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One Nation, One Chemical Policy: The Case for a Unified, Risk-Aligned Chemical Governance Framework in India
Category : Critical Sectors Specifics
Sub Category : Chemical & Allied Industries
Author(s) : Dr. Padmalochan DASH
Article Keywords : One Nation One Chemical Policy, unified chemical governance, Chemical Management and Safety Rules (CMSR), National Chemical Centre, Bharat National Resilience Index (BNRI), Critical Infrastructure Protection Act (CIPA), digital chemical registry and traceability, risk-based lifecycle regulation, chemical industrial disaster management, dual-use chemicals and national security

India’s chemical sector has entered a phase where industrial expansion, global compliance pressures, and national security obligations intersect, exposing the limitations of a fragmented, multi-rule regulatory inheritance that evolved after industrial disasters and incremental policy responses rather than through a unified governance doctrine (MSIHC-Rules, 1989; CA-EPPR, 1996; NDMA, 2019). The sector contributes to pharmaceuticals, petrochemicals, specialty chemicals, defence manufacturing, and export-driven industrial value chains, yet operates without a central statute, integrated licensing regime, or traceability-backed oversight system aligned to international regulatory models such as EU REACH, TSCA reforms, K-REACH, or AICIS frameworks (IBEF, 2023; REACH, 2006; TSCA-EPA, 1976; K-REACH, n.d.; AICIS, n.d.). The proposed policy establishes a unified national governance architecture integrating statutory mandates under a consolidated framework, a national digital chemical registry, BNRI-linked resilience scoring, lifecycle compliance controls, single-window licensing, and a CIPA-aligned enforcement hierarchy capable of addressing dual-use risks, cyber-physical manipulation, hazardous logistics chains, and disaster vulnerability within chemical infrastructure systems (CMSR, n.d.; CERT-IN, n.d.; CISA-CFATS, 2007; BAPI-CIPA, 2025; BAPI-BNRI, 2025). Hazard oversight, industrial safety, precursor tracking, storage verification, and high-risk transport are reframed as regulated national continuity functions rather than procedural compliance obligations, ensuring traceability, control, accountability, and interoperability across federal and state authorities through the proposed National Chemical Centre acting as an apex statutory institution (DCPC, n.d.; NACWC, n.d.; NDMA, 2019). The implementation roadmap adopts a phased transition approach where policy notification, registry activation, licensing convergence, enforcement tiering, and global harmonisation evolve into a unified national operating model supported by IoT-based monitoring, QR-enabled movement governance, SCADA cybersecurity, and AI-powered anomaly detection for high-hazard installations (ICRH-CMSR, n.d.; REACHLaw, n.d.; OPCW, 2021). Compliance is measured through a BNRI-based scoring framework that determines facility status, inspection cadence, export eligibility, and enforcement escalation under a national penalty and shutdown ladder linked to CIPA oversight jurisdiction and dual-use monitoring protocols (PCPIR-Policy, 2007; CMP, n.d.; BAPI-CIPA-Legis, 2025). The framework positions chemical regulation as a core national security, economic competitiveness, and public safety mandate, establishing India’s chemical ecosystem as a digitally governed, resilience-aligned, legally enforceable, internationally interoperable system capable of safeguarding industrial growth, community safety, and sovereign control of high-risk chemical assets.

Introduction:


I. Executive Context and Policy Rationale

India’s chemical sector is positioned at a point where industrial expansion and regulatory responsibility now collide. The sector spans pharmaceuticals, petrochemicals, specialty chemicals, agrochemicals, fertilisers, solvents and dual-use industrial precursors supporting national defence production. It is one of the fastest growing components of the national manufacturing base and contributes significantly to export competitiveness and foreign market penetration (IBEF, 2023). Industrial growth has accelerated rapidly, while the regulatory ecosystem governing chemical manufacturing, transport, handling, lifecycle management and disposal remains uneven, fragmented and operationally inconsistent across states (Enhesa, n.d.; NDMA, 2019).

Recognition of this fractured regulatory landscape began more than a decade ago. The Draft National Chemical Policy acknowledged regulatory duplication, poor institutional clarity, insufficient standardisation of industrial safety practices and the absence of a national-level chemical registry or unified compliance backbone (NCP-Draft, 2012; DCPC, n.d.). Independent industry bodies and export councils echoed the same concerns and noted the need for globally comparable oversight systems capable of supporting innovation, risk transparency and environmental safeguards (CHEMEXCIL, 2015).

Much of the existing compliance environment still relies on legacy legal instruments. The Manufacture, Storage and Import of Hazardous Chemical Rules, 1989, framed to the purview of the Environment (Protection) Act, remain foundational but outdated in hazard classification methodology. The instrument depends on threshold quantities and high-level compliance triggers rather than a lifecycle and risk-based approach suited to contemporary industrial scale (MSIHC-Rules, 1989). A second framework, the Chemical Accidents (Emergency Planning, Preparedness and Response) Rules, 1996, introduced district crisis groups, mandatory emergency planning and minimum reporting requirements following the Bhopal disaster (CA-EPPR, 1996); however, implementation remains inconsistent across states, and regulatory enforcement capacity varies widely, particularly in high-density chemical clusters (NDMA, 2019; NITI-Aayog, n.d.).

A modern regulatory path emerged with the Chemicals (Management and Safety) Rules, often referred to as India-REACH. The proposal aligns with international frameworks such as REACH (2006) and includes registration obligations, safety reporting, hazard classification, substance notification and a national inventory system for all chemicals manufactured or imported in India (CMSR, n.d.; REACHLaw, n.d.). Despite extensive consultation and technical reviews, the rules remain unsigned and unenforced at the national level (ICRH-CMSR, n.d.). Regulatory uncertainty persists and industry continues operating between legacy frameworks and proposed modern compliance expectations without formal legal enforcement.

With a draft policy still unadopted, legacy rules still functioning and a modern regulatory model awaiting notification, India’s chemical governance remains structurally incomplete (NCP-Draft, 2012; CMSR, n.d.; DCPC, n.d.). The result is duplication of reporting burdens, jurisdiction overlap between union and state authorities, an absence of a national chemical registry and significant variation in interpretation of compliance standards (Enhesa, n.d.). That fragmentation increases the likelihood of non-compliance, introduces barriers to export markets governed by strict ESG and safety requirements, and exposes the system to avoidable chemical hazards and long-tail environmental liabilities.

The current trend suggests that, global policy environments are shifting toward traceability, cybersecurity integration, chemical-security surveillance and ESG-linked enforcement. International frameworks such as OPCW chemical security norms and CFATS compliance under the United States Homeland Security regime illustrate the global policy direction where chemical governance to remain inseparable from industrial safety, disaster management and national security (OPCW, 2021; CISA-CFATS, 2007). At the same time, domestic regulatory expectations now increasingly demanding to include digital traceability, sector interoperability and cyber-physical risk control across hazardous industrial ecosystems (CERT-IN, n.d.; NDMA, 2019).

A unified national chemical policy, therefore, now becomes a structural necessity. Industrial competitiveness, supply chain continuity, export market access, critical infrastructure safety and environmental protection require a single national governance framework aligned with risk classification, lifecycle oversight and enforceable compliance accountability. Without unified system architecture and regulatory standardisation, India risks stagnation at a regulatory threshold that no longer meets domestic or international expectations (PCPIR-Policy, 2007; CMP, n.d.).

II. Strategic Vision Statement

India’s national vision for chemical governance must evolve into a unified and enforceable compliance ecosystem that operates on lifecycle risk, digital traceability, enforceable accountability, and national security alignment (NITI-Aayog, n.d.; NDMA, 2019). The purpose of such a governance structure is to establish a chemical system that is safe, controlled, transparent, interoperable, scientifically classified, and aligned with sovereign capability targets tied to national industrial and security priorities (DCPC, n.d.).

Chemical manufacturing forms the structural base of several high-value national industries including defence systems, pharmaceuticals, energy production, agrochemical inputs, polymers, and advanced materials. Independent economic estimates indicate the sector’s expansion trajectory and its projected valuation of approximately USD 304 billion, positioning it as a core driver of India’s industrial and export ecosystem (IBEF, 2023).

Safety is a foundational element of the vision. The Bhopal Gas Disaster of 1984 and the Visakhapatnam LG Polymers leak in 2020 remain systemic reminders of gaps in oversight, classification, industrial preparedness, and compliance enforcement capacity. These events exposed critical weaknesses in emergency readiness, monitoring systems, and state-level accountability obligations (MSIHC-Rules, 1989; CA-EPPR, 1996; NDMA, 2019; G.A.D-HPC-GoAP, 2020). They also confirmed that chemical governance cannot rely solely on voluntary industry adoption or reactive enforcement and requires a preventive posture grounded in risk classification, digital reporting, and institutional preparedness frameworks (CERT-IN, n.d.).

