REACH24H Chemical Regulatory Annual Conference 2015 Draws to a Successful Close in Hangzhou

On November 3, the two-day Chemical Regulatory Annual Conference (CRAC) 2015 jointly organized by REACH24H Consulting Group, China Chamber of Commerce of Foodstuffs and Native Produce, China Petroleum and Chemical Industry Federation draws to a successful close at XIXI Hotel in Hangzhou, China. The two-day conference provides a feast for compliance discussions, inviting various prestigious officials and business representatives from China, Europe, South Korea, Japan and Taiwan to deliver keynote speeches and share insights on coping strategies and future trends of respective chemical regulations in major economies. CRAC2015 is honored to have had the participation of media friends from Bloomberg, China Chemical Industry News and ChemLinked, government officials from the U.S. Consulate in Shanghai, China’s Ministry of Environmental Protection and the European Chemicals Agency etc. as well as our longtime friends from companies including Schlumberger, AkzoNobel, Cytec and Lubrizol, to name just a few, reaching an unprecedented high of over 180 attendees. Here below is a brief introduction to what’s been most heatedly discussed at CRAC2015.

Analysis of the Status Quo and Future Developments of Chemical Regulations in China

The year of 2015 is by no means an ordinary year for China’s chemical and environmental management. The catastrophic Tianjin Blasts of August 12 ignited an increasing call among the public for risk management of hazardous chemicals. Competent authorities have stepped up efforts for intensified regulation, putting into effect the Inventory of Hazardous Chemicals (2015) on May 1st and its corresponding Implementation Guidance on August 19 as well as releasing the revised China New Chemical Substance Notification Guidance and the Measures for the Environmental Management Registration of Hazardous Chemicals on June 25 and October 19 respectively for public consultation.

During the conference, Ms. Jinye Sun and Ms. Mengsha Zhang from the Division of Chemical Management of MEP-SCC, Deputy Director Kaijian Niu of Division III of State Administration of Work Safety (SAWS), Mr. Zongtao Wu from Ningbo Entry-Exit Inspection and Quarantine Bureau, Mr. Jun Chen from NRCC of SWAS, Mr. Bin Zhu from Shanghai Chemicals Registration Office, Mr. Zhengcai Chen from China Petroleum and Chemical Industry Federation and Mr. Huanyong Du from China Academy of Safety Science and Technology gave quite informative talks on the revision of China New Chemical Substance Notification Guidance and the MEP Order 22, industrial practice of the new Inventory of Hazardous Chemicals, regulation on the import and export of hazardous chemicals, hazardous chemicals registration, dangerous goods with small packages and OSH etc., addressing concerns and confusions raised by the attendees.

Kaijian Niu,Division III of State Administration of SAWS

Zongtao Wu,Ningbo Entry-Exit Inspection and Quarantine Bureau

Jun Chen,National Registration Center for Chemicals of SAWS

Jinye Sun, Division of Chemical Management of MEP-SCC

Particularly, in terms of hazardous chemicals management:

• Deputy Director Kaijian Niu from Division III of State Administration of Work Safety (SAWS) pointed out that the latest Inventory of Hazardous Chemicals is quite different from its previous version. The inventory is an important basis for the safety management of hazardous chemicals in China and its Implementation Guidance serves as a significant implementation reference to help enterprises seek for compliance on the one hand and assist competent authorities to step up supervision on the other hand.

• Mr. Zongtao Wu from Ningbo Entry-Exit Inspection and Quarantine Bureau reminded all relevant importing and exporting companies that hazardous chemicals listed in the Inventory and those not listed in the Inventory with hazards meeting the setting principles of the Inventory are subject to entry-exit inspection.

• Mr. Jun Chen from NRCC of SAWS said that the List of Chemicals Free from the Identification and Classification of Physical Hazards was expected to be released soon. Physical hazards identification organizations are conducting onsite checks and the list will probably be available before January 1st, 2016.

In terms of the environmental management registration of hazardous chemicals,

Ms. Jinye Sun, Director of the Division of Chemical Management of MEP-SCC made an in-depth analysis of some significant changes in the revision of MEP Order 22, including the simplification of registration forms and other material requirements and the replacement of registration certificates with public announcement etc.

Interpretation of Priority Chemical Regulations in Major Areas of the World

In order to help companies better navigate regulatory mazes in major areas of the world to tide over technical trade barriers, CRAC2015 managed to invite many prestigious experts and official representatives from the European Chemicals Agency (ECHA), the United Nation Institute for Training and Research (UNITAR), Japan Chemical Database (JCDB), Korea National Cleaner Production Center (KNCPC), the National Chemical Emergency Centre (NCEC) of U.K., Former U.K. Department for Transport, and Taiwan Environmental Sustainable Development Foundation to elaborate on the latest regulatory development in different countries and regions.

Kevin Pollard from ECHA

Park Peaksoo from KNCPC

Richard Davey from NCEC

Sano Hiroshi from JCDB

Zhaojia Hong, Taiwan Environmental Sustainable Development Foundation

Audience

• Mr. Kevin Pollard from ECHA proposed several valuable compliance strategies for the upcoming 2018 registration deadline, elaborating on ways for preparation of the registration dossier and what to expect of the ECHA compliance check.

• Mr. Park Peaksoo from KNCPC shared his in-depth interpretation of K-REACH with the attendees. He mentioned that consortia for the 510 substances subject to registration under K-REACH are being formed up. The competent authority of South Korea makes it compulsory for companies to join specific SIEF and set up Registration Forum from October 26 to November 30, 2015, after which period companies may be in a passive position if not included in.

• Mr. Richard Davey from NCEC pointed out that China is the most stringent in the world at present in terms of emergency telephone numbers, requiring that a local emergency contact number must be provided and helpline must be manned at all times etc. Chinese authorities sometimes conduct active testing and enforcement.

• Mr. Sano Hiroshi from JCDB and Professor Zhaojia Hong from Taiwan Environmental Sustainable Development Foundation also communicated with the audience their insights on chemical regulation in Japan and Taiwan.

Experience-Based Insights from a Senior EHS Practitioner

To help chemical enterprises well perform their due regulatory obligations and avoid potential risks, CRAC2015 also invited a senior EHS practitioner to share his profound insights on compliance strategies summed up from their practical experiences with peer companies in the industry. Mr. Xiaoyang Ding from Solenis (Shanghai) Chemical Co., Ltd gave a vivid presentation on legal liabilities in packaging, transport and storage of dangerous goods.

Xiaoyang Ding from Solenis (Shanghai) Chemical Co., Ltd

Q&A Session

Mr. Ding discussed possible legal liability issues in the transport, storage and packaging of dangerous goods, the definition of “Legal Liability” and its applicable scope, distinction of statutory obligation from legal liability and analyzed the legal effect and future development of “standards”, gaining warm applauses from the audience with his exceptionally informative and instructive presentation.

Some of the Speakers

CRAC2015 successfully served as a unique channel for technical experts from laboratory, officials from chemical registration center and EHS managers from the world’s leading chemical companies to discuss bumpy circumstances concerning substances needing further scrutiny and to share plans of solution to guarantee efficient and cost-effective compliance.