India’s Environmental Policy for Chemicals

Last April we wrote about India’s new manufacturing policy. They needed one then, and some say still do. Manufacturing in the land of cumin and curry has stalled. But don’t be fooled into thinking that means manufacturing is not happening at all in India — it means growth has stalled, not production.

Some wonder, rhetorically, how could Indian manufacturing have kept growing…?

Answer: by finding new markets.

Maybe you saw the news (India GDP news May 31, 2012) that India’s GDP growth slowed to 5.3% in Q1. This represents a three-year low for the nation. However, let’s not count India out just yet. Not even close. The nation, like many of its neighbors, is pausing, looking for new markets to pour its tremendous energy into.

One of those markets looks like it might be the chemicals industry.

Let’s take a look at the chemical industry (and related policy) in India.

India industrial sector growth: chemicals. In India, the chemical industry is said to be one of the oldest in the nation. It’s essential to any nation’s economic development that is based on manufacturing. In years past, India has had to import and almost-embarrassing amount of raw materials, including chemicals. Still, the Indian chemical sector is growing, estimated now to be worth about $108 billion.

Asia itself is a rising star in chemical sales. For example, over the last 10 years, Asia’s share of global chemical sales has increased by ~14%. Currently, the Indian chemical industry accounts for approximately 7% of India’s GDP. The share of industry in national exports hovers near 11%. Despite its large size and significant GDP profile, India’s chemicals industry represents only about 3% of global chemicals.

The Indian chemical industry is one of the most diversified sectors touching thousands of commercial products. As the raw materials engine in a booming manufacturing ship, the chemical industry is central to industrial and the agricultural development. The chemical industry provides essential building blocks for multiple downstream industries, such as textile, paper, paint, soap, detergent, pharmaceutical, varnish, etc. In India, the chemical sector is known to be largely based on feed stock derivatives from cracking of naphtha in oil refineries providing the building blocks, such as benzene, toluene, xylene, cresols, etc.

India environmental policy: chemical policy like REACH? India’s Ministry of Chemicals and Fertilizers has declared the need to invigorate the chemicals aspect of its environmental policy. Holding out for REACH-like* legislation might be a stretch in the near future (someday maybe). But the Ministry is talking in the direction of the safer use of chemicals. “For the protection of human health and the environment, and in order to reduce the current number of chemical-related laws,” authorities are saying.

*REACH is a European regulation, a pioneer initiative in the world on that deals with the registration, evaluation, authorisation and restriction of chemical substances, which entered into effect on June 1, 2007 in the European Union.

However, in India, the Department of Chemicals and Petrochemicals did begin a consultation process of the draft national chemicals policy in April of this year (2012). The resulting document includes a wide range of objectives and proposals.

Included in the documentation is the stated need to consolidate the “multiple legislations in India governing the chemicals industry that fall under the purview of different ministries.”

Also, according to the draft, India lacks legislation that addresses the following:

  1. the registration of substances
  2. preparation of a national inventory
  3. restrictions on hazardous substances
  4. banning of certain substances
  5. detailed classification and labeling criteria
  6. transport classification

The draft policy also calls for the creation of a “National Chemical Centre” (NCC). They would perform functions such as:

  1. draft legislation
  2. monitor its implementation
  3. monitor international trade practices
  4. identify opportunities for innovation and technology

The NCC would have a role in disseminating information about hazardous chemicals and create and maintain a chemicals inventory, which would include data on production, consumption and toxicological properties.

A second new body which the document states should also be set up under the guidance of the department is a “Chemical Standard Development Organisation”, or CSDO. They would “drive consensus regarding national requirements, including safety norms.”

Sound like REACH?  Yes — ish — in theory.  In reality though it’s light years away, in miles, sure, but mostly in time.

Resources besides those referenced above, as links:
International Labor Assn for Sustainable Development ILASD
Subscription / fee based: Chemical Watch

ECHA to Add 7 Chemicals to REACH SVHC List

The European Chemicals Agency (ECHA) will shortly add seven new chemical-substances to REACH regulation’s Candidate List of Substances of Very High Concern (SVHC). The comment period was slated to last through July 4, but ECHA says that the consultation period is now over.

