GHS SITUATION / GAP ANALYSIS

Phase 1 GHS – UNITAR Project on

Training and Capacity Building for The Implementation of The Globally Harmonized System of Classification and

Labelling of Chemicals (GHS) in Indonesia 2005 - 2007

NATIONAL AGENCY FOR DRUG AND FOOD CONTROL OF THE REPUBLIC OF INDONESIA

In collaboration with UNITED NATIONS INSTITUTION FOR TRAINING AND RESEARCH

(UNITAR)

UNITAR

REPORT

The 2005-2007 project on “Training and Capacity Building for Implementation of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS)” is executed in the context of the UNITAR/ILO Global GHS Capacity Building Programme with funding from the European Union and the Government of Switzerland.

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TABLE OF CONTENTS

PageContent Page Table of Contents........................................................... .............................. i1 Executive Summary..................................................... .............................. 1 2 Background Information............................................. .............................. 42.1 The Government of Indonesia........................................ .............................. 52.2 Principles Cities and Towns........................................... .............................. 52.3 Languages....................................................................... .............................. 52.4 Population ...................................................................... .............................. 62.5 Population Growth......................................................... .............................. 62.6 Literacy Rate................................................................... .............................. 112.7 Population of Working Age............................................ .............................. 11112.8 Average Education Level of Population......................... .............................. 11 3 Chemicals Profile in Indonesia.................................... .............................. 123.1 National Production of Chemical Substances and / or Mixtures................. 123.2 National Export Import of Chemical Substances and / or Mixtures............ 163.3 Chemical Use.................................................................. .............................. 203.4 Sector with Like hood of Chemicals Exposure.............. ............................... 223.5 Level of Participation in The Development of The GHS.............................. 223.6 Source of The GHS Information.................................... ............................... 22 4 Situation Analysis......................................................... .............................. 234.1 Government.................................................................... .............................. 234.1.1 Legal Information........................................................... ............................... 234.1.2 Institutional and Administrative Information................. .............................. 334.2 Business and Trade......................................................... .............................. 354.3 Civil Society................................................................... .............................. 37 5 Gap Analysis................................................................. .............................. 405.1 Industry........................................................................................................ 405.1.1 Government.................................................................... .............................. 405.1.2 Business and Trade......................................................... .............................. 475.1.3 Civil Society................................................................... .............................. 475.2 Agriculture.................................................................... .............................. 485.2.1 Government................................................................................................... 485.2.2 Business and Trade......................................................... .............................. 505.2.3 Civil Society.................................................................................................. 515.3 Transportation.............................................................. .............................. 515.3.1 Government................................................................................................... 515.3.2 Business and Trade......................................................... .............................. 555.3.3 Civil Society................................................................................................... 555.4 Consumer Product........................................................ .............................. 565.4.1 Government................................................................................................... 565.4.2 Business and Trade......................................................... .............................. 595.4.3 Civil Society................................................................... .............................. 59

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6 Conclusions.................................................................................................. 59 7 Next Steps...................................................................... .............................. 61 Annexes.......................................................................... .............................. 64 Annex 1 : Requirement on Labeling in SNI

(Indonesian National Standard) for Several Consumer Products..........................................................................

............................... 65

Annex 2 : Mechanism of Information Services on Poison Cases...................................................................

............................... 67

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1. EXECUTIVE SUMMARY Indonesia is the biggest archipelagic country all over the world. With its tropical climate, and having two seasons i.e., rain season and dry season, its agricultural sector is rapidly growing and this makes Indonesia to become an agricultural country. With more than 200 million people and consisting of more than 300 ethnic groups, Indonesia is rich in ethnical cultures.

Indonesia produces chemicals, a part of which is used internally and the rest is exported. Every year, the production and export of Indonesia’s chemicals increase progressively. However, Indonesia still imports chemicals from other countries and the import tends to increase every year. This is because the use of chemicals tends to increase from year to year.

The increase in the use of chemicals affects positively as well as in negative ways, especially to groups of users who are dealing much with these chemicals, e.g., those who are working in factories and transportation sectors, the consumers, and users in general. Generally, these groups consist of those having lower education, so that they do not understand the risk of the chemicals. Therefore, it is necessary to provide the chemicals with symbols and/or labels that can easily be understood by all sides.

Indonesia government has conducted some measures to minimize the possibility of negative impacts of the wide-spreading use of chemicals. Amongst these measures are the issue of regulations on classification, labeling and SDS (Safety Data Sheet). The government also made regulations on control of import in order to manage the distribution of chemicals coming from overseas.

Other attempts included the issue of regulations on trainings on chemical hazards and on the stipulation of reports on chemical accidents or toxicity.

There are some differences when we compare the chemical classification in Indonesia with that of the GHS. This is also the case with such regulations as that on labeling and Safety Data Sheet (SDS), in that Indonesia has not referred yet to the GHS. The existing regulations in Indonesia regulate only the classification, labeling or SDS separately. Nevertheless, there are some regulations that have included the classification, labeling, SDS, import, and training, but, again, these are not in line yet with the GHS.

These regulations are: - Government Regulation No. 74/2001 on Management of Hazardous and Toxic

substances, - Ministry of Health Decree No. 472/1996 on Safety of Hazardous Substances

for Human Health.

Most industries in Indonesia belong to middle and small scale industries or home industries. In addition, there are some foreign and domestic investment industries. The industry has the authority of making symbols and labeling for their products. However, since most of the industries are those of small scale industries, trainings on classification and labeling of chemicals according to the GHS have not been many conducted. However, some efforts in improving the awareness of the need for chemicals labeling have been making until now. Some of these efforts conducted between year 2004 and 2005 by industrial associations in Indonesia are

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seminars on GHS, technical discusions on GHS and GHS training which consist of 3 diferent levels i.e. basic, intermediate and advance.

Labeling and SDS of chemicals in Indonesia do not refer to the GHS yet. At present, chemical labels in the current market in Indonesia include trade name, net weight, producer’s name and address, and a warning: do not use on food. In general, the labels do not include danger symbols or pictograms.

As for the pesticide substance, the format of label refers to the regulation of ILO number 170 that specifies substance’s name, net weight, producer's name and address, direction of use, and danger symbol (according to ILO).

The SDS used in Indonesia refers to the Ministry of Manpower Decree No. 187/MEN/1999 on chemicals control at work place, which covers: 1. substance identity and company; 2. composition; 3. hazard identification; 4. first aid measures, 5. fire fighting measures; 6. measures to overcome leakage and spillage; 7. storage and handling of substance; 8. exposure control and personal protection; 9. physical and chemical properties; 10. reactivity and stability of substance; 11. toxicological information; 12. ecological information; 13. disposal of waste; 14. substance transportation; 15. regulatory information; 16. other necessary information;

Indonesian people in general, especially those who are susceptible to chemicals dangers, do not have adequate knowledge of chemicals danger, while the trainings performed to improve their capacity and knowledge were not adequate yet.

Some social observer groups or NGOs have conducted some awareness improvement efforts, although the efforts did not focus particularly on chemicals danger. Training activities that have been performed only included chemicals as one of sample case where chemicals consumer became the victim.

Specific research on chemicals danger has never been conducted by NGOs. Research relating to chemicals, which has been performed among others included test on active ingredients in detergent and mosquito repellent, and test on the additives in food packing.

Other effort conducted by government and NGOs to improve the public awareness of chemicals danger was spreading of booklets, leaflets, and posters. Publication and advocacy on chemicals danger is now being intensified through printed and electronic mass media.

Densely populated Indonesia is a potential market for chemical products. However, with various level of education and insufficient knowledge of chemical substance, Indonesian people may have a great potential to be exposed to the chemicals without being aware of their risks.

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Therefore, it is necessary to improve the people’s awareness of chemicals danger through socialization and trainings. In addition, it is of necessity to provide symbols or labels on chemicals packing indicating the dangers, which can be understood by all levels of society.

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2. BACKGROUND INFORMATION

Indonesia is the world’s largest archipelago, consists of five major islands and about 30 smaller groups and has the total number of islands approximately 17,500. The sea area is four times greater than that of the land area, which is about 1.9 million sq km. The sea area is about 7.9 million sq km (including an exclusive economic zone), constituting about 81% of the total area of the country. The islands span more than 3,000 miles from east to west, and more than 1,200 miles from North to South.

The climate is tropical with temperature ranging from 8 to 92 degrees Fahrenheit. Humidity ranges from 60 to 90 %. Indonesia’s rainy season last from November to April, with a peak around January and February, where it can be rainy for the whole day. Then, comes the dry season from May to October.

The archipelago is on the crossroad between two oceans, the Pacific and the Indian Ocean and bridging two continents Asia and Australia. This strategic position has always influenced the cultural, social, political and economic life of the country.

The territory of the Republic of Indonesia stretches from 6ο 08’ north latitude to 11ο 15’ south latitude and from 94ο 45’ to 141ο 05’ east longitude.

The five main islands are Sumatra, which is about 473,606 sq km in size, the most fertile and densely populated islands Java and Madura 132,107 sq km, Kalimantan which comprises two third of the island of Borneo 539,460 sq km, Sulawesi 189,216 sq km, and Papua 421,981 sq km, which is the world’s second largest island.

The Republic of Indonesia shares land frontiers with Malaysia and Brunei on the Islands of Borneo and with Papua-New Guinea. It has sea boundaries with East Timor, Malaysia, Singapore, Vietnam, the Philippines and Australia.

Figure 1. Geographical map of Indonesia

PAPUA

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2.1 The Government of Indonesia Indonesia is a unitarian republic with sovereignty vested by the elected person who are fully represented in the People’s Consultative Assembly.

According to the 1945 Constitution there are six organs of the state i.e.: a. The People’s Consultative Assembly b. The Presidency c. The House of Representative d. The Supreme Advisory Council e. The State Audit Board BPK – the financial Supervision Board f. The Supreme Court g. The National Planning Board

Indonesian political system is based on Pancasila (the Five Principles), with the principle of democracy based on consensus through deliberations.

2.2 Principal Cities and Towns

Table 1: Principal Cities and Towns

Main Island Major City/Town Population (millions)

Java Jakarta

Surabaya

Bandung

Semarang

8.4

3

2

1.5

Bali Denpasar 0.3

Sumatra Medan

Palembang

2.1

1.3

Kalimantan Banjarmasin 0.6

Sulawesi Makassar 1.2 Source: CBS – Statistics Indonesia, 2000

2.3 Languages More than 200 million people from over 300 distinct ethnic groups (with different dialects) call Indonesia their home, making Indonesia the fourth most populous nation in the world (after China, India and U.S.). Fortunately, Indonesia has one official language called “Bahasa Indonesia” which literally means “The Language of Indonesia”. There are approximately 580 local languages with various dialects spoken. Some of the distinctly different local languages are Acehnese, Bataks, Sundanese, Ambonese, Javanese, Sasak, Dayak, Minahasa, Toraja, Bugisnese, Ceramese and a number of Irianese languages.

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2.4 Population Indonesia is the world fourth most populous country. On the basis of the Population Census conducted in 2000, the total population of Indonesia on 30 June 2000 was 206,264,595 people. The summary of total population as the result of the 1971-2000 Population Census is presented in Table 2. As with some countries, particularly those in the developing world, the towns and cities are always the major attraction for the rural population. This is undoubtedly when the land is no longer offers an effective means to earn a living. Indonesia is no exception. Over the years, particularly after World War II, cities have been growing rapidly in terms of area size and population so that municipal governments have not been very successful in coping with the impact of urbanisation.

Trend of urban population in Indonesia and in all provinces had been increasing. In 2000, the percentage of urban population reached 42 percent. The increasing population live in urban areas reflected the urbanization process. Rural population are 58 % of the total population who live and work in sub districts, municipalities and villages.

Indonesia’s population is concentrated in Java Island. According to the 2000 Population Census, Java Island which has only 7 percent of total area of Indonesia was resided by around 59 percent of the population. Meanwhile Maluku, North Maluku and Papua which have 24 percent of total area of Indonesia, were inhabited only by 2 percent of the population.

2.5 Population Growth The Average Annual Population growth during 1990-2000 period was 1.49 percent (see Table 3). This figure was far lower than the annual population growth for 1980-1990 period, which was 1.97 percent. One main factor contributing to the decreasing population growth was mostly due to the success in family planning program. The Population Growth Data does not include East Timor since this region has had its own sovereignity become an independent nation. The effect of migration on population growth in Indonesia as a whole is negligible because of the small difference between emigration and immigration rates.

According to the Population Census, the Total Fertility Rate (TFR) in 1998 and 1999 was 2.65 and 2.59, respectively. While the Total Infant Mortality Rate (IMR) in 1998 and 1999 was 49 and 46, respectively.

