Over the past several years we have witnessed major amendments to China’s Environmental, Health, and Safety (EH&S) legislation, standards, and regulations. Essentially, China’s regulatory framework is in place and approaching international standards. Environmental Impact Assessments (EIAs) and the Three Synchronies Policy are the primary regulatory instruments used by the State Environmental Protection Administration (SEPA) and local Environmental Protection Bureaus (EPBs) for enforcing environmental regulations and standards, and for requiring pollution control measures for investments and facilities. As a mechanism to promote sustainable development, an EIA is required by law for all industrial or development-related investments in China, including joint ventures and wholly-owned foreign subsidiaries of multinational corporations. Since province-specific requirements are just as important as those issued by SEPA (national), EHS Solutions and EEI Corporation are creating Nine province/city-specific EH&S audit protocols for China: (Each include SEPA, Province and City Requirements)

• Beijing City
• Shanghai City
• Tianjin City
• Jiangsu Province (Nanjing, Suzhou and Wuxi)
• Zhejiang Province (Hangzhou and Ningbo)
• Guangdong Province (Guangzhou and Shenzen)
• Hubei Province (Wuhan City)
• Shandong Province (Jinan, Qingdao and Zibo)
• Liaoning Province (Dalian, Shenyang)
• Sichuan (Chengdu, Chongquing, Yibin, Neijiang)
• Jiangxi (Nanchang, Jiujiang)
• Hong Kong

It should be NOTED that some regions/cities such as Beijing, Shanghai, Guandong, Xiamen, etc. have their own wastewater discharge standards and/or air pollutants discharge standards that are stricter than national standards. Shanghai, Tianjin, Guangdong, and etc. have local Regulations on Safety Production that set specific requirements on number of full-time safety officers within a plant, and set-up of safety committee. Most regions have their own fire-fighting rules and regulations that set some locally specific requirements. Furthermore, some of the Provinces have cities that are allowed to have stricter requirements and the city requirements are appended as well. Thus, all 3 levels of requirements are provided.

In the past, unregulated industrial development has resulted in considerable unrecorded site contamination in China. It is now imperative to conduct a due diligence Environmental Site Assessment and compliance audit at any proposed site, in order to create a baseline profile of environmental conditions prior to the establishment of a proposed facility.

Over the past few years, the Chinese government’s attention to safe production and occupational health issues has increased. This observation is supported by the government’s enactment of two major occupational health and safety statues: The Occupational Disease Prevention and Control Law, enacted in October 2001; and the Safe Production Law, which became effective on November 1, 2002. This Safe Production Law is China’s central law for establishing the requirements for workplace safety.

EEI Corporation with our local auditors from China have prepared these Environmental, Health & Safety audit protocols to assist corporate EH&S managers and supply chain management personnel in the internal auditing process of manufacturing and toll manufacturing facilities in China. They are intended to be used both by corporate EH&S auditors in English, and by the local facilities in Chinese to manage their self-assessment programs with consistency. To meet both objectives, the audit checklists are in both Chinese and English. Since this is an auditing tool against both federal and local requirements, the regulatory citations are included in the respective sections.

For each audit checklist item, both the English and Chinese are presented together in the same section. The intent is to allow local facility personnel who only understand Chinese to work alongside corporate or international auditors who may only speak English. Additional reference information is provided as reference files as they pertain to each audit question. The list of topics and the accompanying list of reference files provide an excellent library of regulatory summaries in itself, outside of strict uses for audits.

The China EH&S Compliance Audit protocols have been developed to assist clients in understanding the comprehensive regulatory requirements of industrial facility operations in that country. Our product offers the following features:

• Regulatory checklists written in both English and Chinese
• Regulatory citations for each of the relevant checklist questions
• If there is no specific regulatory requirement, “GMP” is used to indicate “good management practice”, as practiced in China
• Readily distinguishable Chinese federal and City/Province-specific requirements
• Sections covering the Chinese Environmental and Occupational Health & Safety regulatory framework, enforcement, and future legislation
• Lists of hazardous and regulated chemicals in China
• Audit checklists developed by experienced auditors which are very “user friendly”. They are not just legal jargon or translations of the regulatory text.

• General Information on China
• Environmental Regulatory Framework
• Occupational Health & Safety Regulatory Framework
• Hazardous Chemicals Lists and Standards at SEPA (National) level

• Environmental Management Systems
• General Permitting
• Air Emissions and Pollution
• Waste Management and Recycling
• Water Pollution
• Water Resources and Drinking Water
• Chemical Management and Spill Prevention
• Underground Storage Tanks (UST), Above Ground Storage Tanks (AST) and Other Storage Facilities
• Soil and Groundwater Preservation
• Ozone Depleting Substances
• Transportation and Packaging, Material Safety Data Sheets, and Product Registration
• Polychlorinated Biphenyls (PCBs)
• Asbestos

• Health & Safety Management Systems
• Fire Safety
• Contractor and Construction Safety
• Noise and Vibration
• Machine, Equipment, and In-Plant Safety
• Electrical Safety and Welding
• Confined Space Entry and Permit Work
• Industrial Hygiene
• Medical Surveillance
• Ergonomics and Material Handling
• Ventilation
• Personal Protective Equipment (PPE) and Respiratory Protection