Index
New monomer shipping requirements
Below is the text from the MSC Website (accessed 18 Oct 2021)
MSC Customer Advisory
Hamburg, Germany, 19 July 2021
Dear Customers,
Due to the actual congestion situation in the world and the time that cargo is staying in ports, we are anticipating pro-actively to transport all IMDG catalogued stabilized / inhibited dangerous cargo as from now in operating live reefers due to safety reasons.
The operational carriage reefer temperature is set in general at +10°C but must always be seen in the context of compliance with the IMDG code.
This customer advisory raises more questions than it answers:
Will other shipping lines follow suit?
Is MSC going to require a lower temperature at loading?
Will that mean that the container needs to be plugged in prior to delivery to the port?
Do enough tank depots have 440v plugs to accomplish this?
Given the current supply chain issues plaguing the world, can companies get enough. A/C units and have them installed in enough time to not create further disruption?
As we have mentioned before in this newsletter, logistics challenges can show up unexpectedly. OURAY strives to keep the information you need heading your way so these challenges can remain as technical issues only and not allowed to grow to complete game-stoppers.
Risk mitigation basics
Risk mitigation can be a daunting task for anyone. Here are a few tips to make the work more accessible.
Break it down into steps. First, you have to assess the risk:
● Ask what could happen? (Risk can be good and bad)
● Identify the risk.
● Identify the source(s) of the risk (External, Process, People, Relationship, System)
● Identify the system(s) affected by the risk (People, Environment, Assets, Reputation)
● Determine the initial risk level. All risk is ranked based on two factors, probability, and severity.
As seen in the chart below (taken from DD 2977) the more frequent and more severe the risk is, the higher the risk level is. The less frequent and lower threat risks are lower risk levels.
Now that you have a grasp on what the risk is, where it comes from, what it may affect, and what the overall magnitude is, you can start looking at risk mitigation strategies. There are four recognized risk mitigation strategies, they are accept (and monitor), avoid, share, and limit (usually through insurance and contracts). Every risk will have its own challenges and will require a tailored risk mitigation strategy.
There are two factors of risk mitigation that often trip people up. The first is that everything about risk analysis and mitigation is subjective. Yes, you can start with objective data, and the more data you have the less subjective the analysis may be, but analysis is subjective in every case. The second stumbling block is that risks absolutely have to be monitored. This means the higher the risk, the more often you should revisit the analysis. As all of us are acutely aware of after the pandemic, things can change very rapidly. The system you analyzed could completely change or the mitigation strategy you established could no longer be valid. And like many things in the chemical world, the plans you develop may not be realized when an event occurs, but the planning you put into your risk mitigation strategy will be invaluable.
OURAY hopes this brief primer on risk helps you get started with your unique risk analysis and mitigation strategies. If you are still finding the idea to be more than you are comfortable dealing with, OURAY can help you and your company tackle the risk monster.
APAC Regulatory updates
Australia
Australian Dangerous Good Code Edition 7.7 to Be Mandatory from October
02 Jul 2021 The ADG Code provides technical requirements for the land transport of dangerous goods across Australia. If you transport Dangerous Goods within Australia by road or rail, check and see if any of the key changes affect your products...
Australian Dangerous Good Code Edition 7.7 to Be Mandatory from October
13 Jul 2021 Three national standards for recycled plastics were issued, involving general rules, and standards for PE and PP materials. Another five standards for ABS, PS, and PS-I, PC, PA, and PET materials will be issued soon...
Australia Publishes Roadmap and Work Plan for Industrial Chemicals Evaluations
11 Oct 2021 Australia has implemented the Evaluations Roadmap and the Rolling Action Plan, providing more targeted information and recommendations about managing the potential risks associated with the introduction and use of industrial chemicals...
Bangladesh
Bangladesh Publishes E-waste Management Rules
02 Sep 2021 Bangladesh published the E-waste Management Rules, 2021 under the Bangladesh Environment Conservation Act, 1995, setting e-waste collection targets and stipulating RoHS provisions for 10 hazardous substances...
China
China MoT Clarifies Requirements for Transport of Medical MRI Machines and Limited Bottled Freon-type Refrigerant Gases
Liquid helium in medical MRI machines and Freon-type refrigerant gases can be exempt from TDG requirements such as qualification of transport enterprises and practitioners, special vehicles requirements, etc...
China Officially Accept the Kigali Amendment to the Montreal Protocol
HFCs will be further controlled to gradually reduce climate warming, which will benefit the development of disposal and treatment technologies of the HFCs and promote the replacement by more environmentally friendly alternatives...
China Proposes to Approve Eight New Varieties of Food-related Products
PET plastic materials and articles with silicon dioxide coatings made from the monomers hexamethyldisiloxane and hexamethyldisilazane should not be used for irradiated food, or contact with infants and young children food or breast milk...