Traceability and transparency define the next requirement in the strategic vision. International market access now depends on digital chemical identity records, verified hazard communication, lifecycle documentation, and inventory-level reporting across manufacturing and import pathways (REACH, 2006). The proposed Chemicals (Management and Safety) Rules signal this transition by requiring registration of all manufactured or imported substances, risk assessment data, hazard disclosure, and compatibility with global chemical safety frameworks (CMSR, n.d.; REACHLaw, n.d.; ICRH-CMSR, n.d.; CMP, n.d.).

Environmental sustainability is embedded as a regulatory obligation rather than a discretionary objective. India’s commitments under the Paris Agreement, NAPCC, and UNFCCC require integration of low-emission manufacturing, safe handling of persistent substances, circular chemical management, and strict hazardous material controls (Enhesa, n.d.; NDMA, 2019). Future manufacturing environments must prevent legacy contamination, eliminate uncontrolled disposal practices, and incorporate scientific controls across waste, transportation, and process safety systems.

Sovereign capability forms another dimension of the vision. Dual-use precursors, defence-linked chemicals, and sensitive intermediates increasingly influence geopolitical leverage and strategic supply chain security. India holds treaty obligations under the Chemical Weapons Convention and maintains national monitoring authority responsibilities through NACWC to prevent diversion, misuse, and unlawful proliferation of regulated substances (NACWC, n.d.; OPCW, 2021).

The strategic vision for a One Nation, One Chemical Policy positions chemical governance as a national compliance architecture that integrates industrial growth, regulatory enforcement, material traceability, emergency readiness, and geopolitical responsibility. It aligns with national industrial policies including petrochemical investment regions and creates the legal basis for uniform enforcement and globally consistent registration systems that reduce compliance ambiguity and industry fragmentation (PCPIR-Policy, 2007; CMSR, n.d.; CHEMEXCIL, 2015; CISA-CFATS, 2007).

III. Policy Mandate Justification

India’s chemical industry operates as a primary feedstock system for pharmaceuticals, petrochemicals, fertilizers, textiles, defence production, agriculture, construction, semiconductors, industrial solvents, polymers, and electronics manufacturing (IBEF, 2023; DCPC, n.d.). IBEF records more than 80,000 commercial chemicals and derivatives active in domestic and export-facing industrial chains. This scale creates a structural dependency on chemical inputs where weak regulation or fragmented oversight rapidly converts into systemic exposure affecting health, environment, industrial continuity, and national capability (Enhesa, n.d.; NDMA, 2019).

Pharmaceutical manufacturing depends on sensitive intermediates and active pharmaceutical ingredient precursors that are often imported and controlled in international markets, particularly those sourced from China. The Standing Committee on Chemicals and Fertilizers documented this dependency and warned that domestic vulnerability affects healthcare access and defence-linked industrial autonomy if supply shocks occur (Government of India, 2020; CMSR, n.d.; ICRH-CMSR, n.d.). Fertilizer manufacturing relies on ammonia, nitrates, phosphates, and urea. These substances fall under global risk-regulated commodity regimes due to blast potential, environmental persistence, or dual-use relevance (CMP, n.d.; REACH, 2006; K-REACH, n.d.). Defence-related manufacturing remains governed under Chemical Weapons Convention compliance, with NACWC responsible for oversight of Schedule chemicals and monitoring of sensitive transfer pathways (NACWC, n.d.; OPCW, 2021).

Fragmentation across authorities, rules, and compliance expectations introduces operational inconsistency, uneven enforcement, regulatory uncertainty, and duplicated reporting obligations (NITI-Aayog, n.d.). NDMA assessments and industry-facing compliance analyses have repeatedly noted that enforcement capacity varies, state interpretation of hazardous chemical oversight is inconsistent, and regulatory auditing remains underdeveloped relative to industry scale and complexity (NDMA, 2019; Enhesa, n.d.). During the COVID-19 emergency, these weaknesses became visible when chemical supply chains for disinfectants, oxygen compression cylinders, solvents, and pharmaceutical precursors experienced disruption and bottlenecks created by unclear regulatory pathways rather than physical scarcity (CERT-IN, n.d.; CHEMEXCIL, 2015).

Evidence of compliance failure is already documented through catastrophic industrial events. The Bhopal Gas Disaster remains a global reference point in chemical governance failure. It demonstrated that classification weaknesses, poor monitoring, unclear oversight authority, and non-existent emergency frameworks create lethal consequences measured in deaths, chronic illnesses, long-term groundwater contamination, and irreversible community exposure (MSIHC-Rules, 1989; CA-EPPR, 1996; NDMA, 2019). The 2020 Visakhapatnam styrene leak inquiry noted inadequate storage protocols, missing compliance documentation, software bypasses in monitoring equipment, and outdated risk assessment benchmarks (G.A.D-HPC-GoAP, 2020).

The existence of the Draft National Chemical Policy and associated working group documentation confirms formal recognition of governance fragmentation. These national documents highlight the systemic absence of a unified registry, misplaced institutional accountability, and limited alignment with international chemical management frameworks (NCP-Draft, 2012; DCPC, n.d.). The proposed Chemicals (Management and Safety) Rules reflect an attempt to address traceability, lifecycle reporting, risk classification, inventory creation, and global equivalence obligations comparable to REACH, CFATS requirements, and modern ESG-linked compliance expectations (CMSR, n.d.; REACHLaw, n.d.; CISA-CFATS, 2007).

The PCPIR framework positions chemical governance as a strategic economic and industrial component requiring regulatory certainty and uniform enforcement to maintain competitiveness in global trade environments (PCPIR-Policy, 2007). The absence of a unified governance regime prevents domestic standardisation, weakens industry compliance posture, increases accident risk, delays export approvals, and sustains dependence on external regulatory benchmarks rather than sovereign compliance architecture (CMP, n.d.; REACH, 2006).

Keeping these in perspectives, the proposed “One Nation, One Chemical Policy” approach serves as a mandatory compliance requirement for operational stability, strategic autonomy, public safety, and national resilience, supported by current sectoral scale, global regulatory pressures, and documented oversight failures (IBEF, 2023; NDMA, 2019).

IV. BNRI-Aligned Framework for the Policy Prescription: from the Global Best Practices

 

1. Technological Priorities

Strengthening India’s chemical governance requires regulatory design that embeds scientific evidence, process safety engineering, digital oversight systems, and innovation-driven compliance mechanisms into formal rulemaking and enforcement practice (NDMA, 2019; CERT-IN, n.d.). The Draft National Chemical Policy identified research capacity, compliance infrastructure, and technology upgradation as essential elements to shift India from operational fragmentation toward a verified, science-based governance model (NCP-Draft, 2012; CHEMEXCIL, 2015). The draft text also identified the need to accelerate indigenous capability in high-value molecules, analytical instrumentation, toxicology platforms, and certification systems that reduce import reliance and create controlled domestic supply chains for regulated precursors (CHEMEXCIL, 2015; DCPC, n.d.).

The Department of Chemicals and Petrochemicals outlines statutory and regulatory responsibilities including policy steering, industrial safety frameworks, and programmatic enablement for innovation adoption and regulatory uniformity across regions (DCPC, n.d.). This institutional mandate reinforces a national requirement to modernise the chemical sector and transition compliance to scientifically validated norms compatible with international frameworks (NITI-Aayog, n.d.; NDMA, 2019).

International regulatory systems demonstrate that advanced chemical governance requires digital chemical identity systems, risk scoring models, and lifecycle-based oversight. Under the EU REACH Regulation, chemical producers must submit full technical dossiers, exposure models, hazard classifications, and risk communication artefacts to European Chemicals Agency systems before market access is permitted (REACH, 2006; EC-IndustrialSafety, n.d.). The United States operates under TSCA Compliance where the Environmental Protection Agency requires quantitative structure-activity relationship data, toxico-kinetic evaluations, and chemical screening models before commercialisation (TSCA-EPA, 1976; CISA-CFATS, 2007). These systems demonstrate a compliance culture where chemical governance is inseparable from documented scientific evidence and transparent accountability architecture.

India’s proposed Chemicals (Management and Safety) Rules reflect elements of this model, including registration, hazard disclosure, adverse effects reporting, and chronic toxicity documentation requirements (CMSR, n.d.; REACHLaw, n.d.). Technical support ecosystems such as the Indian Chemical Regulation Helpdesk have confirmed pre-regulatory guidance and industry preparedness efforts, although the legal framework remains pending notification (ICRH-CMSR, n.d.).