The reason for the decline mortality rate is related to better nutrition, rising standard of living, advances in medical science, development of medical facilities, improved health measures, better working conditions and advances in education related to personal hygiene.

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Table 2 : Population of Indonesia by Province in 1971, 1980, 1990, 1995 and 2000

Population Number No. Province

1971 1980 1990 1995 2000

1. Nanggroe Aceh Darussalam 2,008,595 2,611,271 3,416,156 3,847,583 3,930,905

2. North Sumatra 6,621,831 8,360,894 10,256,027 11,114,667 11,649,655

3. West Sumatra 2,793,196 3,406,816 4,000,207 4,323,170 4,248,931

4. Riau 1,641,545 2,168,535 3,303,976 3,900,534 4,957,627

5. J a m b i 1,006,084 1,445,994 2,020,568 2,369,959 2,413,846

6. South Sumatra 3,440,573 4,629,801 6,313,074 7,207,545 6,899,675

7. B e n g k u l u 519,316 768,064 1,179,122 1,409,117 1,567,432

8. L a m p u n g 2,777,008 4,624,785 6,017,573 6,657,759 6,741,439

9. Bangka Belitung Islands* - - - - 900,197

10. DKI Jakarta 4,579,303 6,503,449 8,259,266 9,112,652 8,389,443

11. West Java 21,623,529 27,453,525 35,384,352 39,206,787 35,729,537

12. Central Java 21,877,136 25,372,889 28,520,643 29,653,266 31,228,940

13. DI Yogyakarta 2,489,360 2,750,813 2,913,054 2,916,779 3,122,268

14. East Java 25,516,999 29,188,852 32,503,991 33,844,002 34,783,640

15. Banten* - - - - 8,098,780

16. B a l i 2,120,322 2,469,930 2,777,811 2,895,649 3,151,162

17. West Nusa Tenggara 2,203,465 2,724,664 3,369,649 3,645,713 4,009,261

18. East Nusa Tenggara 2,295,287 2,737,166 3,268,644 3,577,472 3,952,279

19. West Kalimantan 2,019,936 2,486,068 3,229,153 3,635,730 4,034,198

20. Central Kalimantan 701,936 954,353 1,396,486 1,627,453 1,857,000

21. South Kalimantan 1,699,105 2,064,649 2,597,572 2,893,477 2,985,240

22. East Kalimantan 733,797 1,218,016 1,876,663 2,314,183 2,455,120

23. North Sulawesi 1,718,543 2,115,384 2,478,119 2,649,093 2,012,098

24. Central Sulawesi 913,662 1,289,635 1,711,327 1,938,071 2,218,435

25. South Sulawesi 5,180,576 6,062,212 6,981,646 7,558,368 8,059,627

26. South-East Sulawesi 714,12 942,302 1,349,619 1,586,917 1,821,284

27. Gorontalo* - - - - 835,044

28. M a l u k u 1,089,565 1,411,006 1,857,790 2,086,516 1,205,539

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Population Number

No. Province 1971 1980 1990 1995 2000

29. North Maluku* - - - - 785,059

30. Papua 923,44 1,173,875 1,648,708 1,942,627 2,220,934

INDONESIA 119,208,229 146,934,948 178,641,595 193,915,089 206,264,595

Source: 1971, 1980, 1990, 2000 Population Census, and 1995 Intercensal Population Census. *) new provinces

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Table 3 : Population Growth by Province

Average Population Growth Rate No. Province

1971-1980 1980-1990 1990-2000

1. Nanggroe Aceh Darussalam 2.93 2.72 1.46

2. North Sumatra 2.6 2.06 1.32

3. West Sumatra 2.21 1.62 0.63

4. Riau* 3.11 4.30 4.35

5. Jambi 4.07 3.40 1.84

6. South Sumatra 3.32 3.15 2.39

7. Bengkulu 4.39 4.38 2.97

8. Lampung 5.77 2.67 1.17

9. Bangka Belitung Islands 0.97

10. DKI Jakarta 3.93 2.42 0.17

11. West Java 2.66 2.57 2.03

12. Central Java 1.64 1.18 0.94

13. DI Yogyakarta 1.1 0.57 0.72

14. East Java 1.49 1.08 0.70

15. Banten 3.21

16. Bali 1.69 1.18 1.31

17. West Nusa Tenggara 2.36 2.15 1.82

18. East Nusa Tenggara 1.95 1.79 1.64

19. West Kalimantan 2.31 2.65 2.29

20. Central Kalimantan 3.43 3.88 2.99

21. South Kalimantan 2.16 2.32 1.45

22. East Kalimantan 5.73 4.42 2.81

23. North Sulawesi 2.31 1.6 1.33

24. Central Sulawesi 3.86 2.87 2.57

25. South Sulawesi 1.74 1.42 1.49

26. South-East Sulawesi 3.09 3.66 3.15

27. Gorontalo 1.59

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Average Annual Population Growth Rate No. Province

1971-1980 1980-1990 1990-2000

28. Maluku 2.88 2.79 0.08

29. North Maluku 0.48

30. Papua 2.67 3.46 3.22

31. Islands of Riau - - -

INDONESIA 2.31 1.98 1.49

*) Including the establishment of the new province in 2002 i.e. the Islands of Riau. Source: CBS – Statistics Indonesia, 1971, 1980, 1990, 2000 Population Census, and 1995 Intercensal Population Census.

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2.6 Literacy Rate With reference to the 2000 Population Module Survey conducted by Central Board Statistic (CBS Indonesia) for population segment i.e. 10 years of age and over, the literacy rate of the urban population was 94.8% in comparison to 86.5% for rural population, and the average of national literacy rate was 90.1%.

2.7 Population of Working Age From the National Labour Force Survey in 2001 (CBS Indonesia), the number of population with 15 years of age and over was 144,033,873 people. The number of population with 15 years of age and over who worked was 90,807,417 people.

2.8 Average Education Level of Population From the results of the 2000 Population Module Survey (CBS Indonesia) for urban and rural population, the average education level of population for 10 years of age and over was 48.4% graduated from primary and junior high school, 15.3% from senior high school, 3.3% graduated from higher education, 23.6% did not or have not yet completed primary school, and 9.4% never or not yet attended school.

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3. CHEMICALS PROFILE IN INDONESIA

This chapter is aimed to summarize the situation of chemicals production, use, importation and exportation for 2002 and 2003, highlight of potential chemicals exposure and a brief information in conjunction with Globally Harmonized System of Classification and Labelling of Chemicals.

3.1 National Production of Chemical Substances and/or Mixtures Production, uses and exportation of Chemicals tend to increase annually and are predominated by base organic chemicals. Local production of chemicals varies ranging from special chemicals, pharmaceutical preparations, artificial fertilizer, petrochemical and cleaning products. In agricultural sector, Indonesia produces pesticides in the forms of active ingredients such as glyphosate and propoxur, and a number of pesticide formulations containing more than one ingredient, for instance Glifomin 300/100 AS, Wallop 240/110 WSC, and many others. Data on chemicals production and related information is shown in the following table:

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Tabel 4 : Breakdown Annual Production of Chemicals

Production

Chemical Type Unit Quantity Value

(in 000 Rupiah) Industrial Use

BASIC INORGANIC

- Chloride and Alkali - Industrial Gases

Ton

Ton M3

637,330

1,613,714 11,487,596

286,407,397

1,634,273,612 54,256,788

- Pigment - Inorganic Chemicals not

classified

Ton

Ton Units M3

57,694

9,254,591 547,054 263,180

418,146,399

3,038,771,724 97,566,519

827,463 BASIC ORGANIC - From animals/vegetables

origin - Colouring Materials,

Colouring and Pigments - From Crude Oil, Natural

Gas and Coal - Special Chemicals - Organic Chemicals non

classified

Ton M3

Units

Ton

Ton

Ton M3 Ton M3

161,927

2,640 720,000

45,700

1,618,813

369,289 4,503

1,654,982

4,503

371,119,714

10,945,625 1,224,000

780,725

4,302,050,140

2,535,222,035 55,414,542

5,136,068,979

184,731,523 SYNTHETIC RESINS SYNTHETIC RUBBERS

Ton Rolls

Ton

Metres

1,525,613 50,000

40,656

2,873,001

5,758,261,791 30,000,000

210,385,931

1,182,621

Industrial Use

SYNTHETIC FIBRES - Artificial filament fibre - Artificial staple fibre

Ton Rolls

Ton

Metres M3

170,640

50,702

606,502 8,393,332

411,818,891

770,129,462

6,539,971

3,568,553,995 36,562,066

1,889,684,526

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Production

Chemical Type Unit Quantity Value

(in 000 Rupiah) Petroleum Products

Products of coal Petroleum refineries Natural gas refineries Products of petroleum refineries Lubricating oil

Ton

Ton mmBTU

Ton

M3

Units

2,957

55,815

9,155,302

11,155,117

15,771 3,616,230

6,030,924

19,252,314

183,106,040

577,265,257

31,607,078 10,908,280

PESTICIDES - Pesticides raw materials - Pesticides formulation :

- Insecticides - Disinfectants

- Herbicides

- Fungicides

- Other pesticides - Plant Growth

Regulators

Ton

Ton M3

Dozens Units

Bottles

Ton

Ton M3

Ton M3

Ton

Litres

Bal

62,117

2,862 4,379

20,846,237 70,412,579 2,536,816

82

1,538

19,649

7,465 598,242

4

758

231

141,745,123

33,608,855 67,792,886

564,588,922 28,485,985 19,866,000

14,699,558

18,405,452

384,677,750

18,142 7,081,396

89,721,537 33,966,782

16,174

Specific Chemicals

FERTILIZERS - Natural/non-synthetic

fertilizers - Straight fertilizers - Mixed compounds and

complex fertilizers - Other fertilizers

Ton

Ton

Ton

Ton Bottles

726,751

7,136,643

26,625

125 835,896

89,537,860

5,419,186,163

56,256,545

576,481 3,020,012

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Production Chemical Type Unit Quantity Value

(in 000 Rupiah) PETROCHEMICAL PRODUCTS** - Olefins - Aromatics

Ton Ton

9,966,683 2,432,030

NA NA

SOAP AND CLEANING PREPARATIONS

Ton Dozens

M3 Units Tubes

601,697,714 2,157,585

39,881 183,593,743 12,098,286

2,160,880,375 212,115,754 274,430,125 135,032,811 82,704,487

COSMETICS

Ton Dozens

Unit Bottles

96,918 8,087,363

318,065,076 47,099,700

536,448,565 68,537,884

895,868,853 123,176,422

PAINTS, VARNISHES, LACQUERS

Ton M3

231,185 43,530

3,016,668,037 262,486,258

Consumer Chemicals

PHARMACEUTICALS - Pharmaceutical raw

materials - Pharmaceutical

preparations - Herbal preparation - Herbal Medicine

Ton

Dozens Bottles Units

Ton M3

Bottles Set

Units Tube

Ampoule Bal

Sheets

Ton Unit

Bottles Dozens

Bal Set Unit

303

439,101,543 65,738

2,158,778,564

21,749 15,273

169,162,569 16,044,239

11,279,931,093 99,213,543

477,529,052 1,324,154 4,342,149

1,315 189,405

1,368,923

204,372,887 23,065,604 35,150,952 69,651,807

62,653,625

117,049,460 20,467,536 62,471,611

135, 243,046 335,266,158

1,431,677,837 397,774,781

3,134,500,985 320,212,032 720,312,087 198,674,093 20,157,475

8,040,524 2,760,098

3,058,315

148,085,537 15,990,513 10,889,225

40,842,225

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Production Chemical Type

Unit Quantity Value (in 000 Rupiah)

Miscellaneous Chemicals

- Adhesives - Explosives and

Ammunition

Ton M3

Rolls

Ton Bal

Units

536,273 144,129

49,290,969

6,280 18,974

3,344,561

1,377,792,227 84,845,474

144,566,077

40,891,206 3,950,417

553,198 - Ink

- Essential oil - Matches - Chemicals not classified

Ton

Ton M3

Bottles Dozens

Unit Set

Bal

Ton M3

Rolls Units

1,567

3,158,012 270

14,242,318 150,726 245,280

2,000,000

9,871,886

64,197 5,822

445,529 38,461,743

27,501,469

323,131,714 11,001,515 52,434,269 1,065,516 1,575,901 7,000,000

307,512,825

396,362,241 12,366,883

141,657,767 224,774,085

TOTAL - - 56,178,745,536

*) Source : CBS – Statistics Indonesia, Large and Medium ManufacturingStatistics, 2000 **) Source : Development of Petrochemicals Industries in Indonesia, 2001 (Data in 1999 – Ministry of

Industry and Trade)

3.2 National Export Import of Chemical Substances and/or Mixtures

Based on their types, the volume of chemicals export tends to increase mainly for inorganic chemicals; organic compound or inorganic of inert metals, of rare earth metals, of radioactive and radioisotope elements; organic chemicals, fertilizers; soaps, organic surface actuators, detergent peparation, lubricant peparation, artificial and processed wax, polisher peparation, candle and the likes, pastes for model making, tooth casting waxes, dan gypsum-based tooth casting peparation; photographyc or cinematographyc goods as described on Table 5.

