Regarding **chemical registration issues, those who are knowledgeable please take a look
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I’m running a new company called Xiao An Huan. I’m currently working on **chemical registration and have run into some issues; I’d like to ask for everyone’s advice. In other words, are ammonia aqueous solutions (40%) and triphosgene considered **chemicals that are subject to strict regulation? The list of hazardous substances includes only monoamines, phosgene, and diphosgene. However, in the interpretation provided by the Third Department of the Work Safety Supervision Bureau regarding the list of substances under close supervision, it is stated that the chemicals subject to close supervision include the 60 chemicals listed in the said directory, as well as those that fall into the following categories at a temperature of 20°C and under standard atmospheric pressure of 101.3 kPa: 1. Flammable gases of Category 1 (gases with a lower explosive limit of ≤13% or an explosive range of ≥12%) ； 2. Flammable liquids, Category 1 (closed-cup flash point
Key points: supervision of hazardous chemicals
This interpretation states that enterprises that handle hazardous chemicals under close supervision are not allowed to obtain a safety production license—however, according to the requirements for such licenses, one is only required to obtain them if the final product or intermediates are hazardous chemicals. To obtain a license for the use of hazardous chemicals, it is also required that the amount of such chemicals used reaches a certain level. Isn’t there some contradiction?