A compliance-aligned technological roadmap requires clear benchmarks that reflect proven international models and enforce mandatory system adoption across public and private chemical infrastructure:

Priority Area

Best-Practice Reference Model

Required Direction in India

National digital chemical inventory

EU REACH and Australian AICIS

Establish a legally binding national chemical registry

Scientific hazard classification

UN Globally Harmonised System (GHS)

Full institutional adoption with multilayer state enforcement

Movement traceability and compliance audits

Japan CHRIP

QR-coded movement systems with real-time verification

Innovation and applied testing networks

Fraunhofer research networks

National R&D parks linked with CSIR systems and industry

Table 1: Compliance-aligned Technological Roadmap

India holds a scientific base through institutions such as CSIR, NCL Pune, and IICT Hyderabad. These bodies maintain strong research capability but most likely remain functionally isolated from national compliance systems, with limited standardisation of toxicology data pipelines, test methodology accreditation, and regulatory feedback loops.

It is proposed that, the One Nation, One Chemical Policy must treat technological capability as a national compliance obligation. This requires a systemic shift where regulatory alignment is built on measurable scientific outcomes rather than advisory guidance or voluntary adoption models. Policy direction must include:

A national research and capability roadmap for strategic, dual-use, and high-value chemicals

Digital and AI-enabled hazard identification, exposure modelling, and audit systems

Accreditation and continuous upgrade of testing infrastructure tied to national credentialing standards

System-level alignment with global scientific compliance frameworks including REACH, TSCA, GHS, and CWC oversight structures.

 

2. Cyber-Driven World Order

Chemical regulation now operates inside a digitally governed compliance ecosystem where cyber integrity, verified traceability, and data-based oversight determine regulatory credibility and international trade eligibility (CERT-IN, n.d.; NDMA, 2019). Chemical governance is no longer limited to inspections, physical audits, or hazard declarations. The modern framework relies on authenticated digital submissions, real-time data capture, cybersecurity safeguards, and continuous monitoring of chemical identities and their movements, particularly across high-risk and dual-use supply chains (EC-IndustrialSafety, n.d.; OPCW, 2021).

India’s transition toward the Chemicals (Management and Safety) Rules reflects this shift. CMSR requires digital submission of hazard profiles, concentration thresholds, toxicology data, and classification documentation, similar to the structured compliance architecture mandated under the European Union REACH regime (CMSR, n.d.; REACHLaw, n.d.; REACH, 2006). Advisory bodies such as the Indian Chemical Regulation Helpdesk confirm that mandatory digital filings and electronic classification workflows are part of the intended system design, indicating a shift toward auditable and machine-validated compliance pathways that eliminate undocumented or unverifiable chemical movement (ICRH-CMSR, n.d.; NITI-Aayog, n.d.).

Globally, digital regulatory ecosystems already operate at scale. Under EU REACH, the European Chemicals Agency maintains a continuously updated public digital repository containing substance dossiers, hazard evaluations, supply chain disclosures, toxicological records, and industrial use classifications (REACH, 2006). The platform functions as a regulatory identity system where compliance status is confirmed through structured digital evidence rather than self-declarations or paper filings (EC-IndustrialSafety, n.d.; CMP, n.d.).

Australia’s AICIS model functions in a similar digitally structured format. Manufacturers and importers must generate electronic notifications, pre-market classification documents, and risk declarations before placing chemicals onto Australian supply chains (AICIS, n.d. (1); AICIS, n.d. (2)). The United States introduced digital enforcement under the Toxic Substances Control Act using mandatory electronic submissions through the EPA Central Data Exchange. TSCA compliance now requires standardised digital reporting and retention of exposure data, hazard characterisation, and lifecycle documentation (TSCA-EPA, 1976; CISA-CFATS, 2007).

Unlike these jurisdictions, India does not yet maintain a unified national digital registry for chemicals (CMSR, n.d.; DCPC, n.d.). Current reporting requirements are dispersed across state pollution control systems, hazardous waste portals, import licensing modules, and disconnected compliance portals that do not interface with a central risk intelligence framework (Enhesa, n.d.; NITI-Aayog, n.d.). The Visakhapatnam styrene leak inquiry noted inconsistent safety records, outdated hazard data, and incomplete digital filing integrity, indicating that the absence of unified cyber governance contributed to delayed response and avoidable exposure escalation (G.A.D-HPC-GoAP, 2020; NDMA, 2019).

A credible regulatory blueprint for India requires mandatory cyber governance integration consistent with global standards (CMSR, n.d.; PCPIR-Policy, 2007; CHEMEXCIL, 2015). The following frameworks illustrate applicable compliance direction:

Global Reference

Core Digital Mechanism

Relevance to India

EU REACH

Digital registration and mandatory database disclosure

Basis for national registry and public traceability

U.S. TSCA (post-reform)

Mandatory electronic safety filings and screening

Enables structured audit and enforcement

AICIS

Digital risk-based substance categorisation

Supports scalable compliance models

Japan CHRIP

Searchable national hazard and exposure information

Enables public transparency and emergency access

Table 2: Core Digital Mechanism applicable compliance direction Relevance to India

Therefore, a cyber-regulated chemical governance system for India must include:

• A National Chemical Digital Registry consolidating classification, hazard data, licensing information, and compliance submissions

QR-enabled chemical tracking across ports, bonded warehouses, hazardous clusters, and inland supply chains

SCADA-linked industrial safety monitoring for high-risk chemical facilities with automated system alerts and supervisory access for regulators

AI-based compliance risk scoring capable of identifying high-probability industrial violations, unregistered substances, or dual-use activity anomalies

Secure integration with CERT-IN protocols to protect chemical datasets from tampering, data leaks, cyber sabotage, or transnational proliferation risks

 

At this point, it is clear that compliance strength in a cyber-regulated environment is determined by the integrity of digital evidence, not by paperwork, declarations, or fragmented reporting. A One Nation, One Chemical Policy must embed digital oversight at its core to ensure global compatibility, secure supply chains, strengthen preparedness, and protect operational safety across the chemical ecosystem.

 

3. Economic and Business Technicalities

The economic justification for a unified chemical governance framework is tied to India’s current role and projected scale in global chemical markets. India is documented as the sixth largest global chemical producer and the third largest in Asia, with forecast growth to approximately USD 304 billion by 2025 driven by pharmaceuticals, petrochemicals, agrochemicals, and specialty chemical segments (IBEF, 2023). Despite this positioning, the compliance environment remains fractured across ministries, overlapping legal instruments, and heterogeneous state-level approval pathways. This fragmentation increases operational cost, disrupts regulatory predictability, and weakens export eligibility in high-regulation markets (Enhesa, n.d.; CMSR, n.d.).

The Petroleum, Chemical and Petrochemical Investment Regions initiative illustrates both ambition and operational gaps. PCPIR was designed to establish large-scale industrial corridors with shared utilities, logistics systems, regulatory support, and infrastructure comparable to global models such as Jurong Island in Singapore and Jubail Industrial City in Saudi Arabia. The DCPC confirms this mandate through published guidelines and official documentation. However, NITI Aayog and sectoral assessments record persistent delays in permitting, state-level coordination failures, and absence of an integrated compliance interface that could provide single-window regulation or lifecycle approvals (NITI-Aayog, n.d.; NDMA, 2019).

Industry-level compliance assessments reinforce these systemic inefficiencies. A regulatory analysis from Enhesa identifies multiple business impacts directly resulting from India’s non-harmonised compliance structure, including increased audit labour, extended certification timelines, registration delays, and reduced acceptance in global markets governed by digital compliance ecosystems or lifecycle chemical disclosure requirements (Enhesa, n.d.); and the CMSR analysis highlights that, if this is operationalised, it would help a lot in reducing compliance ambiguity and improve India’s position in global regulatory equivalence pathways (CMSR, n.d.; REACHLaw, n.d.).

Globally, markets with unified governance demonstrate cost reductions, predictable approval timelines, and improved export access. EU REACH offers a reference model where structured compliance requirements and digital traceability reduced unknown toxic releases, improved investor confidence, and supported innovation financing (REACH, 2006). South Korea’s K-REACH and Canada’s Chemicals Management Plan demonstrate similar legislative outcomes, where harmonisation increased compliance transparency and reduced product rejection risk in regulated trade zones (K-REACH, n.d.; CMP, n.d.; NITE-CHRIP, n.d.). These examples demonstrate that regulatory consolidation is not a soft governance preference but an economic performance variable also.

