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Update and Latest Update and Latest Developments on the GHSDevelopments on the GHS
GHS Stocktaking Workshop For Southeast, East and Central GHS Stocktaking Workshop For Southeast, East and Central Asia Asia
15-17 September 201015-17 September 2010
Beijing, People’s Republic of ChinaBeijing, People’s Republic of China
Dr Peter DawsonDr Peter DawsonERMA New ZealandERMA New Zealand
2
Implementation update
Country/region updates
Building block approach
GHS membership
Technical developments
Updates from Rev.2 to Rev.3
Current and on-going work
Implementation issues
OutlineOutline
Implementation updateImplementation update
4Implementation Status (overview)Implementation Status (overview)
Slide from UNECE SCEGHS Secretariat
Detailed information about the status of implementation worldwide:
http://www.unece.org/trans/danger/publi/ghs/implementation_e.html
In force Capacity-buildingpreparation No information available
5Implementation Status (update)Implementation Status (update)
European Union
Implemented 20 January 2009 (Classification, Labelling and Packaging Regulation – CLP) Regulation (EC) No 1272/ 2008
Based on 2nd revised edition of GHS, some GHS categories not adopted
Chemicals must comply with c&l by 1 Dec 2010, Mixtures (products) must comply by 1 June 2015
1st amendment entered into force 25 September 2009
2nd amendment to bring into line with 3rd revised edition of GHS expected first half of 2011
CLP regulation (Annex VI) includes list of GHS classified chemicals – available online
6Implementation Status (update)Implementation Status (update)
New Zealand
Implemented July 2001 (for new substances) and applicable to all (new and existing substances) since July 2006
Implemented by regulations under Hazardous Substances and New Organisms Act 1996
Implementation based on draft GHS (pre first edition)
Amendments to bring into line with 3rd revised edition of GHS underway, expected to be in force early 2011
Published lists of GHS classified substances, available online
7Implementation Status (update)Implementation Status (update)
Australia
Following sectoral Building Block Approach
SafeWork Australia (workplace sector) – Australian Criteria for the Classification of Hazardous Chemicals (draft October 2009) – closely follows EU but adopts GHS 3rd edition
Implementation expected start 2012, over 5 years
2 years for chemicals, additional 3 years for mixtures
Office of Chemical Safety and Environmental Health (public health sector) – health hazards only – discussion paper April 2009 (GHS 2nd edition)
Adoption of all GHS classification criteria
Not proposing to adopt GHS pictograms or signal words
Risk based labelling approach
8Implementation Status (update)Implementation Status (update)
USA
Following sectoral Building Block Approach
OSHA (Occupational Safety and Health Administration) – workplace sector
Notice of Proposed Rulemaking on application of GHS to workplace chemicals – 30 September 2009
Adopts GHS 3rd revised edition
Comment periods and public hearings completed
Moving forward with drafting Final Rule
No confirmed publication date yet
Proposed date of entry into force – within 3 years of publication, during transitional period either existing or new (GHS) system may be used
9Implementation: Building Block Approach Implementation: Building Block Approach
What is the Building Block Approach?
Harmonised elements of the GHS – hazard classes, hazard categories – can be considered as components for forming a regulatory system
Provides flexibility to regulatory approaches
Accommodates sector specific needs
But, could lead to complexity and lack of harmonisation
Use of the same ‘building blocks’ at worldwide level for a given sector is encouraged
Transport sector has achieved GHS implementation internationally by adopting same ‘building blocks’ through UNRTDG (Re.16 aligned with GHS Rev.3)
GHS implementation: BBAGHS implementation: BBA Countries are implementing the GHS using BBA:
GHS hazard USA (Workpl)
EUCLP Reg.
NZ AUS(Workpl)
Korea Singapore
Flammable gas, Cat.2
Flammable liquid, Cat.4 4
Acute toxicity, Cat.5 1
Skin corrosion, Cat.3 1
Skin corrosion, Sub-Cat 1A/1B/1C
Serious eye damage Cat.2 (no sub-categ)
Serious eye damage Sub-cat.2A (only)
Respiratory/skin sensitization Cat.1A/1B
CMR, Cat.1A/1B
Aspiration hazard Cat.2 2
Aquatic hazard, Acute 1 n/a 3
Aquatic hazard, Acute 2 to 3 n/a 2 3
Aquatic hazard, Chronic 1, 2 n/a 3
Aquatic hazard, Chronic 3, 4 n/a 3
Green = adopted Red= not adopted1/ Consumer and domestic chemicals only - proposed change 2/ Proposed3/ Not mandatory (for information only) 4/ Diesel only n/a = not applicable* Data for USA, NZ and AUS according to draft proposals available at the time of writing (still subject to discussion and final adoption).
