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Content♫Law and regulation system ofchemical management♫Institutions Implementing GHS inChina♫Management on the Import andExport of Chemicals♫Problems and Challenges♫Recommendations

,law and regulation system ofchemical managementØChina’s law and regulation system
include four levels---ðthe first level is the laws approved andpromulgated by the People’s Congress˗ðthe second level is the administrative laws
promulgated by State Council˗
ðthe third level is the regulations issued by eachMinistry˗ðthe fourth level is the national standards˗

Laws concerning Chemicals
u Law of the People's Republic of China on Work Safety,promulgated in June 2002, taking effect in November 1,2002
u Law of the People's Republic of China on Prevention
and Control of Occupational Diseases, promulgated inJanuary 2001, taking effect in May 1, 2002

Administrative Regulations
Regulations of the People's Republic of China on Monitored andControlled Chemicals, promulgated by the State Council in 1995
u Regulations of the People's Republic of China on the Control of
Agricultural Chemicals, Promulgated by the State Council in 1997,Amended in 2001
u Regulations on the Control over Safety of Dangerous Chemicals,Promulgated by the State Council in Jan 2002, taking effect in March
15, 2002, Manufacturers are requested to make MSDS andlabeling for chemicals in certain Lists
u Regulation on Work Safety Licenses, Promulgated by the StateCouncil in Jan. 2004
u Regulations on Labor Protection in Workplaces Where Toxic
Substances Are Used, Promulgated by the State Council in April 2002
u Regulations for Administration of Precursors and Chemicals used in
Production of Narcotic Drugs and Psychotropic Substances,Promulgated by the State Council in May 2005uMinisterial regulations
Measures for The Administration of Operating Licenses for Hazardous
Chemicals, issued by the former State Economy and Trade Commission(SETC) in 2002
u Measures for The Administration of Registration of Hazardous Chemicals,issued by SETC in 2002
u Measures for The Administration of Packaging and Container Fixed-point
Production, issued by SETC in 2002
u Regulation of Environmental Management on the First Import of Chemicals
and the Import and Export of Toxic Chemicals, jointly issued by the former
SEPA, SETC and General Administration of Customs (GAC) of in 1994
u Measures for Environmental Management of New Chemical Substances,issued by SEPA in 2003
u Management measure for pesticide label and instruction, issued by Ministry ofAgriculture (MoA) in November 2007, to specifically provide the label andintroduction of pesticide, including the content, logo, production, usage andmanagement requirement which need to be noted in the label and introduction.
uNational StandardsuChemical ClassificationlllllllClassification and code of dangerous goods (GB6944-2005)
List of dangerous goods (GB12268-2005)
Classification and labels of dangerous chemical substances commonlyused (GB13690-1992)
Levels, Classification and Code of Hypertoxic Substance (GA57-93)
Classification of health hazard levels from occupational exposure totoxic substances (GB5044-85)
Safety rules for classification, precautionary labeling and precautionary
statements of chemicals-Flammable aerosols (26 items) (note: the 26
items are totally transferred from GHSˈno Aspiration Hazards
currently)
The guidelines for the hazard evaluation of new chemical substances
˄HJ/T 154-2004˅

Difference between UN GHS and China’s GB
HEALTHY
HAZARDSUN GHS(Second revised edition, 2007)

National Standards of China(GB…-2006)

Acute toxicity(Gases)Category 1
Category 2
Category 3
Category 4: (ATE values is 20 mL/L)
Category 5

Category 1
Category 2
Category 3
Category 4: (ATE values is 5mL/L)
Category 5

Reproductive
toxicity

Classification criteria for mixtures˖
Category 1
Category 2
Additional category for effects on orvia lactation

