Global Status of GHS Presented by Paula Laux Senior Regulatory Specialist Wercs Professional Service

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Global Status of GHSPresented by Paula
LauxSenior Regulatory SpecialistWercs
Professional Services
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Why was GHS developed?

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

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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

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Who is the target audience?

• Governments
• Companies
• Workers
• Emergency Responders
• Member of the Public
• Consumers

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What types of Chemicals are Regulated?

• Hazardous Chemicals
• Substances
• Products
• Mixtures
• Pesticides
• Consumers Products

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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

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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

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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

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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

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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.

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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

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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)

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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

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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)

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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 SDS
• No intent to use GHS mixtures rule
• Want to address a revised GHS hazardous
  substances list
• Intent to make draft for labeling of Workplace
  Chemicals and Preparation of SDSs as well

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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

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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

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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.

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Best Source Of Implementation Information

• www.unece.org/trans/danger/publi/ghs/implementatio
  n_e.html

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Comparison of various regulations and pieces of
GHS classification acceptedCompiled from
multiple slides prepared by Michelle Sullivan,
Ph.D
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Comparison of various regulations and pieces of
GHS classification acceptedCompiled from
multiple slides prepared by Michelle Sullivan,
Ph.D
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Why was GHS developed?

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

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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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Global Status of GHS

• Questions/Comments?

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Global Status of GHSContact InformationPaula
LauxSenior Regulatory SpecialistWercs
Professional Services518 256-6774paulal_at_thewercs
.com