Management of Highly Toxic Chemicals in China

Little Pro on 2015-12-29

Highly toxic chemicals are defined as chemicals with high acute toxicity (usually GHS Acute Toxicity Category 1). Those chemicals can be lethal even in very small quantities. If illegally used as poisons, they could pose a big threat to public security. Examples of such chemicals include sodium cyanide.

In China, highly toxic chemicals are mainly regulated by the following administrative regulations:

The above regulations establish a much tighter regulatory regime for highly toxic chemical than regular hazardous chemicals in China and set additional requirements on the storage, purchase and sales of highly toxic chemicals.

List of Highly Toxic Chemicals in China

The Ministry of Public Security (MPS), the principle police authority in China, used to maintain a separate List of Highly Toxic Chemicals. This list has recently been incorporated into the Catalogue of Hazardous Chemicals (2015). Highly toxic chemicals are now marked as “剧毒” in the note column of the Catalogue.

There are currently 148 highly toxic chemicals in the Catalogue of Hazardous Chemicals (2015). You can search the Catalogue by Chinese name or CAS number.

Regulatory Requirements for Highly Toxic Chemicals in China

Since highly toxic chemicals are also hazardous chemicals included in the Catalogue of Hazardous Chemicals, they are subject to production/operation/safe use license requirements and HazChem registration requirements under Decree 591. In addition to that, they are subject to additional security and reporting requirements on storage, sales and purchase. Here we will only summarize the extra requirements for highly toxic chemicals:

  • Dedicated warehouse, anti-theft system, full-time security guard;
  • Double staff for receiving/delivering chemicals and double staff for safekeeping;
  • Shall declare chemicals stored, quantities and management personnel info to both local work safety authority and local public security bureau;
  • Shall report any loss or theft case immediately;
  • Shall check if buyers possess valid purchase permits before sales;
  • Shall maintain a good sales record including chemicals sold, quantities, uses, buyers’ names, and photo copies of purchase permits and photo identity cards of the handlers; and keep such records for at least 1 year;
  • Shall not sell highly toxic chemicals to private individuals (except pesticides);
  • Shall provide HazChem production/operation/safe use license or purchase permits issued by local public security bureau before purchase;
  • Shall declare highly toxic chemicals bought, quantities and flow info to local public security bureau (at county level) within 5 days since the purchase;

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 Tags: Topics - ChinaControlled Chemicals Trade