China MEE to Further Standardize Discharge Management of Industrial Solid Waste
The draft standard specifies requirements for information report, pollution prevention, and control, and environmental management ledgers and discharge permit implementation reports preparation of industrial solid waste discharge units, etc...
China Issues Data on Occupational Diseases in 2020
According to the Report, pneumoconiosis continues to be the most important occupational disease in the country, which seriously endangers workers' health due to long-term inhalation of large amounts of free silica with other dust...
China MEE Consults on National Work Plan for the Assessment of Standardized Environmental Management of Hazardous Waste
China MEE will improve the assessment of standardized environmental management of hazardous waste in China. The evaluation index has been updated...
China MEE Adds 8 Substances into IECSC
These substances were manufactured in or imported into China before October 15, 2003. They are now regulated as existing chemical substances in China, and thus free from new chemical registration or notification requirements...
China to Formulate Industry Standard on Determination of Phthalates in EEPs
China CESI now invites units to join the working group to draft the standard on determining Phthalates in EEPs by high-performance liquid chromatography method. In 2019, CESI issued a draft for the association standard of the same name...
Shenzhen Customs Answers Questions Regarding Inspection on Imported and Exported Hazardous Chemicals and Their Packaging
15 FAQs from the industry regarding the inspection on imported and exported hazardous chemicals and their packaging were answered by the customs...
China Approves 28 New Varieties of Food Additives and Food-related Products
Nine new enzyme preparations for food processing were approved by China NHC. 19 new food-related products were approved, including three food contact materials (FCM) additives, nine FCM additives with extended application scope, and seven resins for FCM...
China Legislates on Dust Explosion Protection for Industry and Trade Enterprises
The Regulations are formulated in accordance with the newly issued Work Safety Law and will enter into effect on September 1st, 2021, simultaneously with the Law. The Regulations consist of five chapters...
China MEE to Incorporate HFCs Reduction Plan into National Program
China currently produces around 70% of the world’s refrigeration products. In the process of achieving the carbon peak in China, it is critical to curbing non-CO2 greenhouse gas emissions, including HFCs which are "super” greenhouse gases...
China Nantong City Issues the First Environmental Protection Fine on Source Control of VOCs
The enterprise was punished for using solvent-based paint with high VOCs emissions in production. A replacement system of clean raw materials including low-VOC coatings, inks, adhesives, etc. will be established in the city...
China to Implement New Hazchem Registration Online System
The scope of substances subject to hazardous chemical registration and the application process remains the same, while the new version of the system requires more data...
China MEE to Revise List of Controlled Ozone Depleting Substances
China MEE is consulting on the Revision to the List of Controlled Ozone Depleting Substances to reduce and phase out HFCs in China...
Shanghai Steps up New Chemicals On-site Inspections
Random on-site inspection for new chemical substances will be stepped up to cover general enterprises that manufacture, use or import chemical substances...
China MIIT Consults on over 300 National and Industry Standards
The relevant standardization technical organization has completed the compilation or revision of 290 industry standards and 6 national standards. In addition, 10 industry standards were translated into English...
China MEE to Incorporate HFCs Reduction Plan into National Program
MEE specifies the prominent problems in VOCs governance and corresponding measures to be taken. The supervision of the quality of products containing VOCs will be strengthened...
China MEE Publishes New Chemical Record Notification Statistics in the First Half of 2021
China MEE released 2,648 new chemical substance record notifications received from January 2021 to June 2021, covering more than 3,000 new chemical substances...
Shanghai Consults on Use Safety Management Guidelines of Hazardous Chemicals in Industrial and Trade Enterprises
Shanghai is to improve the use safety of hazardous chemicals in metallurgy, non-ferrous metals, building materials, machinery, light industry, textiles, tobacco, and trade and commerce sectors...
Nanjing Released 2021 VOC Product Quality Supervision and Sampling Implementation Rules
The implementation rules specify the sampling methods, inspection basis, determination principles, objection handling, and re-inspection...
China MEE Adds 15 Substances into IECSC
They are now regulated as existing chemical substances in China, and thus free from new chemical registration or notification requirements under the MEE Order No. 12...
China to Form a More Efficient National Carbon Trading Market
China will establish a more effective carbon trading market and send a powerful carbon price signal to help the smooth transition to a low-carbon future...
Fostering Green Finance in Pursuit of Carbon Neutrality, China in Action
Green finance plays an important role in the accomplishment of China’s carbon peak and carbon neutrality targets. China is keeping on making efforts to facilitate its goal of carbon neutrality...
