Environmentally Hazardous Substances Notification and...
Transcript of Environmentally Hazardous Substances Notification and...
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2010/SOM1/CD/WKSP/011 Agenda Item: Afternoon Session I
Environmentally Hazardous Substances Notification and Registration Scheme
Submitted by: Malaysia
Case Study Workshop on the Chemicals Sector - From Principles to Practice
Hiroshima, Japan1-2 March 2010
www.doe.gov.my
Department of Environment, Malaysia
ENVIRONMENTALLY HAZARDOUS SUBSTANCES (EHS)
NOTIFICATION AND REGISTRATIONSCHEME
Dr.Ab. Rahman Awang ([email protected]) and Hanili Ghazali ([email protected])
EHS Notification and Registration Scheme
ROAD MAP FOR PRESENTATION
Background to proposed scheme Need for the Chemical Management The notification scheme - objectives and purpose, definition of
EHS, scope, substances to be notified, exemptions from notification and who to notify
The notification process – types of notification, data to be submitted, when and how to notify
Proposed implementation of the scheme Expected output and benefits of the scheme Conclusion
EHS Notification and Registration Scheme
Background to the Proposed Scheme
Many chemical substances and products are currently put into market in Malaysia
The influx of chemicals far surpassed the information that are collected
As a result, there is an uncertainty on types of chemicals used in a wide range of consumer products
Large percentage of existing chemicals have not been assessed
Government is concerned about human and environmental exposure from toxic substances and unregulated chemicals used in a wide range of chemical products
Long term persistence and accumulation of many chemicals in eco-system and humans
Continued use of chemicals with inherently dangerous properties such as carcinogens, mutagens and reproductive toxicants and substances dangerous for the environment
EHS Notification and Registration Scheme
Need for the Chemicals Management
Need for an overall strategy and coordination of activities in the area of chemicals management as well as an increased capacity and awareness of chemicals management issues among stakeholders
Need for information on the use of hazardous chemicals in Malaysia and for implementation of methodologies for assessment risks to human and the environment
Need for capacity in terms of staff and training for the management of chemicals in general and particularly with respect to the use of risk assessment as a chemicals management tool
To address these needs, an EHS Notification and Registration Scheme is proposed for implementation under the EHS Component of the Malaysian-Danish Environmental Cooperation Programme
EHS Notification and Registration Scheme
EHS Component Objectives
Development objective:
An effective and sustainable management system is established that will minimise and reduce the risks from Environmentally Hazardous Substances
Immediate objective:
A draft strategy and action plan for management of Environmentally Hazardous Substances is agreed among ministerial agencies involved in management of chemicals and their capacity forenvironmentally sound management of hazardous chemical substances has increased as a result of training and implementation of management systems and assessment schemes
EHS Notification and Registration Scheme
What is EHS? EHS are defined in Section 2 of the Environmental Quality Act, 1974
(Act 127) as:
Any natural or artificial substances including any raw material, whether in a solid, semi-solid or liquid form, or in the form of gas or vapour, or in a mixture of at least two of these substances or any living organism intended for any environmental protection, conservation and control activity, which can cause pollution
For the purposes of Notification and Registration under the EQA 1974, the following definition is used:
An EHS is a substance that is assigned a hazard category under the GHS classification scheme or is present on a proscribed list of internationally recognised substances of special concern
EHS Notification and Registration Scheme
The Malaysian EHS Reference List
The EHS Reference List adopted by the Department of Environment Malaysia is based on the proposal for a harmonised European list of classification and labelling of substances according to GHS. This list has been translated from the harmonised classification and labelling in the European Annex VI to the REGULATION (EC) No 1272/2008).
Annex VI contains at approximately 3427 individual substances. The reference list also includes a number of substances considered of global concern because of endpoints not covered by the GHS
classification system.
EHS Notification and Registration Scheme
About EHS Notification and Registration Scheme
Objective
The EHS Notification and Registration Scheme of the Department of Environment Malaysia (DOE) is a scheme to collect information from the chemical industry about environmentally hazardous substances in Malaysia.
