry of Environmental Protection? What will the revised version of document 12 look like in the future, and will QSAR, Read-across and literature data be accepted? Will the revised version of Document 12 be part of the Environmental Management Registration of Hazardous Chemicals? These are worth our expectation! No matter whether the current management brings much trouble to our current work, I firmly believe that China's chemical management will become more and more perfect!
The above is a discussion between myself and my friends. It is purely a personal point of view!
Author: Chen Jichao, Director of New Substance Registration Department of New Anrun (Beijing) Consulting Co., Ltd.
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