Pre-and Post Event Supervision for EHS Issues in China

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Recently revised regulations concerning EHS compliance in China have decreased pre-event supervision and enhanced post-event supervision and legal liability.  Post-event supervision has increased significantly with fines for the violation of Safety Protection increasing from RMB 50,000 in 2011 to RMB 1000,000 in 2017 and fines for violation of Environmental Impact Assessment increasing from RMB 200,000 to RMB 1,200,000 in 2017. 

The tables below analyze how the administrative procedures have become simpler in Environment, Health and Safety separately.

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Table -1: Administrative procedures before the construction of the project

Evaluation Items Before the Reform After the Reform Reform Year Reference Regulations

(E)
Environmental Impact Assessment

 All environmental impact assessment documents should be approved by administrative departments Just submit the form to the administrative departments for archival purpose 2016
  • Measures for the Administration of Filing the Environmental Impact Registration Form of Construction Projects
  • Law of the People’s Republic of China of Environmental Impact Assessment

(H)
Pre-assessment for Occupational Hazard
  •  The preparation of pre-assessment for occupational hazard should be commissioned to the occupational health technical service institutes with corresponding qualifications
  • Construction projects with ordinary occupational hazards: assessment report should be submitted to work safety departments for archival purpose
  • Construction projects with comparatively severe or severe occupational hazards: assessment report should be applied for approval to work safety departments
  • Companies can do pre-assessment for occupational hazard themselves
  • Filing and approval procedures have been cancelled
 2017 Measures for the Supervision and Administration of ‘Three Simultaneities’ of Occupational Disease Prevention and Control Facilities in Construction Projects

(S)
Pre-assessment for Safety

 National and provincial key construction projects requiring pre-assessment for safety:

  • chemical industry
  • metallurgy
  • nonferrous metals
  • building materials
  • machinery
  • light industry
  • textile
  • tobacco
  • trade
  • military industry
  • highroad
  • water carriage
  • rail transit
  • electric power, etc.
 Significantly fewer construction projects require pre-assessment for safety:

  • metal smelting,
  • chemical industry
 2015 Measures for Supervision and Management on ‘Three Simultaneities’ of Safety Facilities in Construction Projects

 Table-2: Administrative procedures after the construction of the project

Evaluation Items Before the Reform After the Reform Reform Year Reference Regulations
(E)
Acceptance check on environmental protection facility		 Acceptance check on environmental protection facility should be conducted by environmental administrative departments
  • Pollutant discharge license management will replace this acceptance check for construction projects involving pollutant discharge license management system
  • Acceptance check report should be commissioned to a third party for construction projects not involving pollutant discharge license management system
 To be determined Regulations for the Management of Environmental Protection in Construction Projects (Revised Draft for Comments)
(H)
Acceptance check on occupational disease prevention facility
  • Occupational disease hazard control effectiveness assessment should be commissioned to the occupational health technical service institutes with corresponding qualifications
  • Construction projects with ordinary occupational hazards: self-reviewed acceptance check report should be submitted to Work Safety Departments for archival purpose
  • Construction projects with severe occupational hazards: acceptance check should be conducted by Work Safety Departments
  • Occupational disease hazard control effectiveness assessment can be done by the companies themselves but need to prepare a written report on the acceptance check plan
  • Construction projects with ordinary occupational hazards: Companies can conduct the acceptance check on occupational disease prevention facility by themselves
  • Construction projects with severe occupational hazards: a written report for the acceptance check procedure is required
 2017 Measures for the Supervision and Administration of ‘Three Simultaneities’ of Occupational Disease Prevention and Control Facilities in Construction Projects
(S)
Acceptance check on safety facility
  • Following projects should apply to the Work Safety Departments for acceptance check on safety facility:

1. Non-coal mine construction projects

2. Construction projects for producing or storing hazardous chemicals

3. Construction projects for producing or storing fireworks and crackers;

  • Following national and provincial key construction projects should be submitted to the work safety departments for archival purpose:
  •   chemical industry
  •  metallurgy
  • nonferrous metals
  • building materials
  • machinery, etc.
 Companies can conduct acceptance check on safety facility themselves but should prepare a corresponding written report for future review/check by the safety authority. 2015 Measures for Supervision and Management on ‘Three Simultaneities’ of Safety Facilities in Construction Projects

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