India’s national chemical management policy has been in the spotlight since the unveiling of the fifth draft of the Chemicals (Management and Safety) Rules (CMSR) in August 2020.So when Mr. Shisher Kumra, representing Global Product Compliance Group, one of the only two non-governmental organizations involved in reviewing the regulation gave his speech at the CRAC-HCF 2021 Virtual Forum held by REACH24H on November 11, 2021, a lot of attention was drawn.

Mr. Shisher Kumra in his speech firstly introduced the fifth draft of CMSR (Details can be accessed here). The authority has encountered many problems in developing and improving CMSR as it is a huge deviation from current practices. Although CMSR will bring in new obligations, e.g. chemical notification, registration and annual reporting, the requirements on safety and accident preparedness as stipulated in Chapter IV remains unchanged compared with the Manufacture, Storage and Import of Hazardous Chemical Rules, 1989 and the Chemical Accidents (Emergency Planning, Preparedness, and Response) Rules,1996.

Due to Covid-19 the legislation indeed slowed down a bit in the middle of this year but according to Mr. Shisher Kumra things are catching up and several discussions are going on internally to speed up legislation. The next step is to notify WTO of the draft proposal for a period of public consultation lasting 60 days, which is expected later this year at the earliest.

Mr. Shisher Kumra reminded stakeholders to actively notify all substances in quantities above 1 tonne per year during the initial notification period since it will create a national existing chemical substances inventory. Otherwise, their substances will be regarded as new substances. The information required for notification, including notifier info, substance’s identity, chemical structural details and spectral data, uses, quantity, downstream users, and hazard classification, SDS, etc. Although India hasn’t adopted UN GHS yet, the hazards shall be classified according to UN GHS based on your best knowledge.