GHS impact on OSH legislation: Trade Union perspective

1
GHS impact on OSH legislation Trade Union
perspective

• Hildo Krop
• IVAM Amsterdam

3rd Seminar on workers protection
chemicals Amsterdam, 21-22 January 2008
2
Impact of GHS on EU OSH Legislation

• Impact on Legislation (Policy side)

• Impact on Implementation (Trade Union side)

3
GHS and other directives/regulation
REACH
OHS Directives (RIE)
SDS DNEL/NEC Exposure scenarios Risk
Characterisation
Test activity
Test result
CL

• UN ? GHS
• EU ? DSD DPD
• Many other systems

4
GHS vs EU

• Consistent with DSD DPD
• Not more testing activity

• New labels and phrases
• Different approach to classify mixtures

• Mixtures
• Return to emphasis with data available for
  complete mixture. (Not possible to trace back
  unwanted effects to the source)
• If not complete mixture data then apply bridging
  principles (incomplete mixture(s), (not) all
  ingredients)
• For acute toxicity Not based on comparison of
  with maximum but use of toxic addition of
  and Toxicity Estimates. (Thus for acute toxicity
  LD50 etc must be known and stated on the SDS).
  More fuzzy to check the CL of the mixture!

Slightly more mixtures will need to be classified
in EU-GHS.
5
Impact of GHS on the implementation of OHS
directives
mg/L
RIE based on R26 ? RIE based on ?? In GHS Cat
1? Reduction in RRM/ Cat 12? Increase in RRM
6
Training
Is the info on the SDS correct? Is the RIE in
line with with the SDS?

• What can be done
• Does the CL of the dangerous substance
  correspond to the CL inventory (gt 1 dec 2010)?
• What to do if CL is NOT harmonised in the
  inventory?
• Is CL based on the HIGHEST registration quantity
  (check registration document on internet)
• Registration dossiers allows to distinguish
  between
• No data ? No risk and
• Yes data ? No risk

• What cannot be done
• Do the dangerous substances on the SDS correspond
  to what is present in the mixture?
• Is their range correct?
• Are they present in the mixture?
• Are dangerous substance present
• in the mixture but not on the SDS?
• Special task for Inspectorates

7
Conclusions

• EU-GHS does not increase the level of protection
  of human health and the environment compared to
  EU - DSD/DPD

• EU-GHS changes the labels but not the message

• EU-GHS does not add to more/better knowledge
• of the risks of the product

• A small change in classification may have a
  large impact
• in the implementation of the Chemical Agent
  Directives.

• EU-GHS will decrease the qualitity of the CL
  and SDS

• REACH gives more tools to check the info on the
  SDS

• Both REACH and EU-GHS cannot check whether
• the info on the SDS corresponds to the mixture
  used

8
Thank you for your attention
9
EUH204 - Contains isocyanates. See information
supplied by the manufacturer.