Under a One Nation, One Chemical Policy, priority economic outcomes must align of regulation with competitiveness requirements; and, business continuity obligations must integrate with compliance architecture. Key directional requirements include:

Policy Axis

Expected Economic Outcome

Reference Models

Unified regulatory compliance regime

Lower transaction cost and reduced approval timelines

EU REACH, K-REACH

Infrastructure clustering with standardised regulatory support

Reduced CAPEX and scalable capacity

PCPIR framework, Jurong Island

Export certification certainty

Reduced non-tariff barrier exposure and improved trade access

CMP, US TSCA reforms

Incentivised innovation with compliance accountability

Domestic value chain expansion and reduced import dependence

German chemical research cluster model

Table 3: Policy–Economy Alignment Matrix

 

The current landscape makes it evident that global trade is now driven by non-tariff compliance triggers such as traceability, ESG reporting, dual-use controls, and lifecycle chemical disclosure. India’s fragmented compliance architecture creates avoidable risk and weakens strategic advantage. A unified national policy brings predictability, improves export eligibility, lowers regulatory disputes, and positions India as a rule-compliant chemical economy instead of a compliance-dependent exporter.

 

4. Disaster Management

Disaster management forms a structural compliance function in chemical governance in India because the country continues to record avoidable industrial accidents and hazardous substance events across multiple states and industrial clusters (NDMA, 2019; MSIHC-Rules, 1989). The Manufacture, Storage and Import of Hazardous Chemicals Rules require threshold-based hazard classification, on-site and off-site emergency planning, safety audits, mock drills, and configuration of District and Local Crisis Groups (MSIHC-Rules, 1989; CA-EPPR, 1996). These mechanisms originated as post-Bhopal corrective controls and were recognised in comparative regulatory assessments including technical guidance recorded under Japan’s NITE platforms that summarise India’s statutory obligations for hazardous chemical preparedness (NITE-CHRIP, n.d.).

Despite these statutory requirements, India continues to experience high-impact chemical incidents. The Visakhapatnam styrene event in 2020 resulted in fatalities, severe exposure injuries, and mass evacuation. The official High-Powered Committee investigation identified absence of predictive maintenance systems, non-functional monitoring equipment, and gaps in emergency coordination as aggravating variables that delayed response mobilisation and increased toxic exposure (G.A.D-HPC-GoAP, 2020; NDMA, 2019). The incident confirmed that compliance requirements under MSIHC and CA-EPPR had not transitioned into operational discipline or digital readiness.

Comparable failures are reflected in other events. The Jaipur IOC depot explosion in 2009, the Bhilai Steel Plant gas release in 2014, and repeated hazardous waste fires across Maharashtra between 2019 and 2023 indicate a repeating pattern of vulnerability, particularly in petrochemical corridors and storage zones located near dense population clusters (CMSR, n.d.; Enhesa, n.d.; NDMA, 2019). NDMA technical guidance reports recommend adoption of digital hazard mapping, interoperable emergency command systems, and SCADA-supported real-time monitoring for high-risk sites where chemical inventory volumes or reactivity profiles present escalation potential (NDMA, 2019; CERT-IN, n.d.).

Global frameworks illustrate the maturity expected from a modern compliance-based disaster architecture:

Country / System

Core Mechanism

Policy Relevance

EU Seveso Directive integrated with REACH (Seveso-III, 2012; REACH, 2006; EC-IndustrialSafety, n.d.)

Mandatory hazard zoning, public disclosure protocols, cross-border emergency coordination

Basis for public safety transparency, zoning laws, and interoperable emergency response

United States EPA RMP combined with CFATS (TSCA-EPA, 1976; CISA-CFATS, 2007)

Vulnerability analysis, mandatory incident reporting, tiered oversight linked to national security

Template for surveillance of dual-use chemicals and high-hazard industrial hubs

Japan CHRIP and hazardous accident framework (NITE-CHRIP, n.d.)

Scientific hazard database with structured reporting and regulatory update cycles

Evidence of value in centralised scientific hazard intelligence

Australia AICIS digital monitoring (AICIS, n.d. (1); AICIS, n.d. (2))

Incident notification tied to regulatory compliance and export eligibility

Reference for compliance automation and audit capability

Table 4: Global Models for Chemical Risk Governance

These systems demonstrate how disaster governance is strengthened when compliance obligations are digitally evidenced, continuously validated, and risk-scored. Under Seveso-III, facilities handling specific hazard classifications must maintain public risk disclosure, periodic emergency audits, and cross-jurisdiction response capability (Seveso-III, 2012; EC-IndustrialSafety, n.d.). In the United States, the Toxic Substances Control Act and the EPA’s Risk Management Programme require hazard modelling, exposure forecasting, and documented mitigation plans for accident-prone installations (TSCA-EPA, 1976; CISA-CFATS, 2007).

Alignment with these models requires enforceable system architecture in India that includes:

A single national hazardous chemical digital inventory with regulator-controlled access

IoT-enabled monitoring layers at high-volume and high-reactivity installations

Periodic simulation drills coordinated at state and national levels tied to CMSR compliance reporting

Interoperable command and control systems for industrial clusters, ports, SEZs, and supply-chain nodes

Public safety information triggers equivalent to Seveso-III notification levels for high-risk installations

National-level integration with CERT-IN to prevent cyber-intrusion targeted at safety-critical systems

 

The regulatory direction makes it clear that a unified mechanism under a One Nation, One Chemical Policy provides the control environment needed for enforceable oversight, coordinated emergency response, and real-time governance of hazardous installations identified through industrial zoning, petrochemical clusters, and PCPIR systems (PCPIR-Policy, 2007; NDMA, 2019).

 

5. Legal and Statutory Provisions

India’s legal framework for chemical regulation developed in response to industrial expansion, public health exposure, environmental externalities, and global compliance demands (NDMA, 2019; Enhesa, n.d.). The system is currently distributed across multiple rules, ministries, and regulatory entities, creating overlapping mandates, interpretive gaps, and fragmented compliance expectations for industry and regulators (CMSR, n.d.; MSIHC-Rules, 1989; CA-EPPR, 1996). The absence of a unified statutory framework reinforces regulatory inconsistency and hinders standardisation across production, storage, transportation, import, export, and end-of-life disposal (NITI-Aayog, n.d.; DCPC, n.d.).

The Chemicals (Management and Safety) Rules represent the most significant legal transition in India’s chemical governance structure (CMSR, n.d.). Regulatory analyses confirm that CMSR is intended to function as a single, comprehensive framework capable of replacing legacy rules such as MSIHC and the Chemical Accidents Rules, while introducing structured mechanisms including mandatory registration of chemical substances, hazard classification aligned to the UN GHS system, safety data submission, and regulatory accountability for both importers and domestic producers (MSIHC-Rules, 1989; CA-EPPR, 1996; REACHLaw, n.d.; ICRH-CMSR, n.d.).

The rationale for legal consolidation has been formally acknowledged. The Draft National Chemical Policy and Working Group deliberations under the Planning Commission documented the need for an overarching national statute that harmonises compliance pathways and reduces multiplicity of regulatory touchpoints (NCP-Draft, 2012; CHEMEXCIL, 2015). These policy outputs identify statutory fragmentation as a structural driver of enforcement weakness, supply chain vulnerability, and compliance burden.

Internationally, consolidated legislation defines the compliance architecture. The European Union operates under a unified legal regime through the REACH Regulation, combining registration requirements, chemical assessment protocols, authorisation sequences, and restriction mechanisms in a single instrument (REACH, 2006). South Korea’s K-REACH and the revised United States Toxic Substances Control Act demonstrate how legislative consolidation strengthens enforcement tools, improves transparency, aligns domestic industry with global trade expectations, and reduces regulatory confusion (K-REACH, n.d.; TSCA-EPA, 1976; CMP, n.d.; CISA-CFATS, 2007).

India’s enforcement ecosystem reflects why this transformation is necessary. Regulatory outcome variability across states, inconsistent licensing pathways, and limited uniformity in compliance monitoring have resulted in uneven application of legal mandates (NDMA, 2019; Enhesa, n.d.; DCPC, n.d.). NDMA guidance references multiple instances where statutory ambiguity contributed to non-compliance, reduced preparedness, and weak oversight of hazardous installations, especially in high-density industrial corridors and petrochemical hubs (NDMA, 2019; CERT-IN, n.d.).