Screenshot from N&R Website
EHS Notification and Registration Scheme
The Purpose of EHS Notification and Registration Scheme
To provide the necessary information to the Malaysian Governmentso as to enable the DOE and other agencies involved in chemicalsmanagement to identify substances of concern in the country and make decisions on how to manage these substances in a safe and sound manner
To establish a Malaysian EHS Register. The Malaysian EHS Register will contain information about the identity of substances that have been notified to DOE, their uses in Malaysia, their hazard classifications and the accumulated amounts present in Malaysia
EHS Notification and Registration Scheme
What is covered under the Scheme?
Covers all substances not covered by other notification/registration schemes in Malaysia and present on the EHS fulfilling the criteria for classification as hazardous according to GHS, or until GHS is fully implemented, the classification according to the current classification requirements for chemicals in Malaysia.
Other substances that are considered substances of concern due to
properties not covered by the GHS classification scheme
What is not covered under the Scheme? Substances for which information is already submitted to
government agencies in Malaysia by means of other legislations, unless the substance is also used for other purposes not covered by Pesticides, Poisons and Chemicals Weapons Convention Acts
EHS Notification and Registration Scheme
Substances Included in the EHS Notification
1 Petrochemicals including plastic and resins
2 Chemicals in fertilizers
3 Soaps and detergents
4 Organic chemicals
5 Oleo-chemicals
6 Industrial gases
7 Paints and paint products
8 Basic industrial chemicals
9 Rubber industry chemicals
EHS Notification and Registration Scheme
Substances Exempted from NotificationNo Substance Type
1 Naturally-occurring materials e.g. minerals, ores and ore concentrates as well as cement clinker
2 Incidental/end-use reaction products3 Substances formed during the manufacture of an article4 Mixtures (but not components of mixture )5 Impurities6 By-products7 Non-isolated intermediates ie chemical substances used to manufacture other
chemical substances that are never separated from the mixture of other chemicals inside a closed system
8 Contained site-limited intermediates9 Transported intermediates10 Substances manufactured solely for export11 Substances used in research and development12 Substances produced for test marketing
13 Substances produced in low volume (<0.1 tonnes per annum)
14 Imported finished consumer products, e.g. household products. However, it is likely that these may be covered at a later stage of the EHS Notification and Registration Scheme
EHS Notification and Registration Scheme
Who Shall Notify
Manufacturers and importers of EHS and importers of chemical mixtures or finished products that contain EHS as their constituents
The company is an importer of individual EHS and/or chemical mixtures or finished products containing EHS as constituents above certain cut-off limits.
Who Shall Not Notify
Chemical industries involved in the manufacture of chemical mixtures or products using locally manufactured EHS or imported EHS sourced from local suppliers as raw materials are NOT subject to notification and registration of EHS.
Chemical companies involved in formulation, distribution, retailing and use of EHS or EHS containing mixtures/products from locally sourced EHS are NOT subject to notification and registration of EHS
EHS Notification and Registration Scheme
The Notification Process
The Notification of EHS to DOE by chemical industries shall be done in two stages:
– Basic Notification: A basic notification of EHS must first be made by all manufacturers and importers
– Detailed Notification: A follow-up detailed notification is also required, if the EHS is not the EHS Reference List
The basic notification of EHS is to be carried out annually, at the beginning of the year (data of past one/two year). Detailednotification if required will only be carried out once, unless new information that change the hazard classification are available for notification
The notification and registration shall be done on-line through the DOE’s official website at www.doe.gov.my
Difference Between Basic and Detail Notification of HS
Basic Notification Detail Notification
Chemical manufacturer or importer are only required to furnish the following data:
Chemical manufacturer or importer are required to furnish the following data:
Substance identification (CAS No, EC No or Index No)Annual tonnage in metric tonsUse of the substanceConcentration interval of substance in raw materials or finished products (maximum and minimum concentration) Country of export (if imported)
Substance identification (CAS No, EC No or Index No)Annual tonnage in metric tonsUse of the substanceConcentration interval of substance in raw materials or finished products (maximum and minimum concentration Country of export (if imported)
Data on Substance Identification (e.g. structural formula, molecular weight, etc)Data on Physical Chemical Properties (e.g. melting point, auto-ignition temperature, etc)Data on Physical Hazards (e.g. flammability, corrosivity to metals, etc)Data on Hazards to Human Health (e.g. acute toxicity, skin corrosion/irritation, etc)Data on Hazards to Aquatic Environment (e.g. acute aquatic toxicity and properties like bio-accumulation, etc)Overall GHS Classification
EHS Notification and Registration Scheme
Implementation
The Notification and Registration of EHS by chemical industries in Malaysia will be implemented in phases. Initially the scheme will be introduced on a voluntary basis (2009).
