TDI should not be included in the "comprehensive list of environmental protection"?

Toluene diisocyanate TDI should not be included in the "comprehensive list of environmental protection"? Here is the reply from mailbox of  the minister of environmental protection...

Letter from industry:

TDI was included in high-risk products, the industry had presented object, but was not adopted, now directly report to the Minister:

1, TDI is the key raw material of polyurethane (PU), the application fields are irreplaceable and involve people's livelihood, the manufacturing technology is complex and only a few companies in the world have mastered.

2. TDI itself is not a product of high environmental risk. It is a common knowledge that in 2015 "Dangerous Chemical Substances List" TDI is not highly toxic already. In 2017, TDI is removed from "Inland Water forbidden Transport Chemicals"(draft), which is protocolled by four ministries and commissions.

3. TDI industrialized only by phosgenation method, there is no alternative route, the industry is highly concentrated, in China there are 6 enterprises (4 domestic and 2 overseas), advanced international even leading production equipment, risk is controllable.

4, China continuously implements incentive policies of isocyanate:

1) TDI, MDI: NDRC and MOFCOM “Guiding Catalog of Foreign Investment Industries” encouragement (02,05 Edition);

2) Production technology of 100,000 tons / year TDI products (200,000 tons / year toluene nitration and DNT hydrogenation) Development and Reform Commission, Ministry of Finance and Ministry of Commerce, "Encourage Import Technology and Product Catalog" (09,11,14 Edition).

3) Homologues of aliphatic isocyanates (phosgenation HDI, IPDI, HMDI) NDRC "Guiding Catalog of Industrial Structure Adjustment" (Revised 11, 13), "Three-year Action Plan for Increasing Manufacturing Core Competitiveness (2018-2020) "encouragement.

5. the preparation of the new explanation for the reasons "Third, in recent years triggered more unexpected environmental events of high environmental risk products, such as (TDI)." Seriously inconsistent with the facts, without any basis.

Reply from mailbox of  the minister of environmental protection:

We include tolylene diisocyanate (TDI) as a high environmental risk product in the "Environmental Protection Consolidated Directory (2017 Edition)" based on the following considerations:

1. TDI itself has high environmental risk. In April 2014, the "Guidelines for Risk Assessment of Environmental Emergencies in Enterprises (for Trial Implementation)" (Circular No. 34 [2014]) issued by the Ministry of China contained the TDI (critical quantity is 5 tons).

2.TDI involved in the production process a large number of high-risk substances. Some raw materials used in the production process of TDI, some intermediate products, by-products and final products are produced, which are toxic, flammable and explosive. Among these substances, phosgene, tolylenediamine, dinitrotoluene and diaminotoluene are all included in the "List of Hazardous Chemicals (2015 Edition)" jointly issued by the General Administration of Customs, the MEP and other departments (Safety Supervision Administration Announcement 2015 No. 5).

3. TDI manufacturing enterprises have caused serious environmental pollution before. For example, on May 11, 2007, an explosion occurred at the TDI workshop nitrification unit of China National Chemical Corporation Cangzhou Dahua TDI Co., Ltd., killing 5 people and injuring 80 people, evacuating thousands of people in the nearby village, while causing a large number of pollutants leaked.

During the process of formulating the "Comprehensive List of Environmental Protection (2017 Edition)", the Ministry of Agriculture extensively solicited opinions from all quarters and organized experts in such fields as environmental protection to conduct special studies on opinions.

Next, we will combined with the "Directory of Environmental Protection (2017 version)" to help the relevant departments to formulate relevant environmental economic policies. In the process, we will make overall consideration of the environmental risk prevention and control of various high-risk products listed in the catalog and the need for sustainable and healthy development of related industries. We will actively and steadily promote the formulation and implementation of relevant policies.