Indonesia imports various types of chemicals and their products from Japan, South Korea, Taiwan, China, Singapore, Malaysia, India, Australia, United States, the Netherland, Germany, Great Britain, Hongkong, and Thailand (see Table 6). The main chemicals imported include inorganic chemicals; organic and inorganic compound of inert metals, of rare earth metals, of radioactive and radio-isotope elements; organic chemicals, fertilizers; soaps, organic surface stimulating agent, detergent peparation, lubricant peparation, artificial and processed wax, polisher peparation, candle and the likes, pastes for model

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making, tooth casting waxes, dan gypsum-based tooth casting peparation; various chemical products. Data is shown in the following table:

Table 5 : Chemicals Export Based on the Industry Type

2002 2003 HS

Code HS Description Net Weight CIF Net Weight CIF

Net Weight Ratio

Net Weight Ratio

(kg) US $ (kg) US $ (%) (%) [1] [2] [3] [4] [5] [6] [7] [8]

28

Inorganic chemicals, organic and inorganic compound of inert metals, of rare earth metals, of radio-active and radio-isotope elements

1.288.703.537 166.203.829 1.534.557.241 256.634.019 19,08 54,41

29 Organic chemicals 2.296.009.545 1.077.709.117 2.279.318.646 1.224.132.953 -0,73 13,59

30 Pharmacetical product 9.399.392 87.205.419 12.889.396 97.614.736 37,13 11,94

31 Fertilizer 1.198.169.944 134.646.052 1.314.518.187 187.860.389 9,71 39,52

32

Tanning extract or coloring matter; tanning substance and its derivative; dyeing material, pigment and other coloring agent; paints; varnishes; lacquers; ink

55.459.400 119.098.918 50.266.220 140.808.443 -9,36 18,23

33

Essential oil and resinoids, perfumes, cosmetics or perfuming preparations

43.692.849 145.523.143 55.289.654 156.322.066 26,54 7,42

34

Soaps, organic surface actuators, detergent peparation, lubricant peparation, artificial and processed wax, polisher peparation, candle and the likes, pastes for model making, tooth casting waxes, and gypsum-based tooth casting preparation

299.985.661 227.373.094 317.211.366 252.248.586 5,74 10,94

35 Albumins; modified starches; glues; enzymes

14.489.608 11.709.182 16.552.862 14.737.243 14,24 25,86

18

2002 2003 HS

Code HS Description Net Weight CIF Net Weight CIF

Net Weight Ratio

Net Weight Ratio

(kg) US $ (kg) US $ (%) (%) [1] [2] [3] [4] [5] [6] [7] [8]

36

Explosieves; pyrotechnic product; matches; pyrophoric mixture, spesific flammable preparations

9.560.785 9.822.540 9.330.447 11.940.673 -2,41 21,56

37 Photography or Cinematography goods

448.819 5.421.424 516.049 3.809.734 14,98 -29,73

38 Various chemical product 579.027.747 335.561.129 585.140.085 321.137.856 1,06 -4,30

Total 5.794.947.287 2.320.273.847 6.175.590.153 2.667.246.698 6,57 14,95

Source: CBS – Statistics Indonesia, 2004

19

Table 6 : Chemicals Import based on the Industry Type

2002 2003 HS

Code HS Description Net Weight CIF Net Weight CIF 2002 2003

(kg) US $ (kg) US $ (%) (%) [1] [2] [3] [4] [5] [6] [7] [8]

28

Inorganic chemicals, organic and inorganic compound of inert metals, of rare earth metals, of radio-active and radio-isotope elements

1.745.993.873 471.058.714 1.661.271.804 459.133.168 -4,85 -2,53

29 Organic chemicals 3.351.170.763 2.081.272.475 2.801.000.014 2.160.898.325 -16,42 3,83

30 Pharmacetical product 7.085.123 98.861.506 7.280.509 127.222.758 2,76 28,69

31 Fertilizer 1.800.705.923 246.494.161 1.570.466.264 230.180.463 -12,79 -6,62

32

Tanning extract or coloring matter; tanning substance and its derivative; dyeing material, pigment and other coloring agent; paints; varnishes; lacquers; ink

228.156.585 407.291.011 171.937.069 352.377.845 -24,64 -13,48

33

Essential oil and resinoids, perfumes, cosmetics or perfuming preparations

30.738.281 190.019.169 33.468.468 193.125.178 8,88 1,63

20

2002 2003

HS Code HS Description Net Weight CIF Net Weight CIF

2002 2003

(kg) US $ (kg) US $ (%) (%) [1] [2] [3] [4] [5] [6] [7] [8]

34

Soaps, organic surface actuators, detergent peparation, lubricant peparation, artificial and processed wax, polisher peparation, candle and the likes, pastes for model making, tooth casting waxes, and gypsum-based tooth casting preparation

188.585.500 233.608.785 186.534.577 242.489.782 -1,09 3,80

35

Albumins; modified starches; glues; enzymes

113.401.733 116.567.111 112.373.247 108.187.203 -0,91 -7,19

36

Explosieves; pyrotechnic product; matches; pyrophoric mixture, spesific flammable preparation

5.170.069 22.614.473 3.592.423 16.145.144 -30,51 -28,61

37 Photography or Cinematography goods

11.585.285 65.969.379 11.673.895 63.976.207 0,76 -3,02

38 Various chemical product 326.662.475 491.756.976 290.372.102 438.338.911 -11,11 -10,86

Total 7.809.255.610 4.425.513.760 6.849.970.372 4.392.074.984 -12,28 -0,76

Source: CBS – Statistics Indonesia, 2004

3.3 Chemical Use Indonesia is an importing country, but in another side also producer of raw materials for industries and various chemical products including goods (PVC pipes, roof, paint). The tendency of chemical usage is increasing from year to year in line with the inter-relation of technology innovation and science on the one side to the society’s need pattern (supply-and-demand) or the increase in the society’s need on the other side. The major use of chemicals is in the base organic

21

chemical industries that produce special chemicals. Profile of chemicals usage is shown in Table 7.

Table 7 : Type of Chemicals and the Usage Value

Type of Chemical Units Amount Used per Year

PESTICIDES

- Pesticides Raw Material

- Pesticides

Ton M3

Units

Ton Units

501,641 3,047

10,300,000

469 35,265,136

FERTILIZERS Ton 1,552,361 PETROCHEMICAL PRODUCTS** Ton 1,256,418 INDUSTRIALCHEMICALS

- Basic Inorganic Chemicals

- Basic Organic Chemicals

- Synthetic Resins

- Synthetic Rubbers

- Synthetic Fibres

Ton M3

Ton M3

Ton

Ton

Ton

9,571,671 2,203,558

3,739,291 847,301

2,037,798

133,839

606,861 CONSUMER CHEMICALS

- Pharmaceuticals

- Soap and Cleaning Preparations

- Cosmetics

- Paints, Varnishes and Lacquers

Ton

Ton

Ton

Ton

138,255

33,244,321

30,312,771

145,470,793 MISCELLANEOUS CHEMICALS

- Adhesives

- Explosives and Ammunitions

- Ink

- Essential Oils

- Matches

- Chemicals non classified

Ton

Ton

Ton

Ton

Units

Ton

928,308

13,219

22,052

21,582

2,912

3,550,203

T O T A L Ton

M3

Units

233,101,853

3,053,906

48,621,954

*) Source : CBS – Statistics Indonesia, Large and Medium ManufacturingStatistics, 2000 **) Source : Development of Petrochemicals Industries in Indonesia, 2001 (Data in 1999 – Ministry

of Industry and Trade)

22

3.4 Sector with high likehood of chemical exposure The tendency of the increase in the chemicals use causes the possibility of the increase in chemical exposure to the worker groups in the factories and transport sector, as well as to the producers and consumers/users.

3.5 Level of Participation in The Development of The GHS Indonesia once attended for the first time the UN Subcommittee of Expert on the GHS (UN SCEGHS) as an observer. Indonesia is a member of the Intergovernmental Forum on Chemical Safety (IFCS) that took part in Asia Pasific Economic Cooperation (APEC) forum in chemical dialogue, in co-operation with Japan (Jetro & The Association for Overseas Technical Scholarship (AOTS)).

3.6 Source of The GHS Information Nowadays, the public may get information on the GHS through the government and other routes (e.g. Chemical Industry associations) through seminars, workshops, and trainings.

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4. Situation Analysis

4.1 Government

4.1.1 Legal Information Currently, there exist some legislations or standards which is relevant to the chemical substance hazard communication :

a. Regulations on Chemical Substance Classification Legislation on classification of chemical substance are as follow : 1) Government Regulation No. 74/2001 on Management of Hazardous and

Toxic Substance This regulation only regulating three stage of chemicals life cycle i.e.

export, import and transport. Industrial, agriculrue sector, Classification described in this regulation is based on: - Physical-chemical properties: Explosive, Oxidizing, Flammability

(Extremely flammable, Highly flammable, Flammable) - Health hazard : Toxic (Extremely toxic, Highly toxic, Toxic),

Corrosive, Irritant, Carcinogenic, Teratogenic, Mutagenic effects - Environmental hazard : Dangerous to environment

2) Ministry of Health Decree No. 472/1996 on Safety of Hazardous Substances for Human Health

Classification described in this regulation is based only on health hazard, such as toxic, corrosive, carcinogenic, teratogenic and mutagenic.

3) Minister of Industry Decree No.148/M/SK/1985 on Safety Management of Toxic and Hazardous Substances in Industrial Company

Classifications described in this regulation are based on: - Physical and chemical property : explosive, oxidator and reductor,

flammable, explosive, gases under pressure, and radioactive - Health hazard : toxic, corrosive/irritant and other hazardous

substance specified by Minister of Industry

4) Ministry of Manpower Decree No. Kep 187/MEN/1999 on Control of Hazardous Chemicals in the Workplace

Classifications described in this regulation are based on: - Physical and chemical property : explosive, oxidator, flammable

liquid, highly flammable liquid, flammable gas, reactive substance - Health hazard: Highly toxic substance and toxic substance

5) Minister of Manpower Circulated Letter No. SE-01/MEN/1997. Classifications in this regulation is based on its carcinogenicity: - A1 : Confirmed Human Carcinogen. Chemical substances with

carcinogenic effect to human, based on positive evidence from epidemiological studies or convincing clinical evidence in exposure to human.

- A2 : Suspected Human Carcinogen. Chemical substances with carcinogenic effect to animal with certain dose, through the route, locations, from histological type or mechanism of exposure that is considered to be suitable to the exposed object. Not enough evidence

24

- form the existing epidemiological studies to prove the increase of cancer risk on exposed human.

- A3 : Confirmed Animal Carcinogen. Chemical substances with carcinogenic effect to animal with relatively high dose through the route, locations, from histological type or mechanism of exposure that is considered less suitable to the exposed object.

- A4 : Not Classified as Human Carcinogen. Not enough data available to classify the substances as human or animal carcinogen.

- A5 : Not Suspected as Human Carcinogen

6) Ministry of Agriculture Decree No. 434.1/Kpts/TP.270/7/2001 on Conditions and Procedures of Pesticides Registration Classifications described in this regulation are based on: - Physico-chemical properties : registerable pesticide and prohibited

pesticide - Health hazard : eye-corrosive pesticide, skin-corrosive pesticide pada

mata

7) Government Decree No. 41/1993 on Land Transportation Classifications described in this regulation are based on: − Physico-chemical properties : explosive; pressured gas, liquid gas,

gas soluble at certain pressure and temperature; flammable liquid; flammable solid; oxydator, organice peroxide; radioactive dan corrosive

− Health hazard : toxic, infectious substance and other hazard.

8) Ministry of Transportation Decree No. 17/2000 on Guidance of Hazardous Substances Handling in Maritime Operation in Indonesia

Classification described in this regulation refers to the IMDG Code, consists of 9 hazard-class: exlosive; gas substance; flammable liquid substance; flammable solid substance, easily oxidizable substance and organic peroxide; toxic and infectious substance; Radioactive; corrosive substance and other hazardous substance.