The seven candidates for SVHC are as follows:

  1. 2-ethoxyethyl acetate
  2. strontium chromate
  3. 1,2-Benzenedicarboxylic acid, di-C7-11-branched and linear alkyl esters
  4. Hydrazine
  5. 1-methyl-2-pyrrolidone
  6. 1,2,3-trichloropropane
  7. 1,2-Benzenedicarboxylic acid, di-C6-8-branched alkyl esters, C7-rich
  8. Cobalt dichloride

The list shows eight substances because it includes cobalt dichloride. The status of cobalt dichloride is actually up for re-evaluation, due to its revised classification as both carcinogenic and toxic for reproduction. Cobalt chloride was originally identified in October 2008 as SVHC solely on its carcinogenic properties, says REACHtracker.

REACH update

The Candidate List is growing. There are now 46 SVHCs. The next ECHA consultation is planned for August, and that will kick off a busy time as the European Commission expects to have reviewed and listed 135 SVHCs by the end of 2012. The goal is to have reviewed, listed and regulated all relevant known SVHCs by 2020.

In the meantime, expect bi-annual updates to the Candidate List.

Further reading

For more on these chemicals, see Chemical Watch (pay site).

For detail on each chemical, here’s a good page from Safe Packaging.

The Actio chemical databases will be updated to reflect the change as soon as the Candidate List is updated; for now these chemicals are flagged as “probable SVHCs.” Wishing you good luck with quality assurance efforts and product development in this era of digital chemical management. It’s not easy!

European Agencies Ban Six Chemicals

In REACH and chemicals news, it was announced in Europe that six dangerous substances are to be phased out. This means that manufacturers who use these chemicals in their products — or have absorbed them somewhere in their supply chain — will have to:

a) know about those offending product ingredients, and

b) find replacement raw materials if the company is to conduct business in Europe legally.

The Commission decision follows the successful first phase of REACH’s registration and notification of chemicals. It’s all a part of REACH, Europe’s initiative to make the use of chemicals safer.

European Commission Vice President Antonio Tajani said, “Today’s decision is an example of the successful implementation of REACH and of how sustainability can be combined with competitiveness. It will encourage industry to develop alternatives and foster innovation.”

What it means is that six substances of very high concern — also known as SVHCs — have been moved from the candidate list to the authorization list, known as Annex XIV, under the EU’s REACH regulation. Annex XIV is like chemical-Alcatraz, substances there cannot be placed on the market or used unless they get a special clearance from the Agency and authorisation is granted for a specific use. All SVHC listings, selections and classifications are based on recommendations made by the European Chemicals Agency (ECHA).

The following six chemical substances of very high concern are the first entrants in the Annex XIV:

1. 5-ter-butyl-2,4,6-trinito-m-xylene (musk xylene)

2. 4,4′-diaminodiphenylmethane (MDA)

3. hexabromocyclododecane (HBCDD)

4. bis(2-ethylexyl) phthalate (DEHP)

5. benzyl butyl phthalate (BBP)

6. dibutyl phthalate (DBP)

If your company uses any of these substances – even in tiny quanitites – or if these substances appear magically in your product from a mysterious supply chain source – a timetable for substitution will have to be submitted. These six substances have been determined to be either carcinogenic, toxic for reproduction or persistent in the environment and to accumulate in living organisms, and will be banned within the next three to five years.

Environment Commissioner Janez Potonik said: “Chemicals are everywhere in the modern world and some of them can be very dangerous. Today’s decision is an important step towards better protecting our health and the environment.”

Additional substances will be added to Annex XIV in the future.

The Commission also says it will put forth a greater number of known substances of very high concern for inclusion in the candidate list. The Commission and the European Chemicals Agency say they are fully committed to achieve this goal, and are expecting the “active engagement of the Member States.”

SVHC background. As we’ve reported previously in this blog, the SVHC list is simply a list of Substances of Very High Concern. “Only the European community could come up with such a tactful term for ‘highly toxic stuff,'” as a recent article in Environmental Leader put it.

By 2012, over 165 substances are expected to be listed on the SVHC candidate list. The list includes substances which are:

* Carcinogenic, Mutagenic or toxic to Reproduction

* Persistent, Bioaccumulative and Toxic (PBT) or very Persistent and very Bioaccumulative (vPvB) (defined by REACH criteria), and/or

* Identified as causing probable serious effects to humans or the environment of an equivalent level of concern as those above, e.g. endocrine disrupters — for reference, in the US there are 134 suspected endocrine disruptors.

The latest SVHC candidate list is online here at the ECHA site, and if that site is down — as it often seems to be — go to the June 2010 SVHC candidate list hosted by Actio.

www.actio.net/default/index.cfm/actio-blog/