To achieve international equivalence and regulatory coherence, statutory transformation under the One Nation, One Chemical Policy must incorporate legally binding compliance structures aligned with global models (CMSR, n.d.; PCPIR-Policy, 2007; NITI-Aayog, n.d.):

Reform Priority

Objective

Comparative Reference

National Chemical Act

Replace fragmented rules with a unified legal framework

EU REACH, US TSCA Reform

Standardised licensing and notification system

Uniform compliance criteria for producers and importers

K-REACH, AICIS

GHS-based classification and labelling mandate

Universal hazard communication system

UN GHS, EU CLP

Enforceable penalties and compliance accountability

Strengthen deterrence and regulatory predictability

US EPA Enforcement

Table 5: Regulatory Reform Priorities and International Benchmarks

The governance landscape shows that a unified statutory authority is necessary to operationalise legal consolidation. Responsibilities are currently dispersed across DCPC, MoEFCC, State Pollution Control Boards, port authorities, and disaster management systems, creating parallel jurisdictions and interpretive variation (DCPC, n.d.; NDMA, 2019). A national regulator with jurisdiction across the full chemical lifecycle is essential to ensure enforceable compliance, coordinated inspections, digital oversight, and uniform interpretation of statutory requirements.

 

6. Socio-Political Governance and Institutional Capacity

Chemical governance requires more than regulatory text. It requires state capacity, interoperable oversight systems, and socio-political alignment across federal ministries, state agencies, and industrial actors (NDMA, 2019; DCPC, n.d.). India currently operates under a distributed governance model where responsibilities are shared among the Department of Chemicals and Petrochemicals, the Ministry of Environment, Forest and Climate Change, the National Disaster Management Authority, State Pollution Control Boards, and sectoral regulators. This distribution results in parallel authorisation systems, varied enforcement practices, and interpretive inconsistency across jurisdictions (CMSR, n.d.; MSIHC-Rules, 1989; CA-EPPR, 1996).

The Draft National Chemical Policy records this fragmentation and identifies the absence of an integrated oversight body as a structural weakness affecting regulatory coordination, risk governance, and national preparedness (NCP-Draft, 2012; CHEMEXCIL, 2015). The draft proposes a National Chemical Centre to function as a central regulatory authority responsible for harmonising compliance frameworks, coordinating cross-ministerial responsibilities, verifying registrations, standardising audits, and providing scientific and technical advisory capability for policy enforcement and rule interpretation (NCP-Draft, 2012; DCPC, n.d.).

Comparable global structures validate the need for such consolidation. Under EU REACH, a single institutional authority, the European Chemicals Agency, maintains registration oversight, compliance enforcement, data evaluation, public disclosure portals, and interaction with member-state enforcement units (REACH, 2006; Seveso-III, 2012). In Japan, the National Institute of Technology and Evaluation manages the chemical safety and classification system through a structured digital platform that supports regulators, manufacturers, and the public (NITE-CHRIP, n.d.; CMP, n.d.). Similar alignment exists within South Korea through K-REACH implementation where the state functions as the primary regulatory verifier of compliance reporting (K-REACH, n.d.).

Institutional capacity-building remains a documented requirement. NDMA guidance notes the need for systematic strengthening of district-level command structures, industrial safety oversight, and emergency response systems, supported by technology and trained personnel (NDMA, 2019; CERT-IN, n.d.). The official inquiry into the Visakhapatnam styrene incident identified gaps in regulatory skill, certification credibility, and operational verification mechanisms across state authorities and industrial compliance teams (G.A.D-HPC-GoAP, 2020). These findings mirror previous assessments that industrial regulation cannot function effectively without trained personnel, accountability systems, and structured cross-agency interoperability (CMSR, n.d.; NDMA, 2019).

Global governance models provide reference points for developing institutional competence:

Reference System

Governance Method

Application for India

European Chemicals Agency

Central oversight with digital transparency and integrated enforcement

Model for National Chemical Centre structure

Japan NITE and CHRIP

Scientific classification authority with national public data system

Basis for science-based regulatory advisory mechanism

Canada Chemicals Management Plan

Federal-provincial co-governance with industry engagement

Framework for coordinated state and union alignment

OECD Chemicals Programme

Harmonised testing and regulatory cooperation platform

Supports export certification and international equivalence

Table 6: Chemical Governance Benchmarking for Indian Policy Architecture

Institutional strengthening must include workforce competency scaling, regulatory credentialing systems, and formalised compliance training standards that apply to inspectors, industry safety officers, emergency responders, and testing personnel (NDMA, 2019; CHEMEXCIL, 2015). A national competency framework is required to ensure that expertise, regulatory interpretation, and enforcement capability are consistent across economic zones, ports, industrial clusters, and hazardous chemical storage regions.

Strengthening governance also requires structured collaboration with industry associations including the Indian Chemical Council and the industry and commerce associations and chambers to operationalise compliance adoption, communication of regulatory changes, and joint development of technical safety practices aligned with Chemicals (Management and Safety) Rules (CMSR) and future statutory frameworks (CMSR, n.d.; CISA-CFATS, 2007). Engagement with scientific institutions including CSIR laboratories, NCL Pune, and IICT Hyderabad is necessary to ensure that regulatory decisions remain grounded in validated scientific expertise, toxicology data, and evidence-based safety evaluation protocols (PCPIR-Policy, 2007; OPCW, 2021).

 

The emerging policy landscape makes it evident that a unified One Nation, One Chemical Policy transitions India from fragmented administration to coordinated governance and builds the institutional strength required to protect compliance integrity, industrial safety, emergency readiness, and public accountability (NITI-Aayog, n.d.; REACHLaw, n.d.).

 

7. Comprehensive National Security

Chemical governance operates at the level of national security, not just industrial regulation or environmental compliance (OPCW, 2021; NDMA, 2019). A significant proportion of chemicals used in manufacturing, pharmaceuticals, petrochemical processing, semiconductor fabrication, and research are categorised as dual-use materials. These substances support legitimate commercial and scientific functions but may also be repurposed for chemical weaponisation, improvised toxic agents, or military-grade precursor synthesis if regulatory oversight is weak or fragmentary (NACWC, n.d.; CMSR, n.d.).

India’s national security responsibilities include compliance with the Chemical Weapons Convention administered by the Organisation for the Prohibition of Chemical Weapons. As a State Party, India is obligated to regulate, document, inspect, and control the manufacture, transfer, storage, export, import, and final disposition of chemicals listed under Schedule classifications (OPCW, 2021; NACWC, n.d.). The Government of India established the National Authority for the Chemical Weapons Convention under the Cabinet Secretariat to serve as the national verification and treaty-compliance body responsible for monitoring reporting accuracy, issuing permits, coordinating facility inspections, and ensuring alignment with CWC requirements across industrial and laboratory environments (NACWC, n.d.; DCPC, n.d.).

A fragmented legal-administrative framework increases national vulnerability. Without unified oversight, India faces exposure to illicit diversion of hazardous precursors, unverified stockpiling, insecure trans-border chemical flows, unregulated Schedule-linked transactions, and increased probability of chemical misuse by non-state actors operating within or outside formal industrial channels (CERT-IN, n.d.; OPCW, 2021). These concerns are reinforced by global incident patterns. Events such as the documented Sarin deployments in Syria and the Novichok poisoning cases in the United Kingdom demonstrate how lawful chemical access or unsecured precursor pathways may be manipulated for hostile use (OPCW, 2021). OPCW reports also note that misuse threats are shifting toward cyber-linked forms of industrial compromise, supply-chain interception, and digital manipulation of registry or permit documentation rather than overt military programmes (OPCW, 2021; CISA-CFATS, 2007).

India’s chemical domain intersects with national critical infrastructure. Sectors linked to national resilience and strategic capabilities depend on secure and uninterrupted access to regulated substances. These include vaccine and pharmaceutical manufacturing, semiconductor and advanced material production, refinery operations, hazardous industrial gases, defence manufacturing corridors, space and avionics systems, clean-energy technologies, and hazardous waste platforms (PCPIR-Policy, 2007; NDMA, 2019). A disruption in any of these sectors, whether originating from sabotage, hostile cyber activity, diversion of precursors, regulatory failure, or foreign dependency shock, carries cascading impacts across national security, trade, defence procurement ecosystems, and public welfare.

Strategic dependence on external sources for high-value chemicals intensifies this exposure. Parliamentary submissions and industry-based assessments confirm that India continues to rely on foreign supply chains for advanced polymers, high-purity gases used in semiconductor fabrication, defence-grade chemical precursors, and critical pharmaceutical intermediates (IBEF, 2023; ICRH-CMSR, n.d.; Enhesa, n.d.). Such dependencies create operational risk, supply vulnerability during geopolitical shocks, and exposure to regulatory pressure from foreign jurisdictions where compliance frameworks such as REACH, CMP, or K-REACH determine eligibility for trade access (CMSR, n.d.; CMP, n.d.; K-REACH, n.d.).