9) Director General of Land Transportation Decree No. SK.725.AJ.302/DRJD/2004 on Transportation of Hazardous and Toxic Substances on the Road Classifications described in this regulation are explosive; pressured gas, liquid gas, gas soluble at certain pressure and temperature; flammable liquid; flammable solid; oxidator, organic peroxide; toxic and infectious substance; radioactive; corrosive substance; and other hazardous substance.

b. Regulations on Chemical Substance Labelling Regulations on chemical substance labelling are as follows : 1) Government Regulation No. 74/ 2001 on Management of Hazardous and

Toxic Substance It obligates each package of hazardous and toxic substance shall be

provided with symbol and label. However, no detail of elements to be included in the lable mentioned.

2) Ministry of Health Regulation No. 239/Menkes/Per/V/1985 on Spesific Coloring Agent defined as Hazardous Substance

25

It states that in the specific coloring substance label shall include the words of "DO NOT USE IN DRUG, FOOD AND COSMETICS” or ”DO NOT USE IN DRUG AND FOOD".

3) Ministry of Manpower Decree No. Kep 187/MEN/1999 on Control of Hazardous Chemicals in the Workplace

It states that the label shall include trade or generic name, active inggredients, net weight/volume, warning words and sign or hazard symbol, and first aid measures.

4) Ministry of Manpower Decree No. Kep 187/MEN/1999 on Control of Hazardous Chemicals in the Workplace

It states that the label shall include the description of product name, hazard identification, hazard sign and its meaning, risk description and tackling, prevention precautions, instruction in case of exposure or contact, instruction in case of fire, instruction in case of spillage or leakage, instruction of filling and storage, refences, name, address and telephone number of the manufacture or distributor.

5) Ministry of Industry and Trade Decree No. 254/MPP/KEP/7/2000 On Import and Distribution of Specific Hazardous Substances

It states that the label shall include the substance name, new-weight, label/symbol and first aid measures. For imported hazardous substance, the label shall follow national regulation and according to terms and conditions of the International Maritime Dangerous Goods (IMDG) Code.

6) Ministry of Agriculture Decree No. 434.1/Kpts/TP.270/7/2001 on Conditions and Procedures of Pesticides Registration

According to this regulation, the label shall include content, signal word and first aid direction, toxicity symptom explanation, first aid direction, information of storage, direction of usage, pictogram, label of limited pesticide.

7) Ministry of Transportation Decree No. 69/1993 on Land Transportation of Substance

It regulates that hazardous substance label shall include the pictogram and hazard statement.

8) Ministry of Transportation Decree No. 17/2000 on Guidance of Hazardous Substances Handling in Maritime Operation in Indonesia

It states that the labelling of hazardous substance has to refer to the IMDG Code, and shall contain hazard pictogram, warning words and lable color.

9) Directorate General of Land Transportation Decree No. SK.725.AJ.302/DRJD/2004 on Land Transportation of Hazardous and Toxic Substances

It states that each package of hazardous and toxic substances (B3) shall be provided with symbol and label which suitable to hazardous substance to be transported.

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c. Regulations on chemical substance MSDS Regulations on chemical substance MSDS are as follow: 1) Government Regulation No. 74/2001 on Management of Hazardous and

Toxic substances. According to this regulation, MSDS shall include brand name, chemical

formula, type, classification, storage direction, and handling procedure in the case of accident.

2) Ministry of Health Decree No. 472/1996 on Safety of Hazardous Substances for Human Health.

MSDS shall include substance name, brand name, address and phone number of manufacturer, chemical formula, CAS Number, hazard risk, handling of spillage or leakage, handling and storage, personal protection and exposure control, physico-chemical propertites, stability and reactivity, toxicological information, ecological information, disposal method, transportation method, labelling, antidote and other information

3) Ministry of Manpower Decree No. Kep. 187 / MEN / 1999 On the Control of Hazardous Chemicals at Workplace.

MSDS shall include the description of Substance and supplier identity, Composition, Hazard identification, First aid measures, Fire fighting measures, Precautions of spillage or leakage, Handling and storage, Exposure control and personal protection, Physical and chemical properties, Stability and reactivity, Toxicological information, Ecological information, Disposal consideration, transportation, information on valid regulation and other necessary information

4) Ministry of Industry and Trade Decree No. 254/MPP/KEP/7/2000 On Import and Distribution of Specific Hazardous Substances

It states that MSDS should include information related to physico-chemical properties, possible hazard, handling method and special measure in case of emergency.

d. Regulations on import control Legislations related to import control which relevant to chemical substance inflow and information control are as follow: 1) Law No. 10/1995 on Custom It states that substance importing activity should be reported to Custom

Office, any loading-unloading should be reported to Custom Offce.

2) Government Regulation No. 74/2001 on Management of Hazardous and Toxic substances

It states that person who practices importing activity shall be obligated to follow the notification procedure.

3) Ministry of Health Regulation No. 239/Men.Kes/Per/V/85 on Specific Coloring Substance Stated as Hazardous Substance

It states that business corporate or individual who practices importing of specific coloring agent shall be obligated to register to Directorate General.

4) Ministry of Health Decree No. 472/1996 on Safety of Hazardous Substances for Human Health

27

It states that importer shall be obligated to register hazardous substance to be distributed or circulated. Importer shall be obligated to submit a report in every 3 month of period that describe the receiving, delivery and usage. Limited to hazardous substances with high risk of abuse (borax, formalin, mercury & methanyl yellow, rhodamin B, cyanide), report shall be submitted no later than 2 weeks after receiving or delivery.

5) Directorate General of Food and Drugs Control Decree No. 3078/E/SK/X/1985 on Registration Procedure of Specific Coloring Substance Stated as Hazardous Substance

It regulates the registration procedure of importing specific coloring substance to the Directorate General of Food and Drug Control .

6) Ministry of Defence and Security Decree No. 010/1988 on Monitoring and Control of Explosives, as Implementation of the Presidental Decree No. 5/1988

It states that explosive import permission is granted to Dahana. The permission is granted by Head of Indonesian Police.

7) Ministry of Industry and Trade Decree No. 254/MPP/KEP/7/2000 On Import and Distribution of Specific Hazardous Substances

It states that only importer as a hazardous substance manufacturer (IP-B2) and registered hazardous substance importer (IT-B2) are allowed to practice the import activity, and currently only one company that is appointed.

e. Regulations on hazard communication training Legislations or standards related to chemical substance hazard communication training are as follow: 1) Government Regulation No. 74/2001 on Management of Hazardous and

Toxic substances (Article 32 - 36) It states that the public awareness raising is accomplished by the

dissemination of Toxic and Hazardous Substances understanding.

2) Minister of Industry Decree No.148/M/SK/1985 on Safety Management of Toxic and Hazardous Substances in Industrial Company

This regulation stipulates the efforts to raise the cautiouseness, awareness, responsibility, discipline, and readiness through education, tutorial and training.

3) Ministry of Manpower Decree No. Kep. 187 / MEN / 1999 On the Control of Hazardous Chemicals at Workplace

It stipulates the technical training for Occupational Safety and Health (K3) officer to be implemented by the company or K3 service company or the authority.

4) Ministry of Agriculture Decree No.517/Kpts/Tp.270/9/ 2002On Pesticides Control

It stipulates a training for pesticide manager, small scale pesticide producer and limited user of pesticide. The training curriculum shall be based on the requirement and be performed on hiearchy base, i.e. national government performs the training for the provincial control officer, it will be followed by training by provincial control officer to the district/city control officer. As for restricted pesticide, the training

28

shall be hold with a cooperation between pesticide control team/comission and company that hold the registration number of pesticide of interest.

5) Ministry of Health Decree No. 472/1996 on Safety of Hazardous Substances for Human Health (Articles 8 ayat 2)

It states that Directorate General of Food and Drugs Control in the company with related institution provide information, training and tutorial to public or hazardous substance handler.

6) Directorate General of Land Transportation Decree No. SK.725.AJ.302/DRJD/2004 on Land Transportation of Hazardous and Toxic Substances (Articles 9, 10, 35)

It states a specified requirement for the driver and co-driver on certification of hazardous substance transportation related knowledge by completing the training. The owner of the hazardous and toxic substance shall be obligated to facilitate the training.

f. Regulations on accident/toxicity reporting Legislations related to hazardous substance accident/toxicity reporting are as folllow: 1) Law No. 1/1970 on Occupational Safety

Person in charge or leader shall be obligated to report the said accident in the workplace to the oficial authorized by Minister of Labor.

2) Law No. 21/1992 on Navigation Everyone on board of the ship who learns of an accident, shall be

obligated to provide assistance and report the said accident within their respective capacities to the nearest authorized official or other parties.

The ship captain shall be obligated to report to the nearest authorized government officials on every condition that may present possible hazards on the safety of maritime transportation within or near the water area under the Indonesian jurisdiction or in the open sea that he knows of.

The captain or leader of a ship located within the Indonesian waters must submit a report to the authorized government official, on any accident involving his ship or other ships that he knows of, which have caused or may have caused damage on the course or building in the relevant water area or that may present hazards to the safety of a maritime transportation.

3) Government Regulation No. 13/1975 on Transport of Radioactive The transportation crew must submit a report to the sender and the authorized government official on any accident that occured.

4) Government Regulation No. 74/2001 on Management of Hazardous and Toxic substances Everyone who conduct the management of hazardous and toxic substance shall be obligated to report the accident or emergency situation to city or region officials.

5) Minister of Industry Decree No.148/M/SK/1985 on Safety Management of Toxic and Hazardous Substances in Industrial Company

29

Director/leader/responsible person of industrial company shall be obligated to report any unexpected occurance in concern with handling of hazardous and toxic substance to Minister of Industry.

6) Ministry of Health Decree No. 472/1996 on Safety of Hazardous Substances for Human Health (Article 6) Each corporation and individual that manage hazardous substance shall be obligated to report the case of toxicity/accident.

7) Ministry of Health Decree No 979/MENKES/SK/IX/2001 on Regular Procedure of Disaster Prevention and Treatment of Evacuee Description of measures on anticapating, preventing and rehabilitating in case of accident.

8) Ministry of Agriculture Decree No.517/Kpts/Tp.270/9/ 2002 On Pesticides Control (Article 14 and 19) • Pesticide control by Provincial pesticide control agency shall put

priority on settlement of the case with broader impact to intradistrict issue.

• The control report based on the object and duty of the control agency shall be reported regularly or by case to the respective head of administration unit.

g. Regulations on Consumer Products There is no such regulation that regulates consumer products as for classification or labeling. In the Law No. 8 year 1999 on Consumer Protection, only such general matters on labeling as the volume or product weight (net weight, volume, and amount) and the agreement of the product and the statement on the label.

Nowadays, specific regulation on consumer product is only in the form of national standard i.e. the SNI (Indonesia National Standard). However, the SNI covers only a small parts of all consumer product and its application is not a compulsory. One of the regulations in the SNI, that is included also in the GHS, is that of labeling. Label as required by the SNI generally covers the product identity, producer/supplier identity, and composition/chemical identity, and for such a special product as pest exterminator, covers also warning sign. In addition, labeling requirement in the SNI refers to the decrees of the ministers that are dealing with the product. Example of SNI requirement on labeling for several consumer products is attached in Annex I.

Although the application of the SNI is voluntary, however, based on the Government Regulation No. 102 year 2000 on National Standardization, it is possible for the SNI of a product to be appllied as obligatory fully, or in part. One criterion that the SNI application is an obligation is that if the SNI relates to the devices for high pressurized gas, public health concern, conservation of environmental fuctions, and economic consideration (e.g., export goods).

Since consumer products cover a wide area, the discussion is limited to the following topics: children toys, household health provisions, food packing, construction materials, stationary, ink, polishing wax, and household tubes

30

containing gas. These are chosen because they are the most used products and have a great possibility of contact with children.

