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
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
Basic Chemicals, Pharmaceuticals & Cosmetics Export Promotion
Council (CHEMEXCIL). (2015, January 2). Suggestions for Draft National
Chemical Policy. https://chemexcil.in/uploads/files/CHEMEXCIL_Suggestions_for_Draft_Chemical_Policy.pdf
Bharat Assets Protection Institute (BAPI). (2025, October 15). Proposing
the Bharat National Resilience Index (BNRI): Building secure and
continuity-ready infrastructure for India. Retrieved from https://bharatassetsprotection.org/Article/Proposing-the-Bharat-National-Resilience-Index-BNRI-Building-Secure-and-Continuity-Ready-Infrastructure-for-India
Bharat Assets Protection Institute (BAPI). (2025, October 16). Legislating
Resilience: Why India Needs a Critical Infrastructure Protection Act for the
Cyber-Physical Age. Retrieved from https://bharatassetsprotection.org/Article/Legislating-Resilience-Why-India-Needs-a-Critical-Infrastructure-Protection-Act-for-the-Cyber-Physical-Age
Bharat Assets Protection Institute. (2025, October 12). The
Strategic Necessity of a Critical Infrastructure Protection Act (CIPA): A
National Imperative for India’s Security and Resilience. Retrieved from
https://bharatassetsprotection.org/Article/The-Strategic-Necessity-of-a-Critical-Infrastructure-Protection-Act-CIPA-A-National-Imperative-for-India’s-Security-and-Resilience
Canada — Chemicals Management Plan. (n.d.). Chemicals Management
Plan. https://www.canada.ca/en/health-canada/services/chemical-substances/chemicals-management-plan.html
CERT-IN — Indian Computer Emergency Response Team. (n.d.). Industrial
cybersecurity advisories. https://www.cert-in.org.in
CISA — Cybersecurity & Infrastructure Security Agency. (2007). Chemical
Facility Anti-Terrorism Standards (CFATS) final rule. https://www.cisa.gov/chemical-facility-anti-terrorism-standards
Enhesa. (n.d.). Chemical regulations and the economy in India.
https://www.enhesa.com/resources/article/chemical-regulations-and-the-economy-in-india
European Commission — Environment. (n.d.). Industrial safety:
Preventing and reducing the risk of industrial accidents. https://environment.ec.europa.eu/topics/industrial-emissions-and-safety/industrial-accidents_en
European Union. (2012). Directive 2012/18/EU (Seveso III
Directive). https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012L0018
Government of Andhra Pradesh. (2020, May 8). General
Administration Department – Constitution of High-Power Committee (G.O. Rt. No.
803). https://gad.ap.gov.in/2020gad_rt803.pdf
Government of India. (1996). Chemical Accidents (Emergency
Planning, Preparedness & Response) Rules, 1996. https://indiacode.nic.in
Government of India. (2007). Petroleum, Chemical &
Petrochemical Investment Regions (PCPIR) Policy, 2007. https://chemicals.gov.in
India — Chemical Management and Safety Rules (CMSR). (n.d.). CMSR
overview. https://www.cirs-group.com/en/chemicals/india-chemical-management-and-safety-rules-cmsr-reach
India Brand Equity Foundation (IBEF). (2023). Indian chemical
industry report (2023). https://www.ibef.org
Indian Chemical Regulation Helpdesk. (n.d.). CMSR public
consultation and updates. https://indianchemicalregulation.com
Intertek — Assuris. (n.d.). Global substance management &
product stewardship solutions. https://www.intertek.com/assuris/chemicals/regulatory/canada-cmp/
Japan — National Institute of Technology and Evaluation (NITE).
(n.d.). Chemical Risk Information Platform (CHRIP). https://www.nite.go.jp
Ministry of Chemicals & Fertilizers (DCPC). (n.d.). Official
government website. https://chemicals.gov.in
Ministry of Chemicals & Fertilizers, Department of Chemicals
& Petrochemicals. (2012). Draft National Chemical Policy (Draft
NCP-2012). https://prod-qt-images.s3.amazonaws.com/indiawaterportal/import/sites/default/files/iwp2/draft_national_chemical_policy_2012.pdf
Ministry of Environment & Forests, Government of India. (1989,
November 27). The Manufacture, Storage and Import of Hazardous Chemical
Rules, 1989. https://ifbgoa.goa.gov.in/sites/default/files/Manufacture_Storage_Import_of_Hazardous_Chemical_Rules_1989.pdf
National Authority for Chemical Weapons Convention (NACWC). (n.d.).
Official website. https://www.nacwc.gov.in
National Disaster Management Authority (NDMA). (2019). Guidelines
on chemical (industrial) disaster management. https://ndma.gov.in
NITI Aayog. (n.d.). Evaluation of PCPIRs (reports and policy
notes). https://www.niti.gov.in
Organisation for the Prohibition of Chemical Weapons (OPCW).
(2021). Annual report 2021. https://www.opcw.org
REACHLaw. (n.d.). India REACH / CMSR regulatory updates. https://www.reachlaw.fi/india-reach
Regulation (EC) No 1907/2006 — REACH. (2006, December 18). Registration,
Evaluation, Authorisation and Restriction of Chemicals regulation. https://osha.europa.eu/en/legislation/directives/regulation-ec-no-1907-2006
South Korea Ministry of Environment. (n.d.). K-REACH regulations
summary. https://eng.me.go.kr
United States
Environmental Protection Agency. (1976). Toxic Substances Control Act (TSCA).
https://www.epa.gov/enforcement/toxic-substances-control-act-tsca-and-federal-facilities
[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”.]