A secure national chemical governance architecture under a unified One Nation, One Chemical Policy must incorporate the following security-linked capabilities:

Strategic chemical reserve protection with electronic identity tracking, validated storage requirements, and lifecycle monitoring (NACWC, n.d.).

Designation of secure manufacturing corridors and regulated industrial zones consistent with risk-tiered oversight models used under the United States Chemical Facility Anti-Terrorism Standards (CISA-CFATS, 2007).

Supply-chain authentication protocols, integrating customs, bonded warehouses, logistics operators, and defence procurement systems into a single verification pathway linked to digital regulatory infrastructure (TSCA-EPA, 1976; REACH, 2006).

Cyber-physical protection of industrial facilities using CERT-In guidance, ICS and SCADA access control, continuous intrusion monitoring, and secure audit logs (CERT-IN, n.d.).

National command interoperability connecting NDMA emergency frameworks with industrial safety protocols and CMSR-aligned compliance systems across state borders (NDMA, 2019; CMSR, n.d.).

International reference systems provide models for structured implementation:

Framework

Core Security Control

Relevance for India

United States CFATS

Threat-tiered oversight, personnel vetting, incident notification

Basis for risk-graded industrial security

EU Seveso + REACH

Chemical hazard transparency, dual-use oversight, integrated emergency enforcement

Applicable to public information and emergency interoperability

Japan HSC regulatory controls

Schedule-linked traceability and licensing

Template for secure precursor registry

Australia Defence Export Controls

Export screening integrated with customs and compliance records

Reference for border-integrated security architecture

Table 7: International Security Frameworks and Policy Relevance for India

 

The strategic security context makes it clear that a unified national chemical framework strengthens deterrence posture, industrial continuity, emergency readiness, and sovereign resilience by replacing fragmented oversight with enforceable regulatory infrastructure across the full chemical lifecycle (CMSR, n.d.; PCPIR-Policy, 2007; CMP, n.d.).

 

V. Implementation Roadmap

 

A. From Fragmented Regulation to Resilience Governed Continuity

The implementation of One Nation, One Chemical Policy must be approached as a national systems transition rather than a procedural amendment or regulatory notification (CMSR, n.d.; NITI-Aayog, n.d.). India’s present governance environment remains rule-driven, decentralised, and fragmented, where enforcement pathways operate in isolation and compliance is often determined by jurisdictional interpretation rather than a unified national standard. The necessary shift is toward a resilience-governed chemical ecosystem in which continuity, traceability, cyber integrity, and public safety are treated as sovereign governance assets rather than routine technical compliance requirements (NDMA, 2019; Enhesa, n.d.).

The policy logic aligns with India’s evolving national security and resilience thinking, as reflected in publications addressing infrastructure protection and resilience measurement frameworks (BAPI-CIPA, 2025; BAPI-BNRI, 2025; BAPI-CIPA-Legis, 2025). These analyses position chemical regulation within a continuity-centric framework where hazardous industrial corridors, supply-chain-linked chemical hubs, dual-use manufacturing environments, and trans-boundary logistics networks are identified as strategic infrastructure categories comparable to cyber systems, energy corridors, defence platforms, and public-utility command nodes (CERT-IN, n.d.; CISA-CFATS, 2007).

Within this framing, the national chemical ecosystem is reclassified as continuity infrastructure. Its operational reliability directly influences national resilience posture, industrial security, export continuity, pharmaceutical stability, defence manufacturing assurance, and economic sovereignty, creating a strategic imperative rather than a sectoral administrative requirement (PCPIR-Policy, 2007; NDMA, 2019).

The implementation model must therefore function as an infrastructure-security programme with four operational pillars:

1.      Policy and regulatory convergence: A consolidation of MSIHC, CA-EPPR, CMSR, environmental approvals, industrial safety frameworks, trade-linked substance controls, and disaster governance mandates into a unified compliance architecture with explicit authority and enforcement jurisdiction (MSIHC-Rules, 1989; CA-EPPR, 1996; CMSR, n.d.).

2.      A national digital registry and continuous monitoring backbone: A unified platform recording chemical identity, licensing status, hazard classification, safety documentation, facility compliance history, movement tracking, and dual-use relevance, interoperable across Customs, SPCBs, CPCB, DGFT, NCIIPC, and port systems (CMSR, n.d.; REACHLaw, n.d.; CERT-IN, n.d.; TSCA-EPA, 1976).

3.      Resilience scoring and risk-tiered regulatory governance: A measurement layer aligned with national resilience concepts, enabling classification of facilities and supply chains based on hazard magnitude, population adjacency, strategic dependency, and cyber-physical exposure, with inspection cadence and legal consequences scaled accordingly (BAPI-BNRI, 2025; NITI-Aayog, n.d.; NDMA, 2019).

4.      Legal enforceability through a CIPA-aligned statutory authority: A shift from consultative regulatory enforcement to statutory accountability, incorporating deterrence-based compliance, penalty escalation pathways, licensing conditionality, and high-risk operational restrictions aligned with dual-use oversight and national-security principles (BAPI-CIPA, 2025; BAPI-CIPA-Legis, 2025; CISA-CFATS, 2007; NACWC, n.d.).

India’s own policy implementation history demonstrates that phased transition is operationally mandatory. The Petroleum, Chemical and Petrochemical Investment Regions framework exposed how fragmented licensing authority, unaligned regulatory pathways, and unclear institutional command structures impede execution (PCPIR-Policy, 2007; NITI-Aayog, n.d.). The CMSR development process similarly shows that national reform requires institutional preparation, digital governance infrastructure, and continuity-focused enforcement capacity prior to rollout, as reflected in ministerial documentation and external compliance reviews (CMSR, n.d.; DCPC, n.d.; Enhesa, n.d.).

Under One Nation, One Chemical Policy, the implementation roadmap functions as a national compliance operating system that creates jurisdictional clarity between Union and State authority, embeds digital traceability as a non-negotiable governance layer, integrates resilience scoring into regulatory decision-making, and positions statutory enforcement as the operational backbone rather than a supporting instrument.

B. Four-Stage National Rollout Architecture

The national rollout framework functions as a phased transition model where each implementation layer builds institutional capability, legal force, and operational traceability in a cumulative and interoperable sequence (NITI-Aayog, n.d.; CMSR, n.d.; NDMA, 2019). The staging is designed to prevent regulatory shock, avoid institutional paralysis, and ensure that compliance infrastructure matures in parallel with legal authority, digital integration, and enforcement readiness. The logic aligns with resilience-governance doctrines and national capability frameworks articulated in critical infrastructure and BNRI policy literature (BAPI-CIPA, 2025; BAPI-BNRI, 2025; BAPI-CIPA-Legis, 2025).

1. Stage 1: Notification and Institutional Setup

Stage 1 establishes legal recognition and institutional legitimacy. The process begins with formal notification of One Nation, One Chemical Policy as the national framework governing chemical regulation, safety, security, and compliance (NCP-Draft, 2012; CMSR, n.d.; DCPC, n.d.). The phase mandates creation of the National Chemical Centre as the apex technical coordinator and regulatory command unit responsible for oversight authority, compliance governance, scientific verification, and inter-agency alignment.

A harmonisation body is constituted with representation from DCPC, NACWC, MoEFCC, NDMA, and a National Industry Council functioning as the structured interface between regulators and regulated entities (NACWC, n.d.; NDMA, 2019; MSIHC-Rules, 1989; CA-EPPR, 1996). This governance configuration addresses regulatory overlap, fragmented compliance interpretation, and operational ambiguity, which currently result in inconsistent monitoring, inspection gaps, and risk silos.

From a BNRI standpoint, Phase 1 establishes the baseline reference architecture for chemical-system resilience measurement by identifying facility types, dependency networks, and geographic risk clusters requiring structured continuity metrics (BAPI-BNRI, 2025). From a security orientation aligned with the Critical Infrastructure Protection Act framework, it initiates national identification of high-dependency chemical infrastructure and dual-use supply chains requiring tiered legal protection, licencing escalation, and operational continuity mandates (PCPIR-Policy, 2007; CERT-IN, n.d.; CISA-CFATS, 2007; BAPI-CIPA, 2025).

2. Stage 2: Digital Registry, Monitoring and Inventorying

Stage 2 operationalises the cyber-governance core. A National Chemical Digital Registry is deployed as an integrated reporting and compliance backbone consolidating classification, licensing, hazard identity, lifecycle documentation, stock levels, supply-chain movement, permitting status, and enforcement history across all chemical entities operating in India (CMSR, n.d.; REACHLaw, n.d.; ICRH-CMSR, n.d.).