31

Table 8 Recapitulation of the existing Regulations

No. Regulation Ministry Sector Classification Labelling MSDS Import Training

1 UU No 10/ 1995 on Customs

Finance Industry, Agriculture, Transport and Consumer Products

√

2 Government Regulation No. 74 Th. 2001 on the Management of Hazardous and Toxic Substances

Environment Industry, Agriculture, and Transport

√ √ √ √ √

3 Government Regulation No. 41, 1993 on Land Transport

Transportation Transport √

4 Minister of Industry Decree No. 148/1985 on Safety of Hazardous Materials in Industrial Companies

Industry Industry √ √

5 Ministry of Industry and Trade Decree No 254/MPP /KEP/7/2000 On Import and Distribution of Specific Hazardous Substances

Trade Industry, Consumer Products

√ √ √

6 Ministry of Manpower Manpower And Industry, Agriculture √ √ √ √

32

Decree No. Kep. 187 / MEN / 1999 On the Control of Hazardous Chemicals at Workplace

Transmigration

7 Circular letter of Minister of Manpower No. SE-01/MEN/1997 on Threshold value of Chemical Factor for Air at Work Circumference

Manpower And Transmigration

Industry √

8 Ministry of Defence and Security Decree No. 010/1988 on Monitoring and Control of Explosives, as Implementation of the Presidental Decree No. 5/1988

Defence And Security

Industry, Transportation

√

9 Ministry of Health Regulation No. 239/Men.Kes/Per/V/85 on Specific Coloring Substance Stated as Hazardous Substance

Health Industry, Produk Konsumen

√ √

10 Ministry of Health Regulation No. 472/MENKES/PER/V/1996 On Security Precautions of Hazardous Substances

Health Industry √ √ √ √ √

33

11 Ministry of Agriculture Decree No. 434.1/Kpts/TP.270/7/2001 on Conditions and Procedures of Pesticides Registration

Agriculture Agriculture √ √

12 Ministry of Agriculture Decree No.517/Kpts/Tp.270/9/ 2002 On Pesticides Control

Agriculture Agriculture √

13 Ministry of Transportation Decree No. KM 69/1993 on Land Transport of Substances

Transportation Transportation √ √

14 Ministry of Transportation Decree No. 17/2000 on Guidance of Hazardous Substances Handling in Maritime Operation in Indonesia

Transportation Transportation √ √

15 Directorate General of Land Transportation Decree No. SK.725.AJ.302/DRJD/2004 on Land Transportation of Hazardous and Toxic Substances

Transportation Transportation √ √ √

34

h. Institutional Responsibilities Available resources for anticipating accidents and chemical exposures are: • NADFC (National Agency for Drug and Food Control) through its

Consumer Claim Service Units (ULPK) in the capital city and regional towns, Directorate for Hazardous Product and Substance Control, and Poison Information Center (SiKer).

• Department of Industry through its Directorate General that controls relevant group of industries (e.g., agro-chemical and forest product industry group, which is cared for by Directorate General IKAH.

• Department of Commerce through its Directorate General for Consumer Protection.

• Department of Agriculture (pesticides) through its Directorate General for Agricultural Resources Development.

• Department of Manpower and Transmigration through its Directorate General for Work Safety Norms and Development.

• Department of Communication through Directorate General for Land Transportation

• Department of Finance through its Directorate General for Customs and Duty

• State Ministry of Environment through its Deputy for the Management of Hazardous and Toxic Substance

• Regional governments through their hospitals, puskesmas (local government clinics), and Bapedalda (Regional Agency for Environmental Impact Control).

4.1.2 Institutional and Administrative Information

a. Current Activities The implementation of the GHS shall be realized through such activities as socialization through printed and electronic media, counsellings, control and monitroring, and trainings.

b. The Role of the Authority of Costums and Duty The role of this institution is limited to physical examination of luggage and label, which is then followed by sample taking for a laboratory test of suspicious items. However, this institution has never conducted trainings related to the GHS.

c. The Role of the Authority of Costums and Duty

Trainings on classiffication and chemical hazard communication held in Indonesia include: • The government, in this case the National Agency for Drug and Food

Control (Badan Pengawas Obat dan Makanan) since 2003 has conducted trainings for other government institutions including Department of Manpower and Tranmigration, Department of Agriculture, Department of Industry, Department of Commerce, Department of Communication, State Ministry of Environment, Regional Governments and organizers of chemicals including industry, importers, and retailers. The trainings were held in the capital city (Jakarta) and regional towns (about 5 provincies a year)

35

• Industrial associations, in this case the Komite Nasional Responsible Care Indonesia (National Committee for Responsible Care Indonesia) in co-operation with JETRO and AOTS conducted trainings in 2003 and 2004 for government institutions (Department of Manpower and Tranmigration, Department of Agriculture, Department of Industry, Department of Commerce, Department of Communication, State Ministry of Environment, Regional Governments) and Industry.

• Internal trainings within foreign investments for their own employees.

d. Poison information centre At national level, information centers that provide suggestions on accident cases or poison occurence are: • NADFC (National Agency for Drug and Food Control) through its

Consumer Claim Service Units (ULPK) in the capital city and regional towns, Directorate for Hazardous Product and Substance Control, and Poison Information Center (SiKer).

Some services offered include: - Providing such information as how to tackle reported symptoms of

poison and accidents. - Providing information on poison/accident-risky substance, the

information being recorded on CDs containing catalog of poison-risky substance

- Providing information on how to administer poison occurence or chemical accidents including exposure of pirolysis product, e.g. plastics, Providing information on personal protecting equipment. The mechanism of information service on poisons and the network of Poison Information Center (SiKer) of NADFC is shown in Annex II.

• Department of Manpower and Transmigration (Crisis Centre of Work Savety in Cilegon, Gresik , Lhoksumawe) It provides the reporter of poison case with information on how to handle the case.

• Department of Commerce (Sub-directorate for Complaint and Services, Directorate of Consumer Protection)

It provides services for comsumers complaining, the services being in the form of facilitating such a mediation between the consumers and producers. However, it does not have the authority of penalty/sanction. Meanwhile, government institutions that are responsible for providing emergency measures are: - National Coordinating Agency for Disaster Tackling and Evacuation

(Bakornas PBP) - Department of Health - Department of Internal Affairs - Ministry of Environment (especially for oil spillage on waters) - Department of Manpower and Transmigration - Department of Industry

4.2 Business and Trade

Based on year 2002 data, the structure of chemical industry in Indonesia consisted of 401 foreign investments, 411 domestic investments, and some 1668

36

other forms of inverstment. There are about 16% of industries that are dominated by raw organic chemical industries producing special chemical substances (KBLI 24118), about 13% of syntethic fertilizer industries (KBLI 24122) and natural and syntethic resin industry, and raw material for plastics of about 11% (KBLI 24131).

As for Industry of chemicals for agricultural use, there are foreign investments (at least 8 foreign investments from European and American countries) and some domestic investments.

The authority for classification lies on the government. Department of Industry is responsible for classification of chemicals. On transport sector, the responsiblitiy lies on the Department of Communication. On agriculture sector (for pesticides), the responsiblity lies on the Department of Agriculture, which is assisted by Pesticides Commission the staff member of which consists of representatives from Department of Agriculture, Department of Manpower and Transmigration, Department of Health, Ministry of Environment, Department of Industry, Department of Commerce, Department of Sea Product, NADFC (Badan POM), universities and research institutions. The criterion used in classification of chemical pesticides is based on the value of LD50 oral dan dermal formulation according to the WHO regulation (Hazard Classification-WHO). As for the consumer product, the classification follows regulations issued by the Department of Industry.

Since the authority for classification lies on the government hands, companies do not make classification of their own products. The companies may make MSDS and labels by refering to the condition of government regulations, i.e. the Ministry of Manpower Decree No. 187/MEN/1999 on the Control of Hazardous Chemicals at Workplace.

Companies make labels for pesticides by refering to regulations mentioned in the Ministry of Agriculture Decree No. 434.1/Kpts/TP.270/7/2001 on Conditions and Procedures of Pesticides Registration. On the other hands, companies making chemical pesticides (in the form of single or mixtures) have to arrange the MSDS of their products by refering to regulation of the ILO no. 170, while other companies producing other kinds of chemical have to refer to the Ministry of Manpower Decree No. 187/MEN/1999 on the Control of Hazardous Chemicals at Workplace, in making the MSDS and labelling. The format of label and MSDS used by chemical industries and pesticides industries has to refer to the regulation of ILO no. 170. Meanwhile, the labelling of the transport means used for chemical substance has to refer to the IMDG Code.

Trainings and awareness intensification activities (socialization) held by industrial associations, especially by foreign investments, are shown on the following table:

37

Table 9 : Activities Related to Awareness Raising and Training on GHS

Number of Participants DATE

VENUE Government Industry Organization

Total Number of participants

Remarks

11 March 2004 Gran Mahakam 8 51 2 61 persons Seminar

12 March 2004 Graha Sucofindo

6 9 1 16 persons Technical Discussion

Intercontinental 7 35 1 43 persons Seminar 4 October 2004

Intercontinental 10 3 13 persons Discussion

5 October 2004 Intercontinental 7 7 14 persons Workshop Elementary

6 October 2004 Intercontinental 7 8 - 15 persons Workshop Elementary

7 – 8 October 2004

Intercontinental 7 8 - 15 persons Workshop Intermediate Training Instructor

14 - 15 February 2004

Menara Cakrawala

4 6 - 10 persons Training Instructor Intermediate

16 February 2004

Menara Cakrawala

4 10 - 14 persons Training Instructor

17 – 18 February 2004

Menara Cakrawala

4 10 - 15 persons Training Instructor Intermediate

April 2005 Sky Building - 12 - 12 persons Training Instructor advance

December 2005 Sky Building 6 4 - 10 persons Training Instructor advance

GRAND TOTAL 238 persons

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4.3 Civil Society Groups of social observers that have interest in chemical hazard communication on industrial sector include Chemical Workers Union, Indonesia Consumer Organization (YLKI), and National Committee for Responsible Care Indonesia (KNRCI).

Groups of social observers that have interest in agricultural chemical hazard communication are Pesticide Action Network (PAN), Indonesia Vehicle of Environmental Thoughts (WALHI), Association of Indonesian Farmers (HKTI), Fishermen-Farmers Communication (KTNA) and Indonesia Consumer Organization (YLKI).

A group of social observers that has interest in agricultural chemical hazard communication on transport sector is the Association of Hazardous Chemical/Substance, which is in co-ordination with Fire Extinguishing Service, Indonesia Association of Loading-Unloding Companies, Association of Hazardous and Toxic Substance Transport Companies, and Fire Protection Association.

Groups of social observers that have interest in chemical hazard communication on consumer product sector are: • Chemical Labour Union • Indonesia Vehicle of Environmental Thoughts (WALHI), with its local

network (e.g. Walhi Jakarta, Medan, and so on) • Legal Aid Services for Health Affairs • YPKKI • ICEL or Indonesian Center for Environmental Law • Konphalindo or Indonesia’s Nature and Forest Conservation Concortium • National Society of Pesticides • Association of Indonesian Farmers (HKTI) • Corplife • Duta Awam Foundation (Solo) • Association of Hazardous and Toxic Substance Transport Companies • Pesticide Action Network (PAN) – Indonesia • Indonesia Consumer Organization (YLKI) with their partners, e.g. YLK –

Yogya, LP2K (Agency for Consumer Development and Education) – Semarang, YLK South Sulawesi

• National Committee for Responsible Care Indonesia with its program for helping the government in training the GHS for industries and for socializing the GHS to chemical industries and to its own members.

Activities conducted by groups of social observers, labour unions, and associations of consumer protection are in the form of workshops, socialization activities, trainings, advocacies, meetings, and seminars.

It is not rarely bad practice conducted related misused of chemicals leading to poisoning cases within the society due to faulty and missing hazard communication. Just to mention a few, the unfortunate incidence in the country of biscuit poisoning was demonstrated by nitrite in 1989 due to mislabelling of chemicals leading to 20 people death and more than 200 people suffered from sickness. Posioning cases have been reported caused by misuse and/or improper handling of pesticide in agricultural sector due to missing hazard communication.

39

Based on poisoning data year 2001-2004, the main cause of poisoning cases was pesticides. Data is shown in the following Figure.

050

100150200250300350400450500550600650700

2001 2002 2003 2004

Drug Narcotics and addictivesNatural Products Food and DrinkPesticides Household chemicals Industrial chemicals CosmeticsTraditional Medicines Others

POISON CASES DATA BASED ON TOXIC SUBSTANCE

2001 - 2004

Available support fundings for public activities come in general from abroad. In the case of the Indonesia Consumer Organization (YLKI), for example, the fundings are as follows : • 1980s – 2000: from USAID some research/test program, where the test

specimens were dependent upon the consumer’s need. USAID also supported training activities, in which the subject on hazardous substances was put as a test case where consumers being the victim.

• 2000 – now: there is no spesific funding for research related to hazardous substances yet.

In Indonesia academic sector so far, has not conducted research and training related to the GHS. It seems that academia and media have not put GHS into their list of activities as the priority or they have limited information on GHS concept. The other possible reason for this fact is lack o knowledge regarding GHS. The dissemination of information on hazardous chemicals, classification, and labelling based on the GHS has been conducting through printed and electronic media (radio).

Meanwhile, there are some social organizations that are actively working dealing with chemicals safety and hazard communication, but have not working at their maximum capacity. Active roles are also played by local associations such as the AMC//CMA (Anyer Merak Cilegon//Chemical Manufacture Assossiation). Apart from this association, the National Committee for Responsible Care to Indonesia (KNRCI) and Indonesia Consumer Organization (YLKI) are also playing active roles in this regard. The following are activities conducted by YLKI : • Conducting research/testing on hazardous substance used in such household

products such as active component of detergent, mosquito repellent, food packaging made from PVC and melamine.

• Conducting surveys on the impact of hazardous products on the consumers, such as active component of detergent and mosquito repellent.

