Discussion on the Announcement by the State Administration for Market Regulation regarding Administrative Licenses for Special Equipment (No. 3, 2019)
Thread Content
This post was last edited by sssshack on 2019-6-15 at 22:51. The **General Administration for Market Regulation of the People’s Republic of China’s Announcement No. 3 of 2019, titled “Announcement by the General Administration for Market Regulation on Matters Related to Administrative Licenses for Special Equipment,” came into effect on June 1st. I have just read this announcement and have some questions, so I would like to ask everyone for their advice. Firstly, the GC3 pipeline is no longer available; it must have been integrated into the GC2 pipeline. That’s not a big problem, as the GC3 pipeline wasn’t very useful to begin with. Additionally, the criteria related to the toxicity of GC1 pipes have changed. Previously, GB20801 was based on GB5044 for classification, but this new regulation relies on the acute toxicity criteria listed in the hazardous chemicals catalog. The most up-to-date version of this catalog is from 2015. There is also a table providing information on the classification of hazardous chemicals, and this document can be downloaded from the official website; by searching for “Hazardous Chemicals Classification Information Table” on the website of the State Administration of Work Safety, one will find the Guidelines for the Implementation of the Hazardous Chemicals Catalog, with the relevant table attached to that page. This table lists the acute toxicity of each material, which can be used as a basis for classifying them as GC1. However, it shows acute toxicity in three forms: dermal, oral, and inhalation; if one of these values meets the requirements, then the material is classified as GC1. There is another issue: for toluene in this table, which has the serial number 1014 (this serial number corresponds to that in the 2015 version of the hazardous chemicals list), the hazard category indicates \"hazardous if inhaled\", Category 1. The hazard classification for the other (overwhelming majority) of substances is listed as Acute Toxicity – Inhalation, Category X. The format used for toluene does not match that of the other substances in this regard; I’m not quite sure why. If classification is based solely on acute toxicity in the future, would toluene be classified under GC1? Please advise :) The attached diagram shows the description of toluene in the classification table. Additionally, the description for substance with serial number 986 follows the standard format used for describing the acute toxicity of most substances, and it can be seen that toluene’s description is different. Another thing is the new division of announcements into GC1 and GC2.
To share my own opinion, the Hazardous Chemicals Catalog (2015 edition) provides some explanations: 1. “Principle for determination: The types of hazardous chemicals are determined based on the **standards for chemical classification and labeling, from the following categories of dangerous and harmful properties.” . . . ” 2. “Threshold for determining severe acute toxicity: Acute toxicity, Category 1, i.e., meeting one of the following conditions: in rat tests, an oral LD50 ≤ 5 mg/kg, a dermal LD50 ≤ 50 mg/kg, and an inhalation (4 h) LC50 ≤ 100 ml/m3 (for gases) or 0.5 mg/L (for vapors) or 0.05 mg/L (for dusts and mists).” Experimental data on percutaneous LD50 can also use rabbit experiment data. ” In summary, is the \"standard for chemical classification and labeling\" mentioned here the current GB30000? The data in point 2 above are consistent with the acute toxicity category 1 values specified in GB30000.18 \"Specifications for Chemical Classification and Labeling – Part 18: Acute Toxicity\". I checked the LD50 for toluene, which is 5000 mg/kg (oral administration in rats) ； LC50 12124 mg/kg (rabbit dermal) ； Inhalation of 71.4 g/m3 can be fatal in a short period of time ； When a person inhales 3 g/m3 for 1–8 hours, acute poisoning occurs ； When a person inhales 0.2–0.3 g/m3 for 8 hours, toxic symptoms appear. (Data sourced from Baidu Baike) According to GB30000.18, it falls into Category 5 of acute toxicity; therefore, it should not be classified as GC1. This is consistent with the classification of toluene under the original GB5044 as having moderate hazard. I’m not sure if GB30000.18 will work in the future It's just my personal opinion; I welcome everyone's feedback
Acute toxicity and inhalation hazards are two different things, right?
After checking, there are about 70 substances classified as \"harmful if inhaled, Category 1\", among which are substances with moderate to low toxicity such as cyclohexane, as listed in GB5044 and HG20660. I don’t know where this “Inhalation Hazard, Category” comes from?
Inhalation is one classification, while acute toxicity is another; therefore, there is no contradiction for toluene
GC3-grade pipes still exist; it’s just that the permits have been revoked and they have been merged.
Something that poses an inhalation hazard isn’t necessarily acute toxic; that makes sense