Enhancing the regulatory framework for upstream chemicals management in Malaysia: Some proposals from an academic perspective

In 2009, the Department of Environment (DOE) implemented the Environmentally Hazardous Substances (EHS) Notification and Registration Scheme aimed at strengthening upstream chemicals management by first collecting data on chemicals that are either imported to or manufactured in Malaysia. However, we noticed that this voluntary scheme was developed merely to collect data on chemicals and there is no clear roadmap on how the scheme can promote the regulatory framework for upstream chemicals management. As responsible academics concerned about chemicals management, we took the initiative to analyse the EHS Notification and Registration Scheme, and identified the critical features in the regulatory framework that need to be enhanced. In this paper, we elaborate on the EHS definition, and propose the term Environmentally Hazardous Chemicals (EHC) to replace EHS in the context of chemicals management. The intrinsic properties of the EHC that are in line with the GHS (Globally Harmonized System of Classification and Labelling of Chemicals) have been identified in this paper. We also propose a systematic approach to regulating chemicals which will also be capable of meeting the demands of chemical related conventions such as the Basel, Rotterdam, Stockholm and Minamata Conventions.