Figure 2 : Poisoning cases with various cases

40

• Analyzing label of household products such as active component of detergent and mosquito repellent.

• Publishing test and survey results in printed and electronic media and to the consumer groups.

• Advocating parties related to the control of hazardous products. Method of advocacy was implemented by, e.g., sending letters to the government institutions, conducting Focused Group Discussion with the stakeholders, and creating public pressure through the media.

So far, there are quite limited activities performed by school organization in the context of chemical safety and hazard communication. It might be resulted from lack of knowledge within schools on chemicals in general and in particular safety culture.

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5. Gap Analysis

5.1 Industry

5.1.1 Government The existing regulations in Indonesia are still partial in nature when compared to the GHS. For example, a regulation may cover only conditions of labeling, while some other regulations may have included the classification, labeling and MSDS. However, they are not yet altogether as according to GHS. Until recently, there is no any regulation at a higher level that regulates the classification, labelling, and MSDS in an integral way, which can be referred to by all sectors.

Regulations in Indonesia as compared with the GHS can be seen on the following table:

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Table 10 : Comparison of Regulation on Chemical Classification

GHS Department of Health/ NADFC Ministry of Environment Department of Manpower

1. Explosives 2. Flammable gases 3. Flammable aerosols 4. Flammable liquids 5. Flammable solids 6. Substances and mixtures which, in contact

with water, emit flammable gases 7. Self-heating substances and mixtures 8. Oxidizing gases 9. Oxidizing liquids

10. Oxidizing solids 11. Organic Peroxides 12. Self-reactive substance and mixtures 13. Pyrophoric liquids 14. Pyrophoric solids 15. Gases under pressure 16. Corrosive to metals 17. Acute Toxicity 18. Skin corrosion / irritation 19. Serious eye damage/eyes irritation 20. Respiratory / skin sensitization 21. Germ cell mutagenicity 22. Carcinogenicity 23. Reproductive toxicity 24. Specific target organ systemic toxicity

single exposure 25. Specific target organ systemic toxicity -

repeated exposure

Ministry of Health Regulation No: 472/MENKES/PER/V/1996 On Security Precautions of Hazardous Substances Appendix I Hazard features: 1. Toxic 2. Corrosive 3. Mutagenic 4. Carcinogenic 5. Irritation 6. Teratogenic

Regulation of Government No. 74 Th. 2001 On the Management of Hazardous and Toxic Substances Chapter II Classification of Hazardous and Toxic Substances Article 5 (1) Hazard and toxic substances may be

classified as: 1. explosive; 2. oxidizing 3. extremely flammable; 4. highly flammable; 5. flammable; 6. extremely toxic; 7. highly toxic; 8. moderately toxic; 9. harmful; 10. corrosive; 11. irritant; 12. dangerous to the environment; 13. carcinogenic; 14. teratogenic; 15. mutagenic;

(2) Classification of Hazard and Toxic

Ministry of Manpower Decree No. Kep. 187 / MEN / 1999 On the Control of Hazardous Chemicals at Work Sites Article 9 The criteria of hazardous chemicals as referred to in Article 8 Sub-section 3 consists of: a. toxic substance; b. highly toxic; c. flammable liquid; d. highly flammable liquid; e. flammable gas; f. explosive substance; g. reactive substance; h. oxidizing substance;

43

26. Hazardous to aquatic environment 27. Aspiration hazard

Substances as referred to in sub-section (1) are for : 1. Hazard and Toxic Substances

that may be used; 2. Hazard and Toxic Substances

that may not be used; and 3. Hazard and Toxic Substances

that may be used restrictedly

44

Table 11 : Comparison of Regulation on Chemical Labelling

GHS Department of Health/ NADFC

Department of Industry and Commerce Ministry of Environment Department of Manpower

1. Chemical identity 2. Product identifier 3. Supplier

identification 4. Pictogram 5. Hazard Statement 6. Signal word 7. Precautionary

statement

Ministry of Health Regulation No. 239/Men.Kes/Per/V/85 On Specific Coloring Substances Stated as Hazardous Substances Chapter V (Labeling) Article 5 Apart from valid regulations on labelling, on the container and wrapping of the specific coloring substances as stated in Article 2 Sub-Article (1) labels has to be attached in the form of warning sign "DO NOT USE IN DRUG, FOOD AND COSMETICS or DO NOT USE IN DRUG AND FOOD" The warning sign as stated in Sub-Article (1) : a. shall be written in Indonesian language in red, capital, latin font and included within a red square sized according to the container or wrapping, and should be clear and

Ministry of Industry and Trade Decree No. 254/MPP/KEP/7/2000 On The Import and Distribution of Specific Hazardous Substances CHAPTER IV

TRANSPORT AND DISTRIBUTION OF HAZARDOUS AND TOXIC SUBSTANCES Article 8 (2) In the distribution of Hazardous and Toxic

Substances shall be well packed and securely according to the UN standard and a label has to be attched on each of the containers or packages, which includes trade or generic name, active inggredients, net weight/volume, warning words and sign or hazard symbol, and first aid measures.

(3) If smaller package is needed

Government Regulation No. 74 Th 2001 On the Management of Hazardous and Toxic Substances CHAPTER I GENERAL REGULATION

A label is a short description that defines, e.g., classification and type of hazardous and toxic substances; Article 15

(1) Each package of hazardous and toxic substances shall be provided with symbol and label and the MSDS (Material Safety Data Sheet)

(2) Packaging, symboling and labelling as sated in Sub-Article (1) are decided by the regulation of the chairman of the institution in charge.

Article 17

(1) New symbol and label shall be replaced for damaged symbol and

Ministry of Manpower Decree No. Kep. 187 / MEN / 1999 On the Control of Hazardous Chemicals at Work Sites Article 5 Label as stated in article 3 letter a shall include the description of : a. Product name; b. Hazard identification; c. Hazard sign and its meaning; d. Risk description and tackling; e. Prevention precautions; f. Instruction in case of exposure or

contact; g. Instruction in case of fire; h. Instruction in case of spillage or

leakage; i. Instruction of filling and storage; j. refences; k. name, address and telephone

number of the manufacture or distributor;

Article 6

45

readable; b. shall be included directly on the container and wrapping or label that is attached to he container and wrapping and on the brochure; c. shall not be easily damage, detached and faded due to sunlight, air, and other causes; d. shall be attached at a visible position or location.

Ministry of Health Regulation No. 472/MENKES/PER/V/1996 On Security Precautions of Hazardous Substances Article 5 A label has to be attached on the container or package, which includes trade or generic name, active inggredients, net weight/volume, warning words and sign or hazard symbol, and first aid measures. Labelling as stated in Sub-Article (2) shall be visible, readable, understandable, not easily detached and faded due to the sunlight or climate.

during the distribution to end-users, IT-B2 may repack, but still has to follow the valid standard as stated in Sub-Article (2) and shall attach on the repackage the name of the hazardous substance, net weight/volume, warning words and sign or hazard symbol, and first aid measures.

CHAPTER V OBLIGATION Article 10 (2) The hazardous substance

imported by IP-B2 and IT-B2 shall has to use packaging and labelling based on valid national regulation and according to terms and conditions of the Maritime Dangerous Good Code (IMDG Code/United National Standard).

label. (2) The responsibility of symboling

and labeling as stated in Sub-Article (1) for damage at: a. Production stage, lies at the

producer; b. Transport stage, lies at the ones

in charge of the transport c. Storage stage, lies at the ones

in charge of the storage. (3) Packaging, symboling and

labelling as sated in Sub-Article (1) are decided by the regulation of the chairman of the institution in charge.

Article 18

(1) The storage of hazardous and toxic substances shall be provided with symbol and label

MSDS as stated in Article 4 and Label as stated in Article 5 shall be placed at posisition visible to workers and their supervisor;

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Tabel 12 : Comparison of the existing regulations on MSDS

GHS Department of Health/ NADFC

Department of Industry and Commerce Ministry of Environment Department of

Manpower

Minimum information included in MSDS:

1. Identification 2. Hazards identification 3. Composition/

information on ingredients

4. First-aid measures 5. Fire-fighting measures 6. Accidental releases

measures 7. Handling and Storage 8. Exposure

controls/personal protection

9. Physical and chemical properties

10. Stability and reactivity 11. Toxicological

information 12. Ecological information 13. Disposal consideration 14. Transport information 15. Regulatory information 16. Other necessary

information

Ministry of Health Regulation No. 472/MENKES/PER/V/1996 Security Precautions of Hazardous Substances Article 1 (2) A MSDS is a guideline sheet

containing information in physical and chemical properties of hazardous substances, possible hazard features, handling and specific precautions in case of emergency.

Article 4 (1) Each corporation or individual that

manage hazardous and toxic substances shall make, arrange, and own the MSDS for the substances in accordance with the example in Appendix III.

(2) The MSDS as stated in Sub-Article (1) shall be placed at a place that is visible and readable so as to facilitate necessary security precautions.

Ministry of Industry and Trade Decree No. 254/MPP/KEP/7/2000 On The Import and Distribution of Specific Hazardous Substances CHAPTER I GENERAL REGULATION A MSDS is a guideline sheet containing information on physical and chemical properties of hazardous substances, possible hazard features, handling and specific precautions in case of emergency. Article 11 (1) IP-B2 and IT-B2 shall make and

arrange the MSDS for the hazardous substances

(2) The MSDS as stated in Sub-Article (1) shall be included in the package and be placed at the storage and shall be visible and readable.

(3) The form of the MSDS is as given in Appendix V.

Government Regulation No. 74 Th 2001 On the Management of Hazardous and Toxic Substances Article 11 Each individual producing hazardous and toxic substances shall make their MSDS (Material Safety Data Sheet) Article 12 Each one in charge of transport, storage and distribution of hazardous and toxic substances shall provide the MSDS (Material Safety Data Sheet) as stated in Article 11.

Ministry of Manpower Decree No. Kep. 187 / MEN / 1999 On the Control of Hazardous Chemicals at Work Sites

Article 3 The control of Hazardous Chemicals as stated in Article 2 shall includes : a. MSDS and label; b. Assignment of chemical K3

officer and expert Article 4 (1) The MSDS as stated in

Article 3 letter a shall include the description on: a. Substance and

supplier identity; b. Composition; c. Hazard identification; d. First aid measures. e. Fire fighting

measures; f. Precautions of

spillage or leakage;

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g. Handling and storage; h. Exposure control and

personal protection; i. Physical and chemical

properties; j. Stability and

reactivity; k. Toxicological

information; l. Ecological

information; m. Disposal

consideration; n. transport; o. information on valid

regulation; p. other necessary

information; (2) The form of MSDS as

stated in Sub-article (1) shall be as given in Appendix I

Article 6 The MSDS as stated in Article 4 dan Label as stated in Article 5 shall be placed at position visible to workers and their supervisor;

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The existing legislation framework shows the responsiblities of the government’s departments/agencies to cover the four sectors pertaining to the GHS. However, there seem to be overlapping and differences between the authorization and responsiblity within the authorities.

The staff member of the government’s officers that have knowledge of legislation and technical aspect of the GHS implementation are still limited in number. The government agencies do not have adequate funds for activities in changing the regulations in the four relevant sectors.

The government does not seem to have adequate capacities of facilitating the implementation of national regulation related to the GHS-based chemical hazard communication.

5.1.2 Business and Trade In Indonesia, industries that have appropriate knowledge and capacities of the classification of chemicals based on the GHS are limited to those of foreign investments. The domestic investments merely adopt.

Capabilities and capacities for making the GHS-based labels and MSDS depend on the level of the group of the industries, starting from the multi-national, middle, and small-scale/home industry level. The multi-national group has performed the preparation for making the GHS-based labels and MSDS, but those belonging to the other level have not yet prepared such activities as trainings on the GHS-based labels and MSDS.

The use of the GHS-based chemical hazard communication tools is not evenly distributed in Indonesia, depending on the level of the group of the industries. Generaly, those belonging to the multi-national group have used them, but those belonging to the other levels have not used them.

The same situation happens with additional activities in facilitating the chemical hazard communication, such as trainings for the workers, which has been conducted by the multi-national industry group only.

Considering unevenly distributed capabilities amongst the industries, activities to encourage the awareness and additional trainings are needed for the business and Commerce realms.

KNRCI is one of agencies that have implemented the GHS in business and commerce, so that it may be an effective partner for the government in encouraging the implementation of the GHS in Indonesia.

5.1.3 Civil Society The interest of the public is still limited and internal in nature, and the capacities of the public and the worker group are not yet significant to give contribution to the implementation of the GHS.

In addition, there is no financial support for the implementation of the GHS from the NGO’s and the worker groups.

There are indeed interest and adequate capacities within academic societies that may support the implemention of the GHS through research and trainings, but these have not yet been conducted.

