GHS Implementation Update

1
GHS Implementation Update Presented by Paula
Laux Senior Regulatory Specialist Wercs
Professional Services
2
Presentation Format

• Short GHS Review
• Update status of rulemaking in major countries
• Short Demo
• Questions

3
Why was GHS Developed?

• So that a system exists where hazards are
  identically communicated to all those exposed

4
What is GHS?

• Globally Harmonized System of Classification and
  Labeling
• Defines health, physical and environmental
  hazards
• Establishes a classification scheme using
  available data
• Establishes a common hazard communication method
• Explains how to apply the system
• Supplies building blocks for countries to develop
  own laws

5
What GHS isnt

• A regulation or a standard
• Not mandated until it becomes law in a given
  region
• May require various regulatory authorities within
  region to pass laws

6
Important Implementation Points

• GHS Voluntary international document-not binding
  treaty
• Only when countries adopt GHS into their systems,
  will there be binding regulatory changes for
  industry
• No international implementation schedule
• Different systems/sectors require different time
  frames for GHS implementation

7
Asia-Pacific-Australia

• GHS MSDS format effective April 2006
• GHS classification proposal encompassed 4
  standards and code of practices, but addressed
  only workplace
• Intend to address a revised GHS hazardous
  substances list
• Intent to consolidate the requirements for
  workplace hazardous and dangerous goods in a
  single framework

8
Asia-Pacific-Australia

• Intent to use the GHS as a classification tool
  for substances within the scope of the proposed
  framework
• March 2007 ended public consultation period
  issued
• Issued Summary of public submission
• Comparison EU to Australian draft proposals

9
Asia-Pacific-Australia

• Proposed implementation in 2008 per UN-
  Declaration of new GHS-based framework for the
  control of workplace hazardous chemicals
• Transitional periods for implementation
• Substances date of entry until 2012
• Mixtures- date of entry until 2015

10
Asia- China

• AQSIQ (General Admin. Of Quality Supervision,
  Inspection and Quarantine) is taking lead.
• AQSIQ finalized 25/26 Standard (same hazards as
  GHS)
• Germ cell Mutagenicity is outstanding
• Technically went into force on Jan. 1, 2008 for
  materials in production
• Technically will be in force for materials in
  distribution Dec. 31, 2008.

11
Asia- China

• Standards used GHS First Edition (2003) for test
  methods and GHS classification
• Standards also compile precautionary statements
  and selectively adopted them
• Biggest differences between GHS (2005) Chinese
  standards
• Chinese GHS standard groups unstable explosives
  with Division 1.1.
• Chinese GHS standards do not include Aspiration
  Hazard
• No Chinese standard to incorporation MSDS
  preparation(GB 16483-2000)

12
Asia- Japan

• 2006- Publication of National Standards JIS
  Z72512006 (Labelling of chemicals based on GHS)
• Entry into force of the amended Industrial Safety
  and Health Laws (ISHL) -December 2006
• Implementation only for product containing gt 1
  of 99 selected ISHL-regulated chemicals

13
Asia- Japan

• All classification for substances under the ISHL
  released on the National Institute of Technology
  and Evaluation (NITE) website- 2007
• Government classification are NOT mandatory
• Expansion to included all 640-1500 ISHL regulated
  chemicals at varying concentrations (December
  2008)
• Provide and On-line tool for the classification
  mixtures (2008) English??

14
Asia- Korea

• GHS classification and labelling project for 2500
  regulated substances
• Ministry of Labor issued Standards for the
  Classification and Preparation of Labeling, and
  SDSs (January 10, 2008 (MoL Public No. 08-01)
• For Korean EPA (Toxic Chemicals Control Law)
  Application will be in stages -July 2008 for
  newly examined products.
• Single existing chemical July , 2010
• Mixtures July, 2015

15
Asia- Korea

• Major differents between UN and Korean MoL
• Flammable gases Only Recognizes Category 1
• Flammable Liquids- No Category 4
• Acute Toxicity- No Category 5
• Skin Corrosion- No Category 3
• Serious Eye Damage/Eye Irritation No Category
  2B
• Aquatic Toxicity- No Category 2 or 3
• Major difference between Korean MoL and Draft
  Korean EPA regulations
• Flammable Gases- Same as UN Recognizes Category 2
• Serious Eye Damage/Eye Irritation- All are
  Category 2

16
Asia- Korea

• 2008-Launching of the government official
  GHS-dedicated website (English?)
• 2008 Launching of a GHS classification and
  labelling project for mixtures

17
Asia-Pacific-New Zeland

• Implemented GHS through the Hazardous Substances
  and New Organisms Act (HSNO) and its related
  regulation.
• For something to be nonhazardous, it must be in
  the lowest boundary of the least hazardous GHS
  category for each class.
• Code of practices issued in 2006 Preparation of
  Safety Data Sheets (HSNOCOP 8-1) Consistent with
  Annex 4 of GHS.
• HSNO Chemical Classification Information Database
  (CCID)-5500 chemicals classified according to GHS

18
Asia-Pacific-New Zeland

• In force since July 2001 for new hazardous
  substances
• For existing substances, transitional period of
  five years (ended July 2006)
• Applicable to all (new and existing) substance
  since July 2006)
• Labeling being handled separately in order to
  align with major trading partner (2010)

19
Canada

• Taking a Tripartite Approach
• Implementation plans are based on the first
  revised edition of the GHS (GHS-Rev.1, 2005
• Health Canada charged with lead

20
Canada

• Completed
• Situational Analysis (2003)
• Multi-stakeholder technical consultations(Pest
  control, workplace chemical, consumer products)
  (2004-2005)
• Comparison of Sector Interim Recommendations or
  Preferred Options (2006)
• Technical consultations and further development
  of final recommendations (2007)

21
Canada

• Economic analysis expected in mid-2008(?)
• Target implementation 2009

22
EU

• June 1, 2007 REACH enter into force
• June 27, 2007 Adoption of proposal for GHS
  regulation (Amends Directive 67/548//EEC and
  Regulation (EC) No 1907/2006)
• October 2007 Adoption of proposals implementing
  the GHS for seven pieces of EU downstream
  legislation (COM (2007) 611 final COM (2007) 613
  final

23
EU

• GHS is primarily a self-classification system for
  enterprise
• Use general principles of GHS- Building block
  approach adaptations to meet EU needs (ozone
  depletion.)
• Scope of regulation includes Biocides just like
  current system.
• Takes over the current Annex I of Council
  Directive 67/568/EEC
• Takes over the Title XI (Classification and
  Labelling inventory from REACH Regulation)

24
EU

• Consistent with transport
• Gases under pressure
• Self-reactive substances and mixture (Types C to
  G)
• Self-heating substances and mixtures
• Oxidizing liquids (Category 3)
• Oxidizing solids (Category 3)
• Corrosive to metals
• Removes hazard categories
• Flammable liquids (Category 4)
• Acute Toxicity (Category 5)
• Skin Corrosion/Irritation (Category 3)
• Aspiration hazard (category 2)
• Acute Aquatic toxicity (Categories 2 and 3)

25
EU

• Transitional period is defined which leaves both
  current legislation and new Regulation in force
• Entry into force for substance reclassification
  Nov 30, 2010
• Entry into force for mixture reclassification May
  31, 2015
• Current Directives on classification, labelling
  and packaging (Council Directive 67/48/EEC and
  Directive 1999/45/EC) repealed on June 1, 2015

26
US

• Last year- Final Rule anticipated at the end of
  2008
• Multi-agency discussion underway with OSHA taking
  lead.
• DOT/IMDG/ICAO have adopted GHS class 3 and 6
  criteria for transport and plan to adopt GHS
  class 9 for aquatic toxicity in 2009

27
US

• OSHA has a detailed comparison of the provision
  of the GHS to the OSHA Hazard Communication
  Standard
• Published a guide to GHS
• Published advance notice of proposed rulemaking
  (ANPR) September 12, 2006
• Notice of proposed rule-making based on the
  comments received
• Economic analysis has been drafted
• Proposed rule is under draft for public comment

28
US

• EPA updated its website and has documents
  available
• Materials/Presentations from October 2006
  Public Meeting on GHS
• White Paper GHS Implementation Planning Issues
  (PDF) (17pp, 88K, about PDF)
• Comparison of Current EPA Requirements and the
  GHS (PDF) (22 pp, 157K, about PDF)
• Sample GHS Labels (PDF) (1 p, 155K, about PDF)
• Benefits of GHS PowerPoint

29
US

• CPSC is just beginning to investigate GHS for
  consumer product.
• US implementation will be staggered across all 4
  agencies ranging from now until 2012.
• No detailed implementation plan has been
  developed

30
Summary

• Difficult to follow because all countries have
  different processes for making laws
• Very clear that countries are implementing using
  parts and pieces of the building blocks
• Many countries, dont have agreement between
  separate regulatory bodies within the same
  country
• Most concise source of information
  http//www.unece.org/trans/danger/publi/ghs/implem
  entation_e.html

31

• WERCS GHS Demo