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*Summary of Slide Provide by Michelle Sullivan
Why was GHS developed?
So that a system exists where hazards are identically communicated to all those exposed
*Summary of Slide Provide by Michelle Sullivan
Why was GHS developed?
Today same product requires multiple MSDSs and labels in international trade
Today there are different classification schemes between Environmental, Industrial, Transportation, and Consumer sector - even in same country
Today the same substance/preparation requires different warnings based on jurisdiction
*Summary of Slide Provide by Michelle Sullivan
Who is the target audience?
Governments
Companies
Workers
Emergency Responders
Member of the Public
Consumers
*Summary of Slide Provide by Michelle Sullivan
What types of Chemicals are Regulated?
Hazardous Chemicals Substances
Products
Mixtures
Pesticides
Consumers Products
*Summary of Slide Provide by Michelle Sullivan
What is GHS?
Globally Harmonized System of Classification and Labeling Defines health, physical and environmental hazards
Establishes 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
*Summary of Slide Provide by Michelle Sullivan
Published Guidance documents
Published by the United Nation Economic Commission for Europe (UNECE)
First publication in 2003
Revision 1 edition published in 2005
Referred to as “UN Purple Book”
*Summary of Slide Provide by Michelle Sullivan
What GHS Isn’t?
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
*Summary of Slide Provide by Michelle Sullivan
General Implementation Guidelines
GHS: Voluntary international document- not binding treaty
When countries adopt GHS into their systems, there will be binding regulatory changes for industry
No international implementation schedule
Different systems/sectors require different time frames for GHS implementation
*Summary of Slide Provide by Michelle Sullivan
Canada Implementation Looking for harmonization between NAFTA countries
Sectors WHMIS, Consumer Chemical, Pesticide control, and Transportation
Published, “Comparison of Sector Interim Recommendations or Preferred Options” (Feb, 2006)
Next steps: Consultation with trading partners; Economic analysis, Development of final recommendations, Decision making, Draft regulations, Regulatory process, Phasing in implementation
May revisit based on US and Mexican work.
*Summary of Slide Provide by Michelle Sullivan
EU Implementation
As per REACH, GHS SDS formats required already June 1, 2007
Sections 2/3 should be inverted
Transition period for GHS implementation 3 years for substances, 7-8 years for mixtures
Will require extended SDS for certain material with varying phase-in period
*Summary of Slide Provide by Michelle Sullivan
Japan Implementation GHS labeling of ISHL (Industrial Safety and Health Law) 1-Dec-
2006
GHS labeling technically applies to only 99 of the denoted ISHL materials
GHS classification manual does exist in English
1500 GHS classification of chemicals regulated in Japan
Industrial labeling and SDS system based on GHS
Have approved risk based labeling for consumer products (Not consistent with GHS)
*Summary of Slide Provide by Michelle Sullivan
Other Asia-Pacific Countries
Australia, Bahrain, Bangladesh, Brunei Darussalam, China, Cambodia, Fiji, India, Indonesia, Islamic Republic of Iran, Japan, LAO, Malaysia, Maldives, Mongolia, Myanmar, Oman Philippines, QATAR, Republic of Korea, Sri Lanka, Thailand, Vietnam, Yemen
20/23 Countries have plans to implement GHS
Several (New Zealand, Bahrain, & Mauritius) countries have already adopted GHS
*Summary of Slide Provide by Michelle Sullivan
Other Asia-Pacific CountriesNew Zealand
GHS has been adopted in a legislative sense (GHS 2003)
Revisions based on 2005 GHS (rev 1) expected in 2007
Implementation not planned before 2008
List of GHS classified chemicals
Labeling being handled separately in order to align with major trading partner. (2010)
*Summary of Slide Provide by Michelle Sullivan
Other Asia-Pacific CountriesAustralia
GHS MSDS format was effective April 2006
GHS classification proposal- Addresses only workplace
Draft National Standard for the Control of Workplace Hazardous chemicals
Transition period: 5 years for SDSNo intent to use GHS mixtures ruleWant to address a revised GHS hazardous substances
list
Intent to make draft for labeling of Workplace Chemicals and Preparation of SDSs as well
*Summary of Slide Provide by Michelle Sullivan
USA ImplementationDOT
For harmonization of transportation (US DOT) voluntary compliance is now authorized, the provisions become mandatory on 1-Jan-2008
Exception to above for Division 3 and 6.1- old packing groups can be used until 1-Jan-2012
Environmentally hazardous substances will be considered for change in a separate rulemaking proceeding
*Summary of Slide Provide by Michelle Sullivan
USA ImplementationOSHA Under a Notice of Proposed Rulemaking (12-Sept-2006)
OSHA considered modifying HCS to include:
Changing criteria for classifying health & physical hazards
Adopting standardized labeling requirements
Requiring a standardized order of information for MSDS
Final Rule anticipated at the end of 2008
*Summary of Slide Provide by Michelle Sullivan
USA ImplementationOther Agencies EPA/FIFRA:
Federal Register 25-Aug-2004 (situational analysis and white paper)
Stakeholder meeting 19-Oct-2006
CPSC:Beginning work on situation analysis
Current regulation includes consideration of risk, but not environmental endpoints.