China Receives Conformity Assessments for 18,420 Products under China RoHS 2
As of the end of July 2021, China MIIT had received 12,369 conformity assessments submitted on its RoHS public service platform from 1,140 companies, involving 18,420 products, an increase of 2,555 since last December...
China MEE Consults on Adding 23 Substances into IECSC
These 23 substances were manufactured in or imported into China before October 15, 2003, which fulfilled the supplementation criteria but missed the previous supplementation window...
China to Revise Plan for 197 Carbon Peak Standards in 10 Industries
These 197 carbon peak-related standards cover 10 industries, of which 161 standards belong to the category of energy conservation and comprehensive utilization, covering many industries...
China MEE Consults on the Draft Work Plan and Indicator System for “No-Waste City” Construction
Based on the successful experience of the pilot construction program, the Work Plan was drafted, aiming to promote the construction for “No-Waste City” in about 100 cities at or above the prefecture-level and minimize the environmental impact of solid waste by 2025...
China to Launch Autumn and Winter Action Plan for Air Pollution Management in Key Regions
More cities will be included in key regions for air pollution management. They are required to meet control targets for the average PM2.5 concentration and the number of severe pollution days from October 1, 2021, to March 31, 2022...
China to Launch Autumn and Winter Action Plan for Air Pollution Management in Key Regions
China to publish a new standard, the Safety Requirements for Footwear, for limits of hazardous chemicals in footwear products...
China Issues Action Plan to Control Plastic Pollution by 2025
China will make efforts to control plastic pollution from plastic reduction, plastic recycling and disposal, and plastic waste cleaning, which will release the market demand for biodegradable plastics to a greater extent...
China Places Bigger Focus on VOCs Governance During the 14th Five-Year Plan
Considering the long-term impact of VOCs on health and the environment, more and more provinces in China are implementing or preparing local regulations to reduce VOC emission based on the 14th Five-Year Plan...
China Requires 52 Enterprises to Submit New Chemical Annual Reports By October 31
enterprises falling to submit annual reports on approved new chemical substances risk being penalized; the extended submission deadline is October 31, 2021...
China to Tighten New Pollutants Management, Industries Facing Challenges on Source Control over Toxic and Hazardous Chemical Substances
China MEE issues a draft action plan on new pollutants treatment. It outlines the first batch of new pollutants for priority management...
China Publishes List of Controlled Ozone Depleting Substances
The List of 2010 version was abrogated at the same time. Compared to the latest version of the List for consultation, there were no changes in this final revised version...
China MEE Consults on Hazardous Waste Exclusion Management List
Six types of solid wastes are proposed to be included in the Hazardous Waste Exclusion Management List...
China Consults on the Second Revision of Vehicle Mark for Road Transportation of Dangerous Goods
The size of slot-type rectangular signs should be at most 2mm less than the specified size; the substrate surface of rectangular signs should be covered with a reflective film that meets the requirements of GA 666-2018...
India
India Consults on Draft Standard for Toluene Diisocyanate Mixture
India’s Bureau of Indian Standards (BIS) published a draft standard prescribing the requirements and the methods of sampling and test for toluene diisocyanate (TDI-80)...
Japan
Japan MHLW Adds 192 Existing Chemical Substances under ISHL
The substances were assigned with ISHL numbers from 29244 to 29435. The manufactures and importers of such substances will no longer need to notify them as new chemical substances under ISHL...
Japan MHLW to Adopt Autonomous Risk Management for Chemicals in Workplaces
According to the report concerning the management of chemical substances in workplaces, the MHLW’s focus on chemical management will shift to businesses’ autonomous risk management...
Japan to Expand Scope of Mandatory SDS and Labelling Obligations
1,800 hazardous substances are proposed to mandate SDS and labeling requirements under ISHL in the following three years...
Japan MHLW Consults on Health Hazard Prevention Measures for 235 Substances
235 hazardous substances are proposed to mandate SDS and labeling requirements under ISHL. More health hazard prevention measures will be imposed in the future...
Japan to Ban PFOA for 13 Kinds of Imported Products from October 22
The Japanese METI published the partial revision to the Import Clearance Procedures for the Chemical Substances. The major amendments align with the revised CSCL Enforcement Ordinance...
Japan Announces 206 New Chemicals under CSCL
These substances will be considered as Newly Announced Chemical Substances (notified on and after April 1, 2011) and regulated as existing chemicals under the framework of CSCL...
New Zealand
New Zealand Consults on Amendments to HSNO Act
Public comments are welcome for the HSNO Act Amendment Bill to improve chemical assessment for a healthier and safer environment...
South Korea
South Korea Designates 19 New Toxic Chemical Substances
19 substances were newly listed as toxic chemical substances after hazard evaluation under K-REACH. Transitional measures were provided for control of these toxic substances under CCA regulation...
South Korea Opens Online Platform for Approval of Biocidal Active Substances
The platform was designed to receive dossiers and communicate with registrants. Enterprises of the first group of active substances are advised to submit a dossier as soon as possible since the deadline is approaching...
South Korean MoE Proposes Amendments to K-REACH Enforcement Rules
Exemptions for duplicate submissions under K-BPR and K-REACH will ease the industry compliance burden. What are the major proposed amendments worth the attention of enterprises?
South Korea Updates GHS Classification List
Mandatory classification and labeling elements of toxic chemicals, restricted chemicals, and accident precaution chemicals were published. So far, it contains 1,058 toxic substances, 13 types of restricted substances, 60 types of prohibited substances, and 97 precautionary chemicals...
Korea MoE Issues Amendments to Stipulated Quantities for Toxic, Restricted, Prohibited, and Authorized Substances
The Regulation is formulated to facilitate the submission of a chemical accident prevention management plan for handling hazardous chemical substances, which is a new requirement under the CCA from April 1, 2021…
17,151 Substances Pre-registered under Korea REACH
A total of 193,224 pre-registration applications have been submitted for 17,151 existing chemical substances, of which 78 are CMR substances. About 11% of the pre-registered substances are manufactured or imported over 1,000 tonnes per year...
Claiming CBI on Korean MSDS
Korea issued new rules to regulate CBI issues with regards to application, extension, provision of the approval number on the MSDS, etc...
K-BPR: MoE Designates Lubricants as Household Chemical Products Subject to Safety Confirmation
Lubricants are subject to safety confirmation testing at qualified labs every 3 years under K-BPR. Manufacturers or importers can start submission via CHEMP on September 6, 2021...
South Korea Requires Dossier Submission for the First Group of Existing Biocidal Active Substances before October 31, 2021
Companies need to complete pre-registration of Group 1 existing biocidal active substances and submit the approval application plan by September 30, 2021; and submit the dossier for final approval by October 31, 2021...
South Korea Designates 23 New Toxic Chemical Substances and Updates GHS Classification List
23 substances were newly listed as toxic chemical substances after hazard evaluation under K-REACH. Classification and labeling information has been updated for 8 previously published substances...
South Korea to Update Quantity Limits for Hazardous Chemicals that Require Submitting Chemical Accident Prevention Management Plan
South Korea’s MoE is now consulting on the amendments to the Regulation on the Stipulated Quantities for Toxic Substances, Restricted Substances, Prohibited Chemical Substances, and Substances subject to Authorization...
Taiwan
TCSB Official Addresses Industry Concerns over Draft Amendments of Taiwan REACH
Taiwan authority answered questions from the industry regarding the draft amendments of Taiwan’s New and Existing Chemical Registration Regulation, especially issues relating to the extended registration deadline, review period, exemptions, registration validity, etc...
Taiwan to Impose Hefty Penalty on Violations of Toxic and Concerned Chemical Substances Control Act
On August 31, 2021, Taiwan EPA released the revised Guidelines of the Criteria of Fines for Violating the TCCSCA to tighten controls over the listed toxic and concerned chemical substances...
Taiwan Regulates Ammonium Nitrate and Hydrogen Fluoride as Concerned Chemicals
The handlings of ammonium nitrate and hydrogen fluoride are subject to tighter regulation under Taiwan TCCSCA. The handlers shall obtain approval for their manufacture, import, sale, use, storage, etc., and report monthly online for their handlings...
Read More
Taiwan Revises Standards of Hazard Prevention for Specific Chemicals
Taiwan’s Ministry of Labor approved the revised Standards of Hazard Prevention for Specific Chemicals. The revision will take effect on July 1, 2023...
Vietnam
Vietnam Consults on the Amendment of Decree No.133/2017/ND-CP under the Law on Chemicals
The amendment focuses on the declaration of imported chemicals, chemical accident response, and industrial chemicals management, etc. More details on the amendment of Vietnam chemical management regulations may be published in the second half of this year...
OURAY Corner
OURAY forms Joint Venture to Establish Tank Depot Company – HYDERA, LLC
HYDERA is a full-service depot servicing the needs of the bulk liquids transportation industry through the Charleston, South Carolina marketplace. We aim to provide the industry with comprehensive, safe, and reliable service offerings like Tank Cleaning, Heating, Repair, Maintenance, Storage, and Transportation to a wide variety of chemical and food-grade customers.
HYDERA is a joint venture between OURAY and Pacolet Milliken and is strategically located at the Charleston International Manufacturing Center (CIMC) in Goose Creek, South Carolina. CIMC is a multi-tenant heavy industrial site with 24-hour security with close access to the expanding port system and highway infrastructure.