The system architecture draws from India-REACH structural logic while ensuring interoperability with CPCB systems, SPCB portals, Customs clearance engines, port surveillance platforms, the National Critical Information Infrastructure Protection Centre, and national taxation and logistics systems such as GST-linked movement records (CERT-IN, n.d.; DCPC, n.d.; NITI-Aayog, n.d.).

This phase transforms chemical regulation from episodic documentation to a continuously observable compliance ecosystem where substance registration, facility behaviour, hazard declarations, and operational activities become digitally visible and audit-capable.

In BNRI terms, traceability and transparency become measurable variables, allowing resilience scores to reflect live data rather than static compliance submissions (NDMA, 2019; Enhesa, n.d.; BAPI-BNRI, 2025). In CIPA-linked governance, the registry becomes the surveillance and verification mechanism for dual-use precursors, hazardous stock movements, and high-risk facility operations, supporting intelligence-linked alerting, cross-agency enforcement, and audit-trigger workflows (CISA-CFATS, 2007; TSCA-EPA, 1976; REACH, 2006; BAPI-CIPA-Legis, 2025).

3. Stage 3: Licensing, Enforcement and Risk-Tier Governance

Stage 3 marks the shift from digital registration to active compliance governance supported by risk stratification, oversight escalation, and enforcement visibility. Facilities are placed into graded risk tiers using criteria including hazard magnitude, industrial scale, dual-use relevance, proximity to dense populations, cyber-physical exposure, and supply-chain dependency. The classification model aligns with global best-practice structures used in the Seveso framework, Korea’s K-REACH governance model, and the United States risk-managed compliance architecture (Seveso-III, 2012; K-REACH, n.d.; CISA-CFATS, 2007; REACH, 2006).

A national inspection grid is activated as part of this phase, functioning through an integrated oversight system combining central regulators, state enforcement teams, and authorised third-party compliance assessors operating under strict credentialing and audit-trace requirements (NDMA, 2019; DCPC, n.d.; CMSR, n.d.). Facilities undergo periodic inspections, operational stress-tests, scenario-based threat simulations, and compliance verification exercises, preventing passive documentation-based adherence and instead enforcing continuous operational readiness.

In the BNRI measurement schema, Phase 3 is where enforcement results become quantifiable governance signals. Facility downtime, redundancy design, emergency response capability, and continuity planning maturity contribute to resilience-scoring inputs used in corridor-level and national-level planning (NITI-Aayog, n.d.; PCPIR-Policy, 2007; BAPI-BNRI, 2025). Weak compliance, non-reporting, or repeated breach patterns reduce BNRI performance bands, directly affecting operator status, future licensing conditions, and investment corridor categorisation.

Within the CIPA security alignment, Phase 3 embeds oversight for hybrid threat environments. The inspection regime incorporates intelligence-linked triggers for insider threat patterns, cyber-enabled manipulation attempts, precursor diversion anomalies, and high-risk storage behaviours (CERT-IN, n.d.; CISA-CFATS, 2007; OPCW, 2021; BAPI-CIPA-Legis, 2025). Facilities considered strategically sensitive undergo heightened scrutiny supported by coordinated enforcement between sector regulators, national security agencies, and continuity oversight units (NACWC, n.d.; CMSR, n.d.).

4. Stage 4: Review, Adaptation and Global Harmonisation

Stage 4 institutionalises a governance feedback architecture rather than a static finalisation process. The National Chemical Centre leads an annual review cycle with mandated participation from DCPC, NACWC, MoEFCC, NDMA, CERT-In, and recognised industry bodies representing high-volume and high-risk chemical sectors (NACWC, n.d.; NDMA, 2019; CERT-IN, n.d.; DCPC, n.d.). This review cycle absorbs operational data, enforcement trends, registry insights, accident analyses, and supply-chain intelligence to recalibrate enforcement instruments, reporting obligations, and policy design.

Global alignment becomes explicit during this phase. The governance framework is benchmarked against international systems including EU REACH, K-REACH, AICIS protocols, Seveso oversight layers, and OPCW verification parameters to ensure cross-border regulatory interoperability and export acceptance (REACH, 2006; K-REACH, n.d.; AICIS, n.d. (1); AICIS, n.d. (2); Seveso-III, 2012; OPCW, 2021). Alignment reduces non-tariff trade barriers and mitigates compliance isolation risks for Indian chemical producers, particularly in export-linked sectors (CMP, n.d.; TSCA-EPA, 1976).

BNRI integrates ESG maturity variables into this stage, transforming governance outcomes into measurable national indicators that reflect operational integrity, environmental stewardship, and continuity assurance across chemical corridors and industrial clusters (IBEF, 2023; Enhesa, n.d.; BAPI-BNRI, 2025). CIPA linkages expand during Phase 4, mapping interdependencies between the chemical sector and critical systems including logistics, power, water, defence manufacturing supply chains, and export frameworks to ensure cross-sector continuity and surveillance (CISA-CFATS, 2007; CMP, n.d.; TSCA-EPA, 1976; BAPI-CIPA, 2025).

This review-harmonisation loop ensures the implementation framework remains dynamic, risk-synchronised, and globally interoperable while retaining statutory alignment with the national resilience and critical infrastructure protection mandate (CMSR, n.d.; NDMA, 2019).

Successful implementation of the four-stage transition depends on structural enablers that operate across ministries, regulatory layers, compliance systems, and digital governance infrastructure (NITI-Aayog, n.d.; NDMA, 2019). These enablers convert statutory intent into executable national capacity and ensure that the regulatory architecture functions as a coherent operating system rather than a dispersed legal framework (CMSR, n.d.; DCPC, n.d.).

C. Cross-Cutting Enablers for Effective Implementation

1. Single-Window Licensing and Regulatory Convergence

A unified licensing and regulatory convergence model is required to eliminate overlapping approval streams, fragmented compliance pathways, and conflicting procedural interpretations. This model must reflect a centralised approval and notification structure comparable to oversight mechanisms used by the European Chemicals Agency under the REACH legislative system and Seveso industrial safety governance (REACH, 2006; Seveso-III, 2012). The National Chemical Centre assumes the role of nodal decision-making authority and acts as the verification body for licensing, classification, facility certification, and appeal adjudication within a structured regulatory command chain (NCP-Draft, 2012; CMSR, n.d.).

Technical scientific review capability must operate in parallel to regulatory decision-making. A governance layer similar to Japan’s NITE approach is necessary to support hazard classification, test-method stewardship, and interpretation of chemical behaviour under industrial and emergency conditions (NITE-CHRIP, n.d.). This ensures that licensing decisions are grounded in validated scientific evidence rather than administrative discretion or industry-provided material without independent verification.

With this framework, India can systematically dismantle fragmented licensing structures and converge duplicative processes covering environmental permissions, storage approvals, process safety compliance, precursor regulation, transport controls, and export-linked certification (DCPC, n.d.; CMSR, n.d.). The shift introduces procedural predictability, reduces cost of compliance through standardisation, and improves regulatory enforceability through consistency and traceability.

Centralising licensing under a single decision pathway also establishes the legal clarity necessary for enforcement bodies to act without jurisdictional conflict or interpretive dependency. This supports oversight integrity, reduces regulatory gaming, and limits the use of procedural ambiguity to delay inspections or evade compliance reporting (Enhesa, n.d.; REACHLaw, n.d.; BAPI-CIPA, 2025).

Within the broader governance doctrine referenced in resilience and critical infrastructure policy analysis, regulatory convergence becomes a national capability requirement rather than an administrative simplification exercise (BAPI-BNRI, 2025; BAPI-CIPA-Legis, 2025).

2. Digital Enforcement Architecture

A digitally enforced regulatory layer is essential for governing a high-hazard chemical ecosystem at national scale. The enforcement system must function as a cyber-physical regulatory environment, consistent with the security doctrine embedded in national cybersecurity advisories, industrial safety controls, and the compliance logic reflected in both CMSR and CIPA-aligned governance frameworks (CERT-IN, n.d.; CISA-CFATS, 2007; CMSR, n.d.; BAPI-CIPA-Legis, 2025). Digital compliance cannot remain a supporting mechanism. It must operate as the primary oversight backbone through which every high-risk chemical, storage unit, and industrial operator is traceable, auditable, and accountable across the full lifecycle from import or synthesis to disposal or export (TSCA-EPA, 1976; REACH, 2006).

QR-tagged tracking for hazardous consignments across ports, industrial corridors, bonded warehouses, and last-mile storage points forms the baseline layer. On top of this, IoT-enabled telemetry that captures tank pressure, temperature thresholds, styrene vapor saturation, ammonia leak trajectories, or chlorine containment stability introduces real-time monitoring capacity across high-risk installations (CMSR, n.d.; NDMA, 2019). AI-integrated anomaly detection feeds continuous risk scoring and incident probability estimation, enabling regulatory bodies to intervene before escalation conditions emerge rather than after loss-of-control thresholds are breached. The BAPI BNRI framework positions such telemetry and continuous verification as necessary for resilience scoring, contingency readiness, and industrial continuity assurance (BAPI-BNRI, 2025; NITI-Aayog, n.d.).

This enforcement model replaces reliance on paper filings, legacy reporting gaps, and periodic compliance inspections with a system where the regulator has persistent visibility over hazardous industrial activity. It introduces a deterrence climate grounded in traceability and enforceability rather than voluntary compliance or self-reporting culture (Enhesa, n.d.; NDMA, 2019). Under a unified digital enforcement architecture, non-compliance becomes detectable as a data anomaly rather than as a delayed legal discovery, and regulatory enforcement shifts from procedural policing to measurable system control.

3. National Capacity-Building and Accreditation Systems

 A digitally governed chemical regulatory framework cannot operate effectively without an equally formalised human capability system. National capacity-building must be institutionalised as a statutory requirement, not a discretionary training expectation. Personnel responsible for chemical handling, facility operation, emergency management, audit verification, and cyber-physical safety oversight must undergo structured pre-qualification and periodic re-credentialing aligned with facility risk tiers and international benchmarks (NDMA, 2019; CMP, n.d.; CMSR, n.d.).

Accredited national training architecture must operate through specialised hubs leveraged from existing research and industrial safety platforms, including CSIR laboratories, national safety institutes, and advanced technical universities. These hubs must function as centres for certification, simulation-based disaster preparedness, process safety instruction, hazardous materials (HAZMAT) control protocols, and technology-enabled compliance learning (DCPC, n.d.; PCPIR-Policy, 2007).

The CMSR framework already implies a shift toward mandatory technical literacy for regulated operators. The CIPA doctrine expands this requirement by positioning chemical sector capability as a national resilience domain and a security priority requiring compliance-auditable skill certification (BAPI-CIPA, 2025; CERT-IN, n.d.; CISA-CFATS, 2007). National accreditation therefore becomes a regulatory verification tool equal in importance to licensing or digital traceability.

Without a trained regulatory and industrial workforce, even advanced systems of monitoring or automation remain operationally insufficient, creating governance gaps in enforcement, reporting accuracy, and emergency response escalation (NDMA, 2019; Enhesa, n.d.).

4. Transparent Public Risk Communication

Transparent and structured public risk communication must function as a statutory obligation and not as a discretionary reporting activity. The governance shift required mirrors the Seveso-III regulatory culture in the European Union where public communication of hazard-zone data, industrial risk maps, emergency protocol visibility, and chemical incident history is mandated for installations crossing defined hazard thresholds (Seveso-III, 2012; REACH, 2006). This transparency obligation strengthens public oversight, introduces citizen-level accountability, and prevents information suppression during emergency conditions (OPCW, 2021; NDMA, 2019).

A public-facing information regime must integrate digital registry outputs into controlled transparency dashboards showing hazard classification, compliance status, emergency protocols, and BNRI-linked safety maturity bands for high-risk facilities (IBEF, 2023; CMP, n.d.; BAPI-BNRI, 2025). Such transparency transforms public safety governance from reactive disclosure after incidents into a visible, expectation-driven compliance climate where accountability pressure exists before regulatory failure.

Public risk communication therefore becomes a tool for compliance enforcement, political governance legitimacy, community preparedness, and industry behaviour correction. It also aligns India with global compliance culture, non-tariff safety expectations, and international dual-use transparency obligations (CMSR, n.d.; NITI-Aayog, n.d.; NACWC, n.d.).

D. Outcome Orientation: From Episodic Response to Structural Resilience

A resilience-governed chemical system requires a shift in regulatory mindset and operational culture from reactive response after incidents to predictive, continuity-led compliance. This transition changes the chemical sector’s risk posture from incident-driven regulation to anticipatory resilience engineering supported by statutory alignment, digital verification, and real-time hazard visibility (NDMA, 2019; CMSR, n.d.; NITI-Aayog, n.d.). Under this governance model, every industrial node, logistics corridor, precursor storage unit, and allied processing chain is treated as part of a national system rather than an isolated industrial operation.

Under the BNRI framework, resilience shifts from a theoretical standard to a measurable compliance benchmark. Chemical facilities are assessed against continuity-readiness metrics, redundancy quality, incident survivability, and the ability to maintain operational integrity under disruption conditions (PCPIR-Policy, 2007; IBEF, 2023; BAPI-BNRI, 2025). The BNRI measurement logic embeds traceability, preparedness, and response performance into regulatory lifecycle scoring, transforming system safety into a quantifiable governance obligation rather than voluntary practice.

CIPA doctrine strengthens this shift by positioning hazardous chemical infrastructure as part of national continuity architecture and not merely as industrial assets (CERT-IN, n.d.; CISA-CFATS, 2007; NACWC, n.d.; BAPI-CIPA, 2025). By treating precursor storage sites, logistics chokepoints, dual-use manufacturing facilities, and high-energy industrial clusters as strategic infrastructure, regulatory oversight becomes linked to national security and sovereign resilience rather than dispersed administrative compliance. This positions the chemical ecosystem within the strategic logic outlined in resilience governance literature and national security policy layers where continuity becomes a binding expectation.

For regulated industry, the structural transition delivers operational predictability. A unified national policy reduces fragmented rule interpretation, delays linked to multi-agency compliance, and uncertainty associated with ambiguous regulatory pathways. Facilities seeking export clearance into jurisdictions governed by REACH-equivalent controls experience reduced certification friction and improved acceptance timelines once compliance is digitally authenticated and legally harmonised (REACH, 2006; REACHLaw, n.d.; K-REACH, n.d.).

For the state, the shift operationalises hazard visibility and supports risk-tiered command across chemical corridors, bonded storage, and industrial clusters. Enforcement authorities gain the ability to detect non-compliance patterns, diversion attempts, or precursor anomalies through digital oversight rather than post-event discovery (OPCW, 2021; CMP, n.d.; TSCA-EPA, 1976).

For communities located near high-risk installations, governance becomes preventative rather than compensatory. Ad hoc emergency management is replaced by structured continuity frameworks supported by public hazard transparency, regulated emergency communication, and documented industrial accountability (Seveso-III, 2012; MSIHC-Rules, 1989; CA-EPPR, 1996).

E. Implementation Position: Policy, Measurement and Statute as a Unified System

A unified system of governance is required to prevent the chemical ecosystem from operating as a patchwork of legacy statutes, digital fragments, and inconsistent enforcement signals (CMSR, n.d.; NDMA, 2019). Under the implementation logic, the policy provides the national blueprint defining control, classification, licensing, and compliance expectations for every entity regulated within the chemical lifecycle (DCPC, n.d.; NCP-Draft, 2012). The BNRI framework provides the measurement spine, scoring resilience, operational continuity, and regulatory performance through quantifiable indicators for installations, clusters, and transboundary supply routes (NITI-Aayog, n.d.; PCPIR-Policy, 2007; BAPI-BNRI, 2025). CIPA provides the security and statutory enforcement layer, transforming compliance from procedural activity into governance enforced through penalties, surveillance authority, and national continuity obligations (CERT-IN, n.d.; CISA-CFATS, 2007; NACWC, n.d.; BAPI-CIPA-Legis, 2025).

As these three systems operate together, the chemical sector becomes governed through a single-national operating model capable of full lifecycle traceability, continuous monitoring, and enforceable resilience. This model is interoperable with REACH, AICIS, K-REACH, and TSCA-style global regulatory systems, enabling alignment with non-tariff compliance regimes shaping global chemical trade and security oversight (AICIS, n.d. (1); AICIS, n.d. (2); REACH, 2006; TSCA-EPA, 1976).

The resulting architecture places India’s chemical governance within a framework of national capability, not merely administrative control, where compliance is measurable, digital, risk-tiered, internationally recognisable, and security-aligned.

REFERENCES

Australia — AICIS (Australian Industrial Chemicals Introduction Scheme). (n.d.-a). Digital compliance portal & guidance. https://www.cirs-group.com/en/chemicals/australian-industrial-chemicals-introduction-scheme-aicis

Australia — AICIS (Australian Industrial Chemicals Introduction Scheme). (n.d.-b). AICIS registrants must provide information about any introduction of 522 listed PFAS. https://www.industrialchemicals.gov.au

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[This work has been funded by the Indian Council of Social Science Research (ICSSR), Ministry of Education, New Delhi, under the ―ICSSR Post-Doctoral Programme 2019-20 on “Critical Infrastructure Protection Programme for India”.]