When legislation is in place (expected date after 2010) to start phasing in the scheme, manufacturers and importers covered by the first phase will be required to notify their substances. The notification will be phased in based on tonnage and toxicity.
EHS Notification and Registration Scheme
Implementation
All substances that, under GHS classification, are assigned an aquatic toxicity classification of ‘chronic 1’ (*) or are ‘suspected or known human carcinogens, reproductive toxicants or mutagens’ (+) must also be notified during years 2011 and 2012
Annual Tonnages
(MT)
Year of Implementation of EHS Notification
2009 2010 2011 2012 2013 2014 2015 2016 2017
> 100Voluntary
Notification
* + * +
10 –100
* + * +
1 – 10 * + * +
0.1 - 1 * + * +
Prepare an Inventoryof all Substances
and Amounts
Are Substances EHS?
Retain Data for DOE Audit
Inventory of EHS and Amounts
Are Amounts > 0.1 Tpa?
Retain Data for DOE Audit
Inventory of Notifiable
EHS and Amounts
Check RequirementsFor Phase In
Is my Sector and Tonnage
Notifiable now?Retain Data And Notify at
Appropriate Time
No
No
No
Yes
Yes
Yes
How do I Notify?
Complete –forms to
Notify Each EHS
EHS Notification and Registration Scheme
Benefits of Scheme
It helps the industry in identifying likely data gaps which are required for GHS classification of substances and compliance with DOSH regulations.
There is sufficient information available on the EHS imported into or manufactured in Malaysia (Malaysian EHS Register) so as to be able to identify priority substances and enable protection of people and the environment from the possible harmful effects of these substances
The scheme provides a means of anticipating potential problems and facilitate the implementation of timely and appropriate control measures for specific EHS
The scheme provides input for the risk assessment of EHS and thereby a means of anticipating potential problems and facilitate the implementation of timely and appropriate control measures for specific EHS. It provides amechanism for identifying, evaluating and controlling of EHS
EHS Notification and Registration Scheme
Awareness Raising and Training
The DOE and CICM conducted awareness seminar for importers and manufacturers of EHS
Hands-on training were conducted for importers and manufacturers of EHS to familiarise with the on-line EHSNR system
EHS Notification and Registration Scheme
Status Report on Voluntary EHS Notification and Registration Scheme (21January 2010)
EHS Indicators Data
No. of Companies Identified as Potential EHS Notifiers 1084
No. of Chemical Companies Registered To-Date 154
No. of EHS Entered By Industry Into System 346
No. of EHS Officially Notified To DOE 215
No. of EHS Not In EHS Reference List (Detailed Notification Required)
60
No. of EHS Officially Notified in Detail by Industry to DOE 29
EHS Notification and Registration Scheme
CONCLUSION
The EHS Notification and Registration Scheme is the initial effort of getting information and enabling the prioritisation, risk assessment, risk reduction strategy and the risk reduction actions to be taken in the future.
Much work is needed to achieve sound management of EHS. Therefore, the need for all those involve in EHS to commit and work together is imperative because how everyone handle and manage EHS will determine its impact and the future of the people and the environment.
THANK YOU