Classification criteria for mixtures˖
Category 1
Category 2—

Specific target
organ toxicity—
single exposure

Category 1
Category 2Category 3

Category 1
Category 2—

Aspiration hazard

Category 1
Category 2——National Standards
u Chemical Label and SDSl Safety data sheet for chemical products-Content and Order of sections(GB/T 16483-2008)
ü Revised according to GHS requirement of safety data sheet for chemicalproducts, instead of GB/T17519.1-1998ǃGB16483-2000
ü Stipulates the construct, content and general format of SDS
ü Appendix (SDS Preparation Guidelines) provides the requirements for thepreparation of the 16 items information, thereinto the information oftoxicology and ecology are revised according GHS requirement.
l Labeling of Chemicals Based on GHS (GB/T 22234-2008)
ü Adopts the contents of JIS Z 7251:2006 <Labeling of Chemicals Based onGHS>˄Japanese version˅
ü Stipulates chemical’s GHS hazards categories and their label elements(symbol, warning, hazard instruction, etc. )National Standards
u Chemical Label and SDS (cont.)l General rules for preparation of Chemical Safety Label(GB15258-1999)
ü Made particular provisions on the definition, contents, compiling

requirements, production and usage of chemical safety label. ( atpresent, the revision has already been done and sent to WTO, but notissued yet )l Labels for packages of dangerous goods (GB190-1990)
ü Stipulates the classification logo, size, color, methods of usage and soon of the package label of dangerous goods. ( at present, the revision
has already been done and sent to WTO, but not issued yet )National Standards
u Chemical Testingl Chemical hazardous properties test methods (a series of 16standards): According to UN’s Recommendations on the Transport ofDangerous Goods: Manual of Tests and Criteria, China developed a series ofstandards of hazardous properties test method for dangerous goods, andimplemented them in 2004.

1.
2.
3.
4.
5.
6.

Safety code for inspection of hazardous properties for dangerous goods—
General specifications, GB 19458-04
Safety code for inspection of hazardous properties for dangerous goods ofoxidizing substances, GB 19452-04
Safety code for inspection of hazardous properties for dangerous of civilexplosives, GB 19455-04
Safety code for inspection of hazardous properties of dangerous goods fornitrates, GB 19456-04
Safety code for inspection of hazardous properties for dangerous goods offlammable solides, GB 19521.1-04
Safety code for inspection of hazardous properties for dangerous goods offlammable liquid, GB 19521.2-04

7. Safety code for inspection of hazardous properties for dangerous goods offlammable gas, GB 19521.3-04
8. Safety code for inspection of hazardous properties for dangerous good of
substances which in contact with water emit flammable gases, GB 19521.4-04
9. Safety code for inspection of hazardous properties for dangerous goods ofpyrophoric solid, GB 19521.5-04
10. Safety code for inspection of hazardous properties for dangerous goods ofcorrosive substances, GB 19521.6-04
11. Safety code for inspection of hazardous properties for dangerous goods oftoxic substances, GB 19521.7-04
12. Safety code for inspection of hazardous properties for dangerous goods of
toxic gases, GB 19521.8-04
13. Safety code for inspection of hazardous properties for dangerous goods of gas
mixture, GB 19521.9-04
14. Safety code for inspection of hazardous properties for dangerous goods ofcompressed gases, GB 19521.10-04
15. Safety code for inspection of small gas receptacles for dangerous goods, GB19521.13-04
16. Safety code for the inspection of medium and minitype receptacles fordangerous goods, GB 19521.14-04

National Standards
u Chemical Testing (cont.)l Physical and chemical, health-toxicity and eco-toxicological test

methods of chemicals (a series of 123 standards)

ü To correspond to REACH, China launched national standard-setting work on the new test methods for hazardous chemicals. Theseries of standards are totally 123 items, among which 65 items arestandards of physical and chemical test methods, and the others arestandards of toxicity and eco-toxicological test methods.

l The Guidelines for the Testing of Chemicals˄HJ/T153-2004˅

and Methods for the Testing of Chemicals

ü To regulate chemical testing, the former SEPA released industry

standards stipulating the testing requirements of chemical
properties of physical and chemical, bio-system effect, degradation
and accumulation, health effects

National Standardsu Others
llllllThe principle of classification of transport Packaging
groups of dangerous goods (GB/T 15098-94)
Rule for the Storage of Common Dangerous Chemicals(GB15603-1995)
Symbols for the Transport of Dangerous Goods (GB1912000)
Material Safety Data Sheet (GB/T 17519.1-1998): Part 1
content and order of sections (instead by GB/T16483-2008)
Material Safety Data Sheet (GB/T 17519.2-2003): Part 2
detailed rules for preparation
General rule for classification and hazard communication ofchemicals (already sent to WTO according to TBTAgreement and waited for reply)II. Institutions Implementing GHS
in ChinauJoint promoting by ministries and committeesl Lead Department: National Development and Reform