11Implementation: SummaryImplementation: Summary
Different levels of implementation
By country/region
EU, NZ implementing GHS in several sectors simultaneously
different ‘building blocks’ adopted
By sectors within countries
USA, Australia starting with workplace sector
Different transitional periods for implementation but most countries trying to match EU timeline (mid-2015)
GHS Sub-CommitteeGHS Sub-Committee Member States 36 full members:
Argentina, Australia, Austria, Belgium, Brazil, Canada, China, Czech Republic, Denmark, Finland, France, Germany, Greece, Iran, Ireland, Italy, Japan, Kenya, Netherlands, New Zealand, Nigeria, Norway, Poland, Portugal, Qatar, Republic of Korea, Russian Federation, Senegal, Serbia, South Africa, Spain, Sweden, Ukraine, UK, USA, Zambia
Observers*:
Cambodia, Cyprus, Gambia, Indonesia, Jamaica, Laos, Mexico, Philippines, Romania, Slovenia, Switzerland, Thailand, Uruguay, VietNam
* Countries which have participated as observers in at least one session (Slide courtesy UNECE SCEGHS Secretariat)
GHS Sub-CommitteeGHS Sub-Committee
Membership: member states (April 2010) (slide courtesy UNECE SCEGHS Secretariat)
= Full members = Observers
14GHS Sub-CommitteeGHS Sub-Committee
Observers
International organizations (IO’s) and UN specialized agencies
IMO, ILO, UNITAR, UNEP, WHO, FAO
Inter-governmental organizations (GO’s)
OECD, European Union
Non-governmental organizations (NGO’s)
Many industry related NGO’s
No labour or civil society NGO’s?
Technical developmentsTechnical developments
16Development of the GHSDevelopment of the GHS
GHS Sub-committee has 2-yearly work programmes (biennium)
GHS First edition: 2003
First version of GHS endorsed Dec 2002, published July 2003
GHS First revised edition: 2005
Aspiration hazard, developmental toxicity – ‘effects on or via lactation’, target organ toxicity - respiratory tract irritation/narcotic effects
GHS Second revised edition: 2007
Guidance on application of building block approach
Codification of hazard and precautionary statements
GHS Third revised edition: 2009
17Updates from GHS Rev.2 to Rev.3Updates from GHS Rev.2 to Rev.3
Classification criteria
Miscellaneous changes to clarify some classification criteria
Sub-categorization of respiratory and skin sensitizers
Subcategory 1A – strong sensitizers
Subcategory 1B – other sensitizers
Optional for competent authorities
Same label elements apply to Category 1 and to subcategories 1A and 1B
Different concentration cut-off values for mixture classification apply to subcategories 1A and 1B
18Updates from GHS Rev.2 to Rev.3Updates from GHS Rev.2 to Rev.3
Classification criteria
Hazardous to the aquatic environment
Revision of classification criteria for long-term aquatic hazard depending on whether adequate chronic toxicity data available and whether or not rapidly degradable
Different approach to classifying mixtures
New environmental hazard class
Hazardous to the ozone layer
Substances listed in Annexes to Montreal Protocol
Mixtures containing ≥ 0.1% of those substances
Introduces label elements for ODP substances
19Updates from GHS Rev.2 to Rev.3Updates from GHS Rev.2 to Rev.3
Labelling
New combined hazard statements for health hazards
Guidance on labelling of small packages
20Current biennium & beyondCurrent biennium & beyond
Work of Sub-Committee in 2009-2010 biennium and on-going
Explosives and related matters – classification of desensitized explosives, fireworks hazards, etc
Classification of chemically unstable gases and gas mixtures
Classification of metals for long-term aquatic hazards
Water activated toxicity (toxic gas released when wet)
Editorial revisions of chapters on skin corrosion/irritation and eye corrosion/irritation (chapters 3.2 and 3.3)
Further alignment of corrosivity criteria in UNRTDG with GHS
21Current biennium & beyondCurrent biennium & beyond
Work of Sub-Committee Working Groups in 2009-2010 biennium and on-going
Practical classification issues – development of classification examples for mixtures
Feeds into UNITAR training materials
Improvements of Annexes 1, 2 and 3 on label elements
Precautionary statements – rationalize and improve useability
Dust explosion hazards
Workplace hazard, but is it a GHS matter as not solely related to the instrinsic hazardous properties of a substance – difficult to classify
22Current biennium & beyondCurrent biennium & beyond
Work of Sub-Committee Working Groups in 2009-2010 biennium and on-going
Labelling of small packages – further guidance needed
Implementation issues
Consistent application of ‘building block’ approach – across sectors at national level, for single sector at international level. More guidance needed?
Management of different implementation timelines
Need for new hazard classes/ hazard categories
eg. For nanomaterials? Introduction of physical and chemical properties into safety data sheets considered
Further harmonisation of precautionary statements
Statement P410 – gases under pressure – ‘Protect from sunlight’
Flammable aerosols - pictogram for ‘gases under pressure’
23Current biennium & beyondCurrent biennium & beyond
Work of Sub-Committee Working Groups in 2009-2010 biennium and on-going
Implementation issues
Sector specific guidance material
Eg. IPIECA Guidance on application of GHS to petroleum substances
Need for a list of GHS harmonized classifications for chemicals?
Lists currently published by EU, NZ, Japan, Republic of Korea, UNECE secretariat for some substances in UNRTDG
Differences in classification noted – UNITAR survey, OECD study of classifications of Rotterdam chemicals
China, Japan, Republic of Korea working on joint project for GHS classification of chemicals
OECD eChem Portal – some GHS classified lists available there already
24Current biennium & beyondCurrent biennium & beyond
Work of Sub-Committee Working Groups in 2009-2010 biennium and on-going
Classification lists
Reasons for differences in results – different datasets used, differences in data interpretation
Need for more guidance, worked examples
For harmonized list using existing lists need to consider
Selection of data used for existing classifications
Development and maintenance of list – who/how?
Need to ensure transparency and record keeping for decisions taken on classifications
Suitable engagement process with stakeholders
Development of harmonized list a challenging issue – to be considered further by SCE GHS
Thank you!Thank you!