China further explains component declaration for hazardous mixtures transported in Port of Shanghai’s Waigaoqiao area

China’s Shanghai Maritime Safety Administration on May 11 released a revised, more detailed version of the explanatory statement clarifying how to declare the components of hazardous mixtures transported by ship in the Port of Shanghai’s Waigaoqiao area. The original statement was issued by the administration in February.

The statement recommends that information on all the components of hazardous mixtures transported be provided in the MSDS submitted in the dangerous goods declaration. The revised version adds that companies can demonstrate that their goods are not goods banned for transportation by submitting a written guarantee if the goods meet certain conditions.

The revised statement also clarifies the definition of “goods banned for transportation” as follows: “Goods banned for transportation refer to the chemicals designated as ‘highly poisonous’ in the note column of the List of Hazardous Chemicals (2015) and the chemicals contained in the List of Hazardous Chemicals Banned for Transportation in Inland Rivers (2019)”.

Moreover, it mentions a service provided by the administration that makes sure if goods are considered banned for transportation or not before actually transporting them.

A tentative English translation of the revised statement

(Parts in bold indicate changes or additions to the original statement.)

1. In this explanatory statement, “goods banned for transportation” refer to the chemicals designated as “highly poisonous” in the note column of the List of Hazardous Chemicals (2015) and the chemicals contained in the List of Hazardous Chemicals Banned for Transportation in Inland Rivers (2019). According to the Article 2 of the List of Hazardous Chemicals (2015) Implementation Guidelines (trial implementation), it is determined solely based on CAS Registry Numbers whether or not certain dangerous goods are banned for transportation.
2. When a hazardous mixture is loaded as dangerous goods in a container on a vessel planning to transport goods into or out of the port in the Waigaoqiao area, transport goods through the area or transship goods within the area, it is recommended that information on all the components of the mixture be provided in the MSDS submitted in the dangerous goods declaration. Information on the components of a mixture should contain the name, proportion, CAS Registry Number and other necessary information of each component.
3. If all the components of a mixture are provided in the MSDS, the transportation ban is enforced on the mixture as follows:
   • If none of the components is banned for transportation, the mixture is not considered banned for transportation.
   • If any of the components is banned for transportation, the following three GHS categories must be provided: health hazard-acute toxicity category, aquatic environmental hazard-acute toxicity category and aquatic environmental hazard-chronic toxicity category. If none of the three categories falls under Category 1, the mixture is not considered banned for transportation. If any of the three categories falls under Category 1, the mixture is banned for transportation and may not be transported into or out of the port in the Waigaoqiao area, transported through the area or transshipped within the area.
4. If there is any component of a mixture that is not provided in the MSDS, the transportation ban is enforced on the mixture as follows:
   • The following three GHS categories must be provided: health hazard-acute toxicity category, aquatic environmental hazard-acute toxicity category and aquatic environmental hazard-chronic toxicity category. If none of the three categories falls under Category 1, the mixture is not considered banned for transportation.
   • If any of the three categories falls under Category 1, information on all the hazardous components contributing to the mixture falling under hazard Category 1 must be provided as supplemental information. This information includes the names, CAS Registry Numbers and ranges of concentration of the hazardous components. This requirement is not subject to the limits listed in Table 1 “Concentration limits on mixture components hazardous to health and the environment” in Section 3.3.2 “Mixtures” of the Guidance on the Compilation of Safety Data Sheet for Chemical Products (GB/T 17519-2013). If the said information on hazardous components includes information on a component that falls under goods banned for transportation, the mixture is banned for transportation and may not be transported into or out of the port in the Waigaoqiao area, transported through the area or transshipped within the area.
5. If a written guarantee is submitted in the declaration process, there is no need to alter the MSDS to provide the “GHS categories” in Paragraph 3 and the “information on all the hazardous components” in Paragraph 4.
6. The requirements of Paragraphs 2, 3, 4 and 5 of this explanatory statement apply only to mixtures that are hazardous goods on board a vessel and do not apply to goods listed as a “substance” in Section 3 of the MSDS.

The Shanghai Maritime Safety Administration provides an advance verification and public notice service for companies that need it: companies may submit technical materials about items to be transported to the administration in advance and if the administration determines that the items do not fall under goods banned for transportation after carrying out a review, the result is published on a website.