49

Additional programs for promoting the implementation of the GHS that may be initiated effectively by the public organizations (including the mass media) may include the Talkshows.

Potential part of the communities supporting implementation of the GHS may be through: • Associations in the chemical industries such as KNRCI and AMCIILMA • NGO’s such as KNRCI As for the shools, they seem not yet to have potential part in implementation of the GHS.

5.2 Agriculture

5.2.1 Government In relation to the implementation of the GHS in the agricultural sectors, especially pesticides, it is necessary to identify existing regulations, institutional infra-structures and administratives, and their capacities.

Classification and labelling of chemicals in the agricultural sectors, especially pesticides, still refer to the FAO/WHO stipulations. However, these have not been according to the GHS. Since the GHS-based classification and labelling of pesticides are more comprehensive and detailed, the implementation of those of the FAO/WHO needs accommodation to the GHS and in a priority scale way. Regulations on the management of chemical substances have been implemented in related authorities according their authorizations. Unfortunately, there are duplications in the implementation. The configuration of regulations in agricultural sectors can be seen on the following table:

Table 13 : Comparison of Regulation in Agricultural Sector on Pesticide Classification

GHS Department of Agriculture

1. Explosives 2. Flammable gases 3. Flammable aerosols 4. Flammable liquids 5. Flammable solids 6. Substances and mixtures which, in

contact with water, emit flammable gases

7. Self-heating substances and mixtures

8. Oxidizing gases 9. Oxidizing liquids

10. Oxidizing solids 11. Organic Peroxides 12. Self-reactive substance and mixtures 13. Pyrophoric liquids 14. Pyrophoric solids 15. Gases under pressure 16. Corrosive to metals 17. Acute Toxicity 18. Skin corrosion / irritation 19. Serious eye damage/eyes irritation 20. Respiratory / skin sensitization

Ministry of Agriculture Decree No. 434.1/Kpts/TP.270/7/2001 on Conditions and Procedures of Pesticides Registration Artilce 5 1. Based on physico-chemical properties and their hazard:

a. Registerable pesticides; and b. Prohibited pesticides

3. Prohibited pesticides as mentioned in sub-section (1) letter b, the pesticides included are as follows: a. Formulation of the pesticides is belong to class Ia,

meaning extremely dangerous and class Ib meaning highly dangerous according to the WHO classification

b. Having LC50 inhalation formulation less than 0.05 mg/l in 4 hour exposure period

c. Having indication of carcinogenicity, onkogenicity, teratogenicity and mutagenicity

4. Based on the use pesticides may be classifified into: a. Registerable pesticides; and b. Prohibited pesticides

5. Pesticides based on the use classifified as limited pesticides are those having the following criteria: a. pesticides formulation that is corrosive to eyes (causing

irrecoverable damage to ocular cells) or causing cornea shrinkage or irritation up to 7 days or more

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21. Germ cell mutagenicity 22. Carcinogenicity 23. Reproductive toxicity 24. Specific target organ systemic

toxicity single exposure 25. Specific target organ systemic

toxicity - repeated exposure 26. Hazardous to aquatic environment 27. Aspiration hazard

b. pesticides formulation that is corrosive to skin (causing irrecoverable damage to internal dermic cells or ) or svere irritation up to 72 hours or more

c. pesticides, if conducted as to the label or according to general procedures for the pesticides, still causing sub-chronic, chronic real toxicity or delayed to human being as the result of single and repeated exposure to the pesticides and their residues.

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Tabel 14 : Comparison of Regulation on Pesticide Labelling

GHS Department of Agriculture 1. Chemical identity 2. Product identifier 3. Supplier

identification 4. Pictogram 5. Hazard Statement 6. Signal word 7. Precautionary

statement

Ministry of Agriculture Decree No.517/Kpts/Tp.270/9/ 2002 On Pesticides Control Articel 1 Labels are words or phrases and may be accompanied by figures or symbols, that specify the pesticides, and attached to their container or wrapping.

Articel 25 (1) Each container of the pesticides shall be labelled, which is attached to and not

easily detached, or printed on the container. (2) The label is proposed by the registration holder and is one of the conditions of

the application for registration. diusulkan oleh pemegang pendaftaran dan merupakan salah satu persyaratan dalam permohonan pendaftaran

(3) All the description on the label and the direction of use appendix have to provided in Indonesian language; foreign language may also be provided just for translation of necessary points that have given in Indonesian language

(4) Description and warning sign have to be printed clearly, visible and readable, resistant to the pesticide in the package and not easily wiped off.

(5) Detailed description on label content, signal word and first aid direction, information on storage, usege, provision of symbol, label of limited pesticides and the arrangement of lable shall be as stated in Appendix VII

The MSDS has been implemented in the import/export and local transportation although it has not been included in one of the regulations on pesticides issued by the Department of Agriculture.

Since there has not been any agency/institution in Indonesia that is responsible for the implementation of the GHS-based classification and labelling of chemicals, it is necessary to ensure which agency/institution should be responsible for the implementation of the GHS succesfully, effectively, and sustainably.

Although not specifying the implementation the GHS, there are some legislations in related institutions pertaining to the safety precaution of chemicals.

Human resources are not adequate in number and quality, the knowledge and skill about the GHS need to be intesified. In addition, it is of importance to have adequate fundings to facilitate the renewal of the GHS regulation and its implementation.

5.2.2 Bussiness and Trade Multi-national agricultural industries in Indonesia have been preparing for the classification and labelling and MSDS based on the GHS. However, national industries in Indonesia do not generally have adequate knowledge and have not yet prepared adequately for the classification of single/mixed chemicals, their labelling and MSDS based on the GHS. The chemical classification and labelling communication means used in the business and commerce in the agricultural sectors, specifically for pesticides, refer to the FAO/WHO stipulations.

52

Socialization and trainings have been conducted in the business and commerce in agriculture sectors in order to facilitate the communication of the classification and labelling of chemicals. In general, industries that have implemented responsible care can implement the GHS.

5.2.3 Civil Society Collaboration with the NGO’s and workers in agriculture sectors need to be done. Unfortunately, there has not been enough capacities within the NGO’s and workers, as well as the academic sectors (research and training), to contribute in the implementation of the GHS. In addition, financial supports are needed to ensure the implementation of the GHS. Therefore, pre-socialization of the GHS to the public through the media electronically and in printed forms, leaflets, brochures, posters, need to be conducted to promote the effective implementation of the GHS. Some companies have socialized dangerous chemicals and in the future the information on hazardous chemicals should be included into the school curriculum, including elementary, junior and senior high schools.

5.3 Transportation

5.3.1 Government So far, existing regulations in transportation sectors still refer to the UN-RTDG system. While in maritime transportation, Indonesia adopted IMDG code which has been ratified by the government in year 2000. The regulations are significantly relevant to the GHS. Compared to the IMDG code, the GHS does not include regulations on radioactivity, although in the GHS its properties are regulated more thoroughly.

The national system for classification and labelling in transport should be brought in to line with the UN RTDG which encompasses the GHS criteria and elements relevant to the transport sector. Government’s institutions and/or agencies relevant to the the GHS implementation, have not yet owned means/instruments and a clear frame-work for the implementation. The upgrading step needed is, therefore, providing a national regulation in order to implement the GHS effectively and comprehensively. The following table shows the case obviously:

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Table 15 : Comparison of Regulations on Classification in Transportation Sector

GHS Government of RI Department of Transportation (Sea)

Department of Transportation

(Land)

1. Explosives 2. Flammable gases 3. Flammable aerosols 4. Flammable liquids 5. Flammable solids 6. Substances and mixtures

which, in contact with water, emit flammable gases

7. Self-heating substances and mixtures

8. Oxidizing gases 9. Oxidizing liquids

10. Oxidizing solids 11. Organic Peroxides 12. Self-reactive substance

and mixtures 13. Pyrophoric liquids 14. Pyrophoric solids 15. Gases under pressure 16. Corrosive to metals 17. Acute Toxicity 18. Skin corrosion / irritation 19. Serious eye damage/eyes

irritation 20. Respiratory / skin

sensitization 21. Germ cell mutagenicity 22. Carcinogenicity 23. Reproductive toxicity 24. Specific target organ

systemic toxicity single exposure

25. Specific target organ systemic toxicity - repeated exposure

26. Hazardous to aquatic environment

27. Aspiration hazard

Government Regulation No. 41 year 1993 on Land Transport

CHAPTER III Land Transport by means of Motorized Vehicles

Article 14 (1) Transport of

hazardous substances is classified as transport of : a. Explosive

substances; b. Compressed

gas, liquified gas, gas soluble at certain pressure and temperature;

c. Inflammable liquid;

d. Inflammable solid;

e. Oxidizing substance, Organic peroxide;

f. Toxic and infecting substance;

g. Radioactives; h. Corrosives; i. Other

hazardous substances.

Ministry of Transportation Decree No. 17/2000 on Guidance of Hazardous Substances Handling in Maritime Operation in Indonesia Article 1 Puts into effect the “International Maritime Dangerous Goods (IMDG) Code” and its supplement as the guideline in handling of hazardous goods/substance in shipping operation in Indonesia, which consists of Book I, Book II, Book III, Book IV and the Supplement the detail of which is as given in the Appendix of this Decree. Appendix Class 1 Explosives Part 1.1 Substance and object having ability to mass explosion Part 1.2 Substance and object having ability to projected explosion but not mass explosion Part 1.3 Inflammable substance and object and may cause fire, and low explosive or having ability to low projected explosion but not mass explosion. Part 1.4 Substance, mixture and object having ability to insignificant hazard.

Ministry of Transportation Decree No. KM 69 Th 1993 on Land Transport of Substances Part Two Transport of Hazardous Substances Article 11 (2) hazardous

substancesas stated in Sub-article (1) are classified as follows: 1. Explosive

substances; 2. Compressed

gas, liquified gas, gas soluble at certain pressure and temperature;

3. Inflammable liquid;

4. Inflammable solid;

5. Oxidizing substance, organic Peroxide;

6. Toxic and infecting substance;

7. Radioactive; 8. Corrosives 9. Other

hazardous substances

Directorate General of Land Transportation Decree No. SK.725.AJ.302/DRJD/

54

Part 1.5 Highly insensitive substance or mixture having ability to mass explosion Part 1.6 Highly insensitive substance or mixture not having ability to mass explosion

Class 2 Gas Class 2.1 Inflammable gas Class 2.2 Non-toxic and non-flammable gas Class 2.3 Toxic gas

Class 3 Inflammable liquid

Class 4 Class 4.1 Inflammable solid Class 4.2 Substances liable to self-ignition Class 4.3 Substance that when in contact with water may cause inflammable gas

Class 5 Class 5.1 Oxidizing substance Class 5.2 Organic peroxide

Class 6 Class 6.1 Toxic substance Class 6.2 Infecting substance

Class 7 Radioactives

Class 8

Corrosives

Class 9 Other substances and objects

2004 on Land Transportation of Hazardous and Toxic Substances CHAPTER VI Operating Procedure of Vehivcles Transporting Hazardous and Toxic Substances Article 14 Hazardous and toxic substances are classified as follows: a. Explosive; b. Compressed gas,

liquified gas, gas soluble at certain pressure and temperature;

c. Inflammable liquid; d. Inflammable solid; e. Oxidizing

substance, Organic peroxide;

f. Toxic and infecting substance;

g. Radioactives; h. Corrosives; i. Other hazardous

substances.

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Table 16 : Comparison of Regulations on Labelling in Transportation Sector

GHS Department of Transportation (Sea)

Department of Transportation (Land)

1. Chemical identity 2. Product identifier 3. Supplier identification 4. Pictogram 5. Hazard Statement 6. Signal word 7. Precautionary statement

Ministry of Transportation Decree No. 17/2000 on Guidance of Hazardous Substances Handling in Maritime Operation in Indonesia This decree regulates labelling in reference to the IMDG Code,

Ministry of Transportation Decree No. KM 69 Th 1993 on Land Transport of Substances Appendix III on Classification and Labelling of Hazardous Substances

Class 1 : Explosive Class 2 : Gas Class 3 : Inflammable liquid Class 4 : Inflammable solid Class 5 : Oxidizing substance and Organic peroxide Class 6 : Toxic substance; Class 7 : Radioactives Class 8 : Corrosive Class 9 : Other substances Label must consist of : 1. Hazard Pictogram 2. Warning statement 3. Label color

Directorate General of Land Transportation Decree No. SK.725.AJ.302/DRJD/2004 on Land Transportation of Hazardous and Toxic Substances

CHAPTER VI Operating Procedure of Vehivcles Transporting Hazardous and Toxic Substances Article 19 (2) Each package of hazardous

and toxic substances has to be completed with marking and label according to the type of hazard and toxicity of the substances being transported

(3) Posters, markings, and labels stated in Sub-article (1) and (2) are as stated in Appendix VI, VII, and VIII of this decree.

