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Explore how CHEMTREC has assisted organizations in readiness, response, and recovery from incidents and crisis situations.
Our case studies include real life examples of how our Emergency Response and Consulting Solutions services have benefited companies throughout the product lifecycle.
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Highly anticipated regulatory changes are on the horizon! OSHA sent the final HCS rule to the Office of Management and Budget (OMB)1 on October 12, 2023. CHEMTREC is here to provide a comprehensive insight on what this means and who may be affected!
The American Chemistry Council (ACC) proudly recognizes two of its members, Dow, and Albemarle Corporation, for their valued contributions as they become the first ACC members to sponsor a CHEMTREC® HELP Award (Dow) and join the esteemed Chairman's Club of the TRANSCAER® Corporate Member Program (Albemarle).
CHEMTREC® is pleased to announce the appointment of Andrew H. LaVanway as its new Chief Executive. LaVanway joins CHEMTREC from ICF, where he served as Senior Vice President and Division Leader of Disaster Management.
Transport Canada Publishes New Registration Requirements
On October 25, 2023 Transport Canada published new registration requirements under TDGR - Part 17, Site Registration Requirements. During an internal audit of Transport Canada’s Dangerous Goods (TDG) Program in 2006, and a 2011 audit, it was determined that Transport Canada was not fully aware of the entire regulated community involved in “Dangerous Goods Activities” and was recommended they develop a national system to prioritize its inspections of sites. To do this, Transport Canada needs current, accurate, and complete information about persons involved in DG activities. The new registration requirements will require that persons who import, offer for transport, handle or transport dangerous goods at a site located in Canada they own or operate be registered in a new registration database if applicable; and require that all registered persons provide administrative information concerning the dangerous goods and operations being conducted at their respective site located in Canada that they own or operate.
On February 3, 2023, a Norfolk Southern freight train derailed in East Palestine, Ohio, including 11 tank cars containing hazardous materials that left the tracks and ignited, resulting in a release to air, groundwater, and the surrounding community. As a result, Congress is developing legislation designed to improve rail safety. The proposed Railway Safety Act of 2023 would increase federal oversight designed to prevent future derailments. The Act contains key initiatives to advance rail safety and increases the maximum fines DOT may impose on rail carriers for violating safety regulations. The bill also:
requires DOT to update rail car inspection regulations,
requires a minimum two-person crew for certain freight trains,
phases out certain tank cars by May 1, 2025 (four years sooner than required under current law),
expands training for local first responders,
imposes a new fee on certain rail carriers, and
provides funding for research and development to improve railway safety.
U.S. Postal Service issues Final Rule for Shipping Electronic Devices Containing Lithium Batteries and Other Hazmat – November 30, 2022
On November 30, 2022, the United States Postal Service (USPS) published a Final Rule revising its Hazmat Postal Regulations, Publication 52, covering used, damaged, or defective electronic devices containing or packed with lithium batteries. The USPS is limiting the mailing of these products to surface transportation only and are prohibited from being mailed via airfreight. These packages must be marked “Restricted Electronic Device” and "Surface Transportation Only", in addition to all other required markings and labels. This change takes effect immediately. This prohibition does not apply to new devices in original packaging or manufactured certified new/refurbished devices. USPS cites a consistent increase in incidents involving packages being offered for air transport containing used/defective lithium batteries that have not been properly packaged and labeled. The new restrictions in Pub 52 are designed to protect the safety of the public as well as USPS employees.
IATA Significant Changes and Amendments in the 64th Edition (2023)
The lithium battery mark has been revised to remove the requirement for a telephone number to be provided on the mark. There is a transition period until December 31, 2026 during which time the mark shown in the 63rd edition of the DGR may continue to be used.
PHMSA Request for Information (RFI) on Electronic Hazard Communication Alternatives – July 11, 2022
On July 11, 2022, the DOT Pipeline and Hazardous Materials Safety Administration published a Request for Information (RFI) on Electronic Hazard Communication Alternatives. PHMSA is seeking input on the potential use of electronic communications as an alternative to the current, physical documentation requirements for hazard communication. PHMSA anticipates that electronic communication would improve transportation safety, efficiency, and effectiveness by providing electronic access to the same information as currently required under paper documentation.
PHMSA Safety Advisory Notice for the Disposal and Recycling of Lithium Batteries in Commercial Transportation - May 17, 2022
On May 17, 2022, PHMSA issued a Safety Advisory Notice about the dangers related to shipping lithium batteries for recycling or disposal to increase the public’s overall awareness. PHMSA states that it’s hazardous materials investigators routinely saw shippers and carriers improperly package and ship lithium batteries for disposal or recycling. Such dangers included the improper packaging of lithium batteries as not to prevent short circuits, mixing damaged lithium batteries with other batteries in the same packaging, and shipping pallet loads of batteries in boxes and drums with inappropriate identification of package contents.