Commission (NDRC)l Participating departments: MEP, Ministry of Health (MoH),
Ministry of Commerce (MoC), Ministry of Public Security(MPS), Ministry of Transport (MoT), General Administrationof Quality Supervision, Inspection and Quarantine (AQSIQ),
the State Administration of Work Safety (SAWS), etc.

Responsibilities/Activitiesof Ministries
u National Development and Reform
Commission (NDRC)l From a policy point of view, study and establish

directory of chemicals whose production should be
supported and restricted or prohibited, and makerelated policy measuresl Give support to the approval of the major projects ofthe relevant department

Responsibilities/Activities
of Ministriesu Ministry of Environmental Protection (MEP)l Be responsible for the formulation and amendment of China's environmental protection laws
and standards related to chemicalsl Organize the compilation of chemical eco-toxicological test methods for testing chemicals,by reference to GHS requirements of aquatic environment damage and related OECDtechnology guidelines
l Take charge and organize the classification and implementation of GHS part ofenvironmental damagel Participate in the research on reacting strategies and relevant science, provide data aboutchemical impact on environmental; set up the laboratories and improve the conditionsl Develope the eco-toxicological testing and environmental hazards assessment of newchemicals, constructed the eco-toxicological testing institutions and qualified laboratories(GLP)l Be currently studying on and carrying out the classification of the basis and hazard of
notified new chemical substances according to GHS requirements.

Responsibilities/Activitiesof Ministries
uMinistry of Commercel Investigate and analyze the status in quo of chemicals tradel Research and make policies to facilitate the application and registration ofexport enterprisesl Carry out a number of international cooperation or negotiation from theperspective of foreign tradeu Ministry of Healthl Participate in policy study and provide toxicological test dataResponsibilities/Activitiesof Ministries
u General Administration of Quality Supervision, Inspection and Quarantine(AQSIQ)l AQSIQ has started to establish Key Laboratories in inspection and quarantine agencies inTianjin, Shanghai, Guangdong, etc. to implement GHS and react REACH, set up therelevant databases, web sites and chemical database, information platform, andcompleted the 16 items public information required by the safety data sheets (SDS) ofimport and export chemicalu Standardization Administration Committee (SAC) of PRCl Evaluate the status in quo of chemical standards and test methods of Chinal Preside the amendment of national standards of chemicals

u Other departmentsl MPS, MoT and other departments in China are actively carrying out the work

corresponding to GHS within their functions

III. Management on the Importand Export of Chemicals
u AQSIQ is responsible for the inspection and quarantine against

import/export of dangerous goods, according to the Law on
Import and Export Commodity Inspection and Regulations on theControl over Safety of Dangerous Chemicals.
u In 1985, 1995, 2000 and 2003 respectively, China promulgatedshipping, air, rail and road transport of dangerous goods on
packaging test management approach.
u Based on Law of Commodity Inspection and IMDG Code,Inspection and quarantine agencies drafted nearly 100 standards
for the classification level test and packaging inspection ofdangerous goods during various modes of transport, which are
effective technical supports of China’s dangerous goods
management and in the basic standards of international
dangerous goods technical regulations.

IV. Problems and Challengesu Multi-departments involved, not yet formed inter-ministerial coordination mechanismu Lack of uniform plan for GHS implementationu Distempered system of chemical management laws
u Technically difficult for China to ensure the timeliness ofGHS, due to quick update of GHS
u Lack of experts and experiences of GHS classificationu Authoritative data information of the substances is severely
in shortu Lack of domestic propaganda

V. Recommendations
u Establish and perfect chemical management law andregulation systemu Revise the existing national standards such as chemicalclassification, label according to GHS classification
requirements
u Enhance international cooperation and GHS
information communionu Strengthen personnel and technical training aboutchemical identification and classificationu Promote the propaganda of GHS, etc.

Thanks for your attention!
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