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Appendix VIII Examples of Label on Package of Hazardous and Toxic Substances 1. “Toxic Gas” Label 2. “Inflammable solid” Label 3. “Dangerous when wet” Label 4. “Oxidizing substance” Label 5. “Organic oxidizing substance”

Label 6. “Toxic”Label 7. “Irritant” Label 8. “Infecting Substance” Label

The above mentioned legislation framework shows clearly the responsiblity of related government’s departments/agencies, in which each sector adjusts existing regulations to the GHS.

The government has resources competent for legislation aspects and implementation techniques of the GHS, and has the capacities for facilitating the implementation of national regulations.

5.3.2 Bussines and Trade Transporting service industries in Indonesia do not classify single/mixture chemicals, label and MSDS. Labelling and MSDS are done by the chemicals manufacturers, while the authority for classification is owned by the government. Transporting service industries attach the labels on transport vehicles.

Communication means for classification and labelling of chemicals used in transport sector in Indonesia still refer to the IMDG Code, but still has to be adjusted to the GHS. Transportion sector applies additional operation to facilitate chemical hazard communication effectively, e.g. trainings (awarded with certificates from accrediting institutions) for drivers and co-drivers of hazardous substance vehicles.

Although some chemical hazard communication programs have been conducted, the implementation, however, still has to be intensified, i.e. by improving the awareness and addtional trainings for businees and commerce societies, as well as the environmental societies, so that the GHS implementation will be running effectively and comprehensively.

Multinational transporting service industries have the capacities adequate for making necessary changes, so that the GHS implementation will be running effectively.

Existing programs such as Responsible Care may be implemented to intensify the use of the GHS in Indonesia.

5.3.3 Civil Society Worker societies and NGO’s have the capacities and interests in contributing to the implementation of the GHS.

In transportation sector, research is conducted by Balitbang Departemen Perhubungan (R & D institution under the Department of Communication) through panel discussions by inviting organizations and associations to gather

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inputs for the research. As for the training, this is conducted by the government, i.e. the Department of Transportation, in co-operation with private companies.

Programs for implementation of the GHS initiated by the above mentioned societies may be conducted via research, trainings, and socialization.

NGO’s related to transport sector may take part in encouraging the public awareness and knowledge of the implementation of the GHS, i.e. through socialization and discussion. School organizations have not so far given contribution to the implementation of the GHS; such contribution may be in the form of extra-curriculum activities.

5.4 Consumer Products

5.4.1 Government Indonesia does not have special regulation for the classification of consumer products of which are generally in the form of mixtures of chemicals. Meanwhile, in the GHS there is a regulation for calssification of chemical mixture, which can be used for the classification of products based on the composition.

Regulation related to labelling of consumer products, e.g., Law No. 8 year 1999 on Consumer Protection, includes label elements but they are different at all from those mentioned in the GHS. Meanwhile, the Ministry of Agriculture Decree No.517/Kpts/Tp.270/9/ 2002 on Pesticides Control includes only 2 of label elements mentioned in the GHS, i.e., product identitiy and pictogram. Ministry of Agriculture Decree No. 434.1/Kpts/TP.270/7/2001 on Conditions and Procedures of Pesticides Registration includes 6 of label elements mentioned in the GHS, namely product identity, supplier identity, chemicals identity, hazard pictogram, hazard statement, and signal word, as well as expire date, medical care, toxic symptom and first aid measures. However, pictogram and classification methods mentioned in both decrees still refer to the FAO/WHO regulations.

Issued by Indonesia’s National Agency for Standardization, the SNI, as the only standard that regulates each type of consumer products, includes only 3 to 4 of label elements mentioned in the GHS (depending on type of products), namely product identity, supplier/manufacturer’s identity, composition/identitiy of chemicals, and, for certain products such as pesticide, signal word.

Based on the Government Regulation No. 102/2000, one may have the priority to choose one’s consument products that have to conform to the SNI, partially or fully, for labelling conditions in accordance with the GHS.

Table 17 : Comparison of Regulations on Labeling for Consumer’s Goods

GHS Law No. 8 Year

1999 On Consumer Protection

Department of Agriculture

National Agency for Standardization

1. Chemical identity

2. Product identifier 3. Supplier

identification

Article 8 a. Net weight, net

volume, and amount in number

Ministry of Agriculture Decree No. 517/Kpts/Tp.270/9/ 2002 On Pesticides Control

SNI 06-0080-1987 on Bleaching Liquor Quality and Test Object name Content Supplier’s name and address

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4. Pictogram 5. Hazard

Statement 6. Signal word 7. Precautionary

statement

b. condition, guarantee, special features or effectiveness

c. quality, degree, composition, manufacturing process, fashion, mode, or specific use

d. "halal" (allowed by Islamic law) declaration if produced in Islamic way

Article 5 The obligation of the consumer is to read/follow the information and direction of use/utilization of goods or services for the sake safety and security. Article 7 The obligation of the corporation is to give right, clear, and honest information on the condition and guarantee of goods or services and to give direction of use, repair and maintenance.

Article 1 Description on pesticides Ministry of Agriculture Decree No. 434.1/Kpts/TP.270/7/2001 on Conditions and Procedures of Pesticides Registration Appendix VII Description that has to be included in label : a. Trade name formulation b. Pesticides type c. Name and ontent of

active ingredients d. Net volume and weight

in package e. Safety warning f. Classification and

hazard symbol g. Safety guideline h. Toxic symptom i. First aid measures j. Medical care k. Handling guideline l. Direction of use m. Pictogram n. Registration number o. Name, address and

telephone number of regitration number holder; production number, month, year and expired date

p. Direction of destruction

SNI 06-1842-1995 on Floor’s Cleaning Agent/ Desinfectant Product name Content of active ingredients Direction of use Product code Supplier’s name, address and logo Valid regulation

SNI 06-2588-1992 on Liquid Synthetic Detergent for Hand Cleaning Trade name Manufacturer Net Volume/weight Product content Special requirement

SNI 14-3344-1994 on Paper Tissue Napkin

Manufacturer or trade name Phrase: ”Paper Tissue Napkin” Size, with the notation order of width (mm) x length (mm)

Number of sheet SNI 16-4772-1998 on Baby’s

Dummies Trade name Number of Content Manufacturer’s name Manufacturer’s address Dealer’s License Number Production Code Storage Direction of use and cleaning care Signal word SNI number (Indonesian National Standard number)

SNI 16-4773-1998 on Shampoo for Carpets According to valid regulation Warning about possible damage

in case of misuse, including prohibiton of use on specific materials

SNI 06-4903-1998 on Clothing Softener In accordance with Decree of

Minister of Health No. 96/Menkes/ Per/V/ 1997 on Container, Wrapping, Labelling, and Cosmetics and Health products Advertisement

Warning : ”Attention! Keep out of reach of children”

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SNI 06-4904-1998 on Cleaning Powder for Hard Surfaces In accordance with Decree of Minister of Health No. 96/Menkes/ Per/V/ 1997 on Container, Wrapping, Labelling, and Cosmetics and Health products Advertisement SNI 16-4946.1-1998 on Mosquito Repellent, Lotion In accordance with Decree of

Minister of Health No. 96/Menkes/ Per/V/ 1997 on Container, Wrapping, Labelling, and Cosmetics and Health products Advertisement

In accordance with Decree of Minister of Health No. 376/Menkes/ Per/VIII/ 1990 on Substance, Coloring agent, Preservation agent, and Sunlight protecting agent on Consmetics

Decree of Minister of Agriculture No. 429/Kpts/um/9/1973 on Conditions for Packaging and Labelling of Pesticides

SNI 16-4946.2-1998 on Mosquito Repellent, Gel In accordance with Decree of

Minister of Health No. 96/Menkes/ Per/V/ 1997 on Container, Wrapping, Labelling, and Cosmetics and Health products Advertisement

In accordance with Decree of Minister of Health No. 376/Menkes/ Per/VIII/ 1990 on Substance, Coloring agent, Preservation agent, and Sunlight protecting agent on Consmetics

Decree of Minister of Agriculture No. 429/Kpts/um/9/1973 on Conditions for Packaging and Labelling of Pesticides

SNI 16-4946.3-1998 on Mosquito Repellent, aerosol In accordance with Decree of

Minister of Health No. 96/Menkes/ Per/V/ 1997 on Container, Wrapping, Labelling, and Cosmetics and Health products Advertisement

In accordance with Decree of Minister of Health No. 376/Menkes/ Per/VIII/ 1990 on

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Substance, Coloring agent, Preservation agent, and Sunlight protecting agent on Consmetics

Decree of Minister of Agriculture No. 429/Kpts/um/9/1973 on Conditions for Packaging and Labelling of Pesticides

Warning: ”Attention !Avoid contact with eyes or other selaput lendir lain and do not inhale” ”Attention ! Presurized container, may explode at temperatures exceeding 50oC. Do not pierce, do not place in heated areas, near fire, or dispose of into incinerator.

The number of staff member of the government’s officers that have knowledge of legislation and technical aspect of the GHS implementation is still limited. Therefore, they do not have adequate capacities in facilitating the implementation of the GHS. The contribution of government’s institutions such as Sentra Informasi Keracunan (Information Center for Toxicity) of NADFC (National Agency for Drug and Food Control) to the GHS need to be intensified in terms of capacity, capability, and socialization.

5.4.2 Bussiness and Trade In Indonesia, industries that have appropriate knowledge and capacities of the classification of chemicals based on the GHS are limited to those of foreign investments/multi-national. Middle-scale and small-scale/home industries do not have enough capabilities for labelling based on the GHS, so that their capabilities need to be improved. So far as the labelling of consumer products concern, there is no standard at all that can be adopted by all levels of industry.

MSDS for consumer products is out of discussion since they have been in the form of end products that are used directly by the consumers (therefore, they do not use MSDS). Hazard communication is done via the labels attached to the products.

Additional activities in facilitating the chemical hazard communication, such as trainings for the workers, have been conducted by the multi-national industry group only, in contrast to the other industry levels.

Considering the variation of industry profiles in Indonesia, it is necessary to encourage the knowledge, awareness, understanding, and additional trainings for business and commercial societies.

There is no aggreement within the industries producing chemicals in Indonesia to adopt the classification and labelling based on the GHS, so that the capacities in the business and commerces have not yet been made use optimally.

One of agencies that have been arranging for implementation of the GHS is KNRCI. The arrangement includes such activities as socialization and trainings for its employees.

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5.4.3 Civil Society Social observers and workers do not have adequate capacities and insterest in contributing to the implementation of the GHS, one of the causes is lack of knowledge on the GHS. Resources in these group should get that knowledge on the GHS.

Financial resources special for the implementation of the GHS within the NGO’s are not available continually. Foreign fundings that once have been given were incidental and assigned for research/test, in which the products tested were dependent on the consumers’ need, e.g., hazardous substances in the products.

There are indeed interest and adequate capacities within academic societies that may support the implemention of the GHS through research and trainings. However, since lack of means and infrastructures in terms of laboratories, chemical apparatus, and supporting funds, the research has not yet been conducted.

Additional programs for promoting the implementation of the GHS that may be initiated effectively by the public organizations (including the mass media) may include the Talkshows, leaflets, and booklets.

The GHS contains regulations on classification and labelling in a scientific manner. Therefore, the socialization of the GHS should be conducted in a language that is understandable by the public in general.

Potential roles of the school community or organization are: • Socializing the GHS in informal/school children language • Compelling the program into school’s extra-curriculum • Training the teachers to undertand the GHS implementation, so that they

may insert the idea of the GHS into other relevant school’s subjects during the class, although the curriculum has not yet covered the GHS.

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6. Summary of Key Findings Indonesia has already had several regulations pertaining to chemicals issued

by different institutions that cover classification, labelling, and SDS. However, the scope of these regulations is partial in nature. It can be seen that almost all of the existing regulations (except to some extend, Ministry of Manpower Decree No. Kep. 187 / MEN / 1999 On the Control of Hazardous Chemicals at Work Sites) do not include classification criteria for chemical hazard in their provisions. In addition, overlaps are exist among regulations leading to disharmony in the implementation of regulations. For instance, SDS format issued by Ministry o Manpower is different to that of SDS format issued by Ministry of Health.

In the context of GHS implementation, a multisectoral process is of necessary. Firstly, there should be an agreement amongst all related sectors to adopt this new system. Secondly, government need to establish higher-level regulation for GHS implementation to encourage the participation of all stakeholders. And finally, there is a need to have one formal institution/agency acts as a monitoring body for implementing GHS effectively. Based on meetings that have been conducted, most of the stakeholders have agreed that industrials sector, agricultural sector and consumer product sector to adopt the