Lithium Battery UN 38.3 Test Summaries - January 1, 2022
PHMSA, Hazardous Materials Regulations (HMR; 49 C.F.R., Parts 171-180). Final Rule, May 11, 2020.
Effective January 1, 2022, for lithium cells and batteries being offered for transport, manufacturers must make available a test summary upon request. The test summary must include a list of specific elements based on the results of the test report outlined under section 38.3 of the UN Manual of Tests and Criteria. This requirement includes all cells and batteries manufactured after January 1, 2008. This PHMSA rule differs from international requirements in two ways. First, it covers batteries manufactured after Jan. 1, 2008, whereas UN 38.3 goes back to 2003. The other difference is the compliance date. PHMSA extended their compliance date from 2020 to January 2022.
Starting January 2022, packing instructions 965 and 968 have been revised to remove Section II. Small lithium ion and lithium metal batteries and cells will be packaged in accordance with Section IB of Packing Instruction 965 and Packing Instruction 968, as applicable. There is a 3-month transition period to March 31, 2022, to comply with this change. During which time shippers may continue to use Section II.
New International Safety Guidelines for Warehouse Storage of Dangerous Goods in Preparation for Sea-Transport - December 2021
In response to recent warehouse incidents involving improper storage of dangerous goods, including Tianjin, China (2015) and Beirut, Lebanon (2020), a coalition of organizations including ICHCA, IVODGA, National Cargo Bureau, and the World Shipping Council has published a guidance document in the form of a White Paper in December 2021. The document covers topics on warehouse construction, operations, fire protection, security and emergency response and has been endorsed by industry stakeholders such as port operators, insurance companies and associations. It has also been submitted to maritime regulators and the IMO for consideration to be included in international requirements.
TSA Announces 100% Screening of International All-Cargo Flights - June 30, 2021
On June 30, 2021, TSA announced that all Importers, Exporters, Carriers, and Freight Forwarders must comply with the ICAO security requirements for 100% screening of all international all-cargo flights. Requirements include screening of cargo to identify and/or detect hidden explosives and institute supply chain security controls that prevent the introduction of concealed explosives into air cargo. This rule is not new and has been in effect for cargo on commercial passenger aircraft since 2010. As a result, on June 14, 2021, TSA published Federal Register Notice 86, No 112 FR 31512, announcing the Secured Packing Facility (SPF) program.
OSHA Interpretation Regarding Lithium-Ion Batteries as Articles - June 23, 2021
OSHA Hazard Communications Standard, 29 CFR 1910.1200. Letter of Interpretation dated June 23, 2021.
On June 23, 2021, OSHA published an Interpretation Letter responding to the European Portable Battery Association providing clarification that it does not consider lithium-ion batteries to be "articles" under the Hazard Communications Standard (HCS) and are therefore not exempt from the requirement for a Safety Data Sheet. OSHA has stated that it based its decision on public and government information sources showing that lithium-ion battery failure can present a fire/physical hazard and a toxic exposure hazard (e.g., lithium, cobalt) to workers during normal use and foreseeable emergencies.
This interim final rule (IFR) which becomes effective immediately amends the HMR to (1) prohibit the transport of lithium-ion cells and batteries as cargo on passenger aircraft; (2) requires all lithium ion cells and batteries to be shipped at not more than a 30 % state of charge on cargo-only aircraft; and (3) limits the use of alternative provisions for small lithium cell or batteries to one package per consignment. The amendments will not restrict passengers or crew members from bringing personal items or electronic devices containing lithium cells or batteries aboard aircraft or restrict the air transport of lithium-ion cells or batteries when packed with or contained in equipment.
This website contains links to other third-party websites. Such links are only for the convenience of the reader, user or browser; CHEMTREC, LLC does not recommend or endorse the contents of the third-party sites.
The information provided on this website does not, and is not intended to, constitute legal or regulatory advice; instead, all information, content, and materials available on this site are for general information purposes only. While CHEMTREC strives to keep this information current, information on this website may not constitute the most up-to-date legal or regulatory information. Readers of this website should contact their attorney or regulatory expert to obtain advice with respect to any particular matter. All liability with respect to actions taken or not taken based on the contents of this site are hereby expressly disclaimed.
Register for emergency response services when shipping in China
It is mandatory under Chinese regulations to display a 24-hour emergency telephone number on Safety Data Sheets and labels for hazardous products placed on the market within mainland China.
Order 53 from the Chinese State Administration of Work Safety (SAWS) requires importers and domestic manufacturers to register hazardous products with NRCC for emergency response purposes, as stated in Article 5-6, Chapter 2, and Article 22, Chapter 4.
CHEMTREC can help facilitate companies’ registration for the National Registration Center for Chemicals (NRCC) Emergency Response Telephone Number Service.
CHEMTREC's partnership with NRCC offers:
One Contract
Registration for both NRCC and CHEMTREC services directly through CHEMTREC.
Comprehensive Compliance
Assist with hazardous chemicals registration, SDS and label production, and GHS classification reports.
One Phone Number
Use of a single 24/7 emergency response phone number that is authorized by both CHEMTREC and NRCC.
Chinese Compliance
CHEMTREC's Asia inside zone, or any outside zone service, enables companies to register for the NRCC Emergency Response Telephone Number Service through one simple CHEMTREC contract.
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We’ve got your back when it comes to shipping in China. Connect with us and get an estimate to register for NRCC service with CHEMTREC.
All company names that are displayed on the SDS going into and being distributed within mainland China.
Your Chinese version of the SDS.
Index documents, in some cases.
Learn More About Our Partnership with NRCC
CHEMTREC, the world’s leading emergency hazmat response service provider, has partnered with China’s National Registration Center for Chemicals (NRCC) to create a unified global response for chemical emergencies in China.
CHEMTREC offers three levels of coverage based on the regional zones of your shipment origins and destinations. Give us a few details about your shipping practices and we’ll guide you to the right level of CHEMTREC protection.
CHEMTREC can help your company stay safe and in compliance with our online hazmat training courses. Self-paced, interactive, and comprehensive courses make it easier than ever to stay up-to-date on your required training.
Frequently Asked Questions and Confirmation of the Answers from NRCC
CHEMTREC provides a truly global emergency response service that is compliant in China through our partnership with the National Registration Center for Chemicals (NRCC). These frequently asked questions aim to provide international companies managing chemicals in China with an overview of the emergency response requirements on them as companies importing chemicals into China, or companies manufacturing within China.
These questions are aimed specifically at NRCC’s Emergency Response Service and its requirements, not NRCC’s product registration department and requirements.
What is the official regulatory body managing/regulating emergency response in China and what are the specific emergency response (ER) regulations called?
Following the institutional reform of the State Council (2018), the State Administration of Work Safety (SAWS) was abolished and its responsibilities transferred to the Ministry of Emergency Management (MEM).
The specific regulation requiring companies to register hazardous products with NRCC for Emergency Response purposes is set out by SAWS “Article 5-6, Chapter 2 and Article 22, Chapter 4, Order 53” and this continues to be regulated by MEM.
Am I a local Chinese company or foreign company when I register my products with NRCC’s ER center?
Producers or importers based/registered in China are deemed local. Any foreign company importing products into China are classified as a foreign company
Which of my hazardous products require emergency response phone number registration with NRCC?
Any products registered in the Chinese “Catalogue of Hazardous Chemicals, 2015 (including highly toxic chemicals)” require registration with NRCC. This catalogue is only available in Chinese.
Also, any hazardous chemicals classified under GHS (Rev. 4; 2011) require registration with NRCC.
Do my hazardous research and development (R&D) products need to be registered with NRCC for ER purposes? For example, flavor and fragrance R&D products or fuel additives for blending
Yes – R&D products do require registration with NRCC for ER number purposes.
Is there a volume/quantity that requires registration?
No – if the product is hazardous and being sold in China then it requires registration irrespective of the volume.
Do chemicals stored/used inside products/machinery require registration?
No. e.g. fuels and oils inside a vehicle (for the vehicle to run) are hazardous but don’t require registration.
If I manufacture products overseas and another company imports the products into China am I liable for registration of the products or is the importer?
The importer is liable for registration with NRCC. From a legal standpoint the importer should also re-label and re-author the SDS in their name.
However, it’s worth considering whether the costs to register with NRCC mean you mitigate any risks on your company. It also means if you change importer you don’t have to renegotiate the registrations with that importer.
If a company manufactures a chemical inside China, which is registered with NRCC and then for some reason needs to import that same chemical, do they have to then register the product as an import and pay twice for the same product registration?
No – once a product is registered once by a company they do not have to register it again, even if importing the product.
Do Lithium batteries need to be registered with NRCC and to display the ER number?
Lithium batteries are categorized as dangerous goods in China, not dangerous chemicals. Therefore the regulations stipulate that they do not need to be registered, however if a company would prefer to display the NRCC number an SDS will need to be registered. Alternatively companies can display CHEMTREC’s Chinese or international numbers in section 1.4 of the SDS.
Can CHEMTREC provide wider chemical compliance solutions e.g. chemical product registration, SDS/label authoring, testing etc.
Yes – please complete a request a quote form and we can provide more details on how we can support you.
Are products which are unclassified under GHS, or not classed as dangerous goods, required to be registered with NRCC for Emergency Response purposes and to display the NRCC ER number?
If a product is classified under GHS, they need to be registered with our NRCC Emergency Telephone Number Service. However, if a product is unclassified under GHS, companies can display NRCC’s telephone number in section 1.4 of the SDS provided the SDS is registered with NRCC or alternatively CHEMTREC’s international telephone number can be used. If there is uncertainty as to whether the product is unclassified then it is recommended to register the SDS with NRCC.
CHEMTREC, in conjunction with NRCC, provides this Frequently Asked Questions (FAQ) overview as a service to its customers and potential customers. This information was compiled as of May 1, 2021 and CHEMTREC believes it to be current and correct as of May 1, 2021. Be aware that regulations often change or are revised over time. Please check the regulatory source to ensure you have the most up-to-date information available. Neither the American Chemistry Council, CHEMTREC nor NRCC warrants or guarantee the accuracy of the information provided herein and accept no liability for any inaccuracies or improper reliance. Each user should independently verify the regulatory requirements of each relevant jurisdiction. This document does not constitute legal advice and each user should retain counsel of its own choosing before relying on any information contained herein.
Stay ahead of new and emerging regulations with REGTREC™
It’s challenging to keep up with evolving regulations in today’s fast-moving world. REGTREC is designed to help our customers navigate major chemical regulatory requirements of top countries worldwide. Whether expanding your business internationally or monitoring the impact of ever-changing regulations, REGTREC keeps you informed and helps make sure you understand existing and new chemical regulations.
REGTREC provides a single source for up-to-date regulatory content on a broad range of topics, including:
Safety Data Sheet (SDS)
Labels
Product and Substance Registration
Restrictions and Bans
Transportation Requirements
With REGTREC, experienced regulatory specialists can find and monitor country-specific information and provide easy-to-use summaries, helping your business stay compliant.
Features & Benefits
24/7 access to international regulatory requirements
Updates for over 50 countries around the globe
Summary of relevant information to quickly determine the potential impact of regulatory changes
User-friendly portal with easy navigation
Access to the latest regulatory information
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CHEMTREC offers three levels of coverage based on the regional zones of your shipment origins and destinations. REGTREC is included for CHEMTREC customers with Outside Zone or Global coverage. Give us a few details about your shipping practices and we’ll guide you to the right level of CHEMTREC protection.
Are your hazardous material shipping labels meeting the requirements?
Ensuring your product gets where it needs to be safely is a major component of your business. Extra care and legal requirements have to be taken into consideration when shipping hazardous and dangerous materials.
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Get access to CHEMTREC's emergency response number and all the benefits of registration.
By using hazardous materials labels, it is easy to identify what is inside the package. Clear markings from proper hazardous material labels make the storage, handling, and transportation of all hazmat materials simple.
Correct hazmat markings may include a proper shipping name, identification number, technical name, special permit packaging, environmental handling, consignment information, and marine pollutants. In the event of an accident, exposure or chemical spill, the quick identification of hazardous materials is essential to emergency response. Proper handling, cleanup and documentation are easier when there are no guessing games.
Changes to Rules and Regulations
49 CFR 172.406 states labels must be printed on or affixed to a surface (other than the bottom) of the package or containment device containing the hazardous material and be located on the same surface of the package and near the proper shipping name marking, if the package dimensions are adequate.
CHEMTREC’s exclusive approved label supplier, Labelmaster, takes the guesswork out of hazardous materials shipping labels and stays up to date with the latest changes in rules and regulations.
Saving You Time and Money
Our exclusive partnership with Labelmaster makes it easy to get exactly the right hazmat labels for your shipping supplies and products. If you are registered with CHEMTREC you can only purchase CHEMTREC labels through our exclusive approved label supplier, Labelmaster. Labelmaster helps save your company money and time by helping you get the correct labels for your hazmat shipments.
Smaller Lithium Battery Marks May Be Used as of 1/1/2021
CHEMTREC customers can now use the smaller 100mm x 100mm or 100mm x 70mm lithium battery labels. This saves money on the price of the label and also allows the use of smaller packages which can reduce packaging and freight costs. The existing sizes of lithium battery marks will remain compliant in 2021 and beyond.
Labelmaster’s comprehensive offering of industry-leading products helps CHEMTREC customers remain compliant with all dangerous goods regulations. For more than five decades, Labelmaster has been the go-to source for companies — big and small — to navigate and comply with the complex, ever-changing regulations.
CHEMTREC offers three levels of coverage based on the regional zones of your shipment origins and destinations. Give us a few details about your shipping practices and we’ll guide you to the right level of CHEMTREC protection.
CHEMTREC can help your company stay safe and in compliance with our online hazmat training courses. Self-paced, interactive, and comprehensive courses make it easier than ever to stay up-to-date on your required training.
