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Shanghai Maritime Safety Administration Further Clarify the Declaration Requirements for Dangerous Goods Transportation in Waigaoqiao Area: 100% Components Disclosure is NOT Mandatory

from CIRS by

Transport,Dangerous,Goods,River,China,Mixture,

On May 11, 2022, Shanghai Maritime Safety Administration issued a Statement to further clarify the declaration requirements for the Components of hazardous mixtures transshipped through Waigaoqiao Area. Compared with the Statement released on February 8, 2022, the new Statement stipulates that it is not mandatory for enterprises to provide 100% component information when making declarations. Meanwhile, if the goods subject to transport do not contain prohibited components, related enterprises only need to provide a written document to guarantee that their goods are not banned to transport via inland waterways instead of revising the MSDS.

To facilitate enterprises to understand the main changes to the statements, CIRS Group make a comparisons and give explanations item by item for your reference:

Statement on February 8

Statement on May 11

Major Changes

1. According to the requirements of Article 2 of the Guidance Documents for Catalog of Hazardous Chemicals (2015 version), CAS Number is the one and the only criterion to determine whether the dangerous goods fall under the scope of prohibited goods;

1. “Prohibited Goods” under this Statement refer to hazardous chemicals marked as “highly toxic” in the remark column of the Catalog of Hazardous Chemicals (2015) and chemicals listed in the Inventory of Hazardous Chemicals Prohibited in Inland Waterways (2019 revision). According to the requirements of Article 2 of the Guidance Documents for Catalog of Hazardous Chemicals (2015 version), CAS Number is the one and the only criterion to determine whether the dangerous goods fall under the scope of prohibited goods;

It is much clearer to determine whether the hazardous goods are prohibited to transport.

2. If the dangerous goods that are to be transported or transit through Waigaoqiao Area are mixtures, it is recommended to provide MSDS with full components information when going through the declaration procedures, which include the name, proportion, CAS Number, etc.

2. If the dangerous goods that are to be transported or transit through Waigaoqiao Area are mixtures, it is recommended to provide MSDS with full components information when going through the declaration procedures, which include the name, proportion, CAS Number, etc.

None

3 Mixtures whose components information is fully shown in the MSDS and the components do not fall within the scope of prohibited goods can transport or transit through the Waigaoqiao water area;

3 In terms of mixtures whose components information is fully shown in the MSDS, the following requirements shall prevail:

1) If all the components do not fall within the scope of prohibited goods, aforesaid mixtures can transport or transit through the Waigaoqiao water area;

None

In terms of mixtures whose components information is fully shown in the MSDS yet part of the components fall within the scope of prohibited goods, three indicators are needed to further determine whether the goods can be transported:

Health hazards- acute toxicity ;

Hazardous to the aquatic environment-acute toxicity;

Hazardous to the aquatic environment-long term hazards.

If any of the above three indicators is Category 1, aforesaid mixtures are prohibited to transport or transit through Waigaoqiao Water Area.

2) If components of the mixtures fall within the embargo scope, three GHS indicators are further required. They are

  • Health hazards- acute toxicity ;
  • Hazardous to the aquatic environment-acute toxicity;
  • Hazardous to the aquatic environment-long term hazards.

If none of the three indicators is Category 1, aforesaid mixtures are allowed for transportation or transit.

If any of the above three indicators is Category 1, aforesaid mixtures are prohibited to transport or transit through Waigaoqiao Water Area.

The requirements remain unchanged when any of the indicators is Category 1; If not, the goods are allowed to passage.

4. In terms of mixtures whose components information are not fully shown in the MSDS, the following three indicators must be shown in the MSDS:

  • Health hazards – acute toxicity;
  • Hazardous to the aquatic environment – acute toxicity;
  • Hazardous to the aquatic environment – long term toxicity;

If any of the above three indicators is Category 1, then the goods are prohibited from transportation and shall not access or transit through the Waigaoqiao water area.

4.1 In terms of mixtures whose components information are not fully shown in the MSDS, the following requirements shall comply:

If any of the three indicators is Category 1, information of all relevant hazardous component including ingredient name, CAS number, and concentration range, shall be supplemented. Besides, this requirement is not restricted by 3.3.2 (“Mixtures”) and Table 1 (“Concentrations limits of health and environment hazard components of mixtures”) under the Guidance on the Compilation of Safety Date Sheet for Chemical Products (GB/T 17519-2013).

If any of the above-mentioned hazardous components contain ingredients banned from transport, then the goods are prohibited from transportation and shall not access or transit through the Waigaoqiao water area.

Significant changes have been made to this Article: When any of the indicators is Category 1, enterprises shall provide the active ingredients that impact the classification of substances. The goods shall be banned from transportation only if any of the components contains active ingredients prohibited from transportation.

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4.2 The following three indicators shall be provided:

  • Health hazard-acute toxicity category;
  • Hazardous to the aquatic environment- acute toxicity
  • Hazardous to the aquatic environment- long term hazard.

If none of the three indicators is Category 1, then the goods are not prohibited from transporting or transiting through the area.

Make clear that although the complete components information is not provided, the goods can be transported if none of the indicators is Category 1.

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5. The above-mentioned “GHS classification indicators” and “relevant hazard component information” in Article 3 and 4 of the Statement can be submitted in a written guarantee during declaration, thus the MSDS does not need revising.

Newly added. Enterprises can provide a written guarantee containing hazardous information to clarify whether any of the indicators is Category 1. It is more convenient as it is not necessary to revise the MSDS.

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6. Article 2, 3, 4, and 5 under this Statement are only applicable to hazardous mixtures transshipped within the area and are not applicable to “substances” prescribed in Part III of the MSDS.

Newly added. It is clarified that only mixtures are required to provide information on all or some components and Category 1 components information. This requirement is not applicable to “substances”.

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7. The Administration provides pre-review and publicity services for enterprises. Enterprises can submit relevant technical information to the Administration in advance. Publicity will be made on the official website if the Cargo is not banned to transport after review.

Newly added. Shanghai Maritime Safety Administration provides a pre-review service to help enterprises judge whether the goods is banned to transport.

The new Statement released to help enterprises determine whether their products are prohibited to transship in inland waterways. Meanwhile, the components information can be provided via a written guarantee, which lessens enterprises’ burdens. Moreover, the Shanghai Maritime Safety Administration also provides a pre-review service.

Background

The Yangtze River Protection Law of the People’s Republic of China has entered into force on March 1, 2021. In accordance with Article 51 (2) of the Protection Law, “the transportation of highly toxic chemicals and other hazardous chemicals that cannot be transported in inland waterways under national standards are prohibited in Yangtze River.” The Waigaoqiao Area, as the main section of the Yangtze River Basin as stipulated in this Law, does not allow the prohibited goods to access or transit through the area from 1 Mar. 2021.

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