*Summary of Slide Provide by Michelle Sullivan
Best Source Of Implementation Information
www.unece.org/trans/danger/publi/ghs/implementation_e.html
*Summary of Slide Provide by Michelle Sullivan
Comparison of various regulations and pieces of GHS classification accepted*Compiled from multiple slides prepared by Michelle Sullivan, Ph.D
GHS Hazard OSHA EPA DOT EU WHMIS Canada
PCP Canada
CCCR Canada
Australia
Skin Corrosion: Cat 1A, 1B, 1C
Cat 1A, 1B, 1C
Cat 1A, 1B, 1C
Cat 1A, 1B, 1C
Cat 1A, 1B, 1C
Cat 1 Cat. 1 Cat 1A, 1B, 1C Cat 1A, 1B, 1C
Skin Irritation: Cat 2, Cat 3
Cat 2, Cat 3
Cat 2, Cat 3
Cat 2 Cat 2, Cat 3 Cat 2, 3 Cat 2, Cat 3 pending
Cat 2, Cat 3 (only if EU excepts Cat 3)
Serious eye damage/Irritations: Cat 1, 2A, 2B
Cat 1, 2A, 2B
Cat 1, 2A, 2B
Cat 1, 2A,
Cat 1, 2A, 2B Cat 1, 2A, 2B
Cat 1, 2A, 2B Cat 1, 2A, 2B
Skin Sensitization: Cat 1
Cat 1 Cat 1 Cat 1 Cat 1 Cat 1 Pending Cat 1
Respiratory Sensitization: Cat 1
Cat 1 No Cat 1 Cat 1 Under discussion
Pending Cat 1
Germ Cell Mutagenicity: Cat 1A, 1B, 2
Cat 1A, 1B, 2
Does NOT require hazard labeling
Cat 1A, 1B, 2
Cat 1, 2 Cat 1A, 1B, 2 (only adopting for SDS purposes; risked based labeling)
Pending Cat 1A, 1B, 2
Cacinogencity: Cat 1A, 1B, 2
Cat 1A, 1B, 2
Does NOT require hazard
Cat 1A, 1B, 2
Cat 1, 2 Cat 1A, 1B, 2 (only adopting for SDS
Pending Cat 1A, 1B, 2
*Summary of Slide Provide by Michelle Sullivan
Comparison of various regulations and pieces of GHS classification accepted*Compiled from multiple slides prepared by Michelle Sullivan, Ph.D
GHS Hazard OSHA EPA DOT EU WHMIS
Canada PCP
Canada CCCR Canada
Australia
Reproductive Toxicity-Effects on lactation: Cat 1
Cat 1 Does NOT require hazard labeling
Cat 1 Cat 1 Cat 1 (only adopting for SDS purposes; risked based labeling)
Pending Cat 1
Reproductive Toxicity: Cat 1A, 1B, 2
Cat 1A, 1B, 2
Does NOT require hazard labeling
Cat 1A, 1B, 2
Cat 1, 2 Cat 1A, 1B, 2 (only adopting for SDS purposes; risked based labeling)
Pending Cat 1A, 1B, 2
Specific target organ-Single Cat 1, 2, 3
Cat 1, 2, 3
Methanol, Others?
Cat 1, 2, 3
Cat 1, 2, 3 Cat 1, 2 (only adopting for SDS purposes; risked based labeling); Cat 3 (under discussion)
Cat, Cat 2/3 Pending
Cat 1, 2, 3
Aspiration Toxicity: Cat 1,2
Cat 1,2 ? Cat 1 Under discussion
Under discussion
Cat 1,2 Pending Cat 1,2
*Summary of Slide Provide by Michelle Sullivan
Why was GHS developed?
So that a system exists where hazards are identically communicated to all those exposed
*Summary of Slide Provide by Michelle Sullivan
Other Challenges
Ingredient Disclosure (Purple book leaves it Competent Authority)
Additional Country Specific information that is outside classification
Labeling (especially for Consumer Products that have been historically risk based)
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