On the 11th October 2011, the State Administration for Work Safety (SAWS) in China released two draft new laws for public consultation concerning hazardous chemicals. These laws affect anyone exporting chemicals to China or manufacturing chemicals within China. Responses to the consultation close on 18th November with the new laws effective from 1st December 2011.
The first of these laws - the revised Measures for the Administration and Registration of Hazardous Chemicals requires domestic manufacturers and importers to register chemicals listed in the Catalogue of Hazardous Chemicals prior to their manufacture or importation into China for the first time with the National Registration Centre for Chemicals (NRCC). The amendments to the law, which have been drafted by NRCC, lay down additional requirements of an emergency response service provider, the appointment of which is a requirement for importers or manufacturers during the registration of chemical products in China. These additional requirements are that the emergency response service provider must have:
- A domestic “fixed-line” number dedicated to provide emergency response
- A fixed office space with 24-hour manning by professionals familiar with the hazardous properties of the company’s chemicals and emergency response techniques and being able to answer questions and provide advice on these topics
- Having a database of hazardous chemicals and emergency response information
We at the UK’s National Chemical Emergency Centre understand that the purpose of the revisions to law is to improve safety regarding chemical products and we fully endorse this aim. We agree that these features are necessary for the highest standards of emergency response and support SAWS and NRCC in stipulating these requirements.
We have engaged in dialogue with NRCC and have submitted a formal response to the consultation, acknowledging the purpose of the changes and submitting the view that NCEC’s Carechem 24 service fully meets the requirements of the new law as listed above, namely that:
- We provide a fixed line number that is based in China and which connects to our emergency response experts who are situated in an office which is occupied at all times.
- Our emergency response experts have both a high level of education and training in chemical hazards and emergency response.
- We maintain a large database containing a detailed description of the hazardous properties of the company’s chemicals and emergency response techniques.
Going forward, we will continue to support our Carechem 24 clients by offering an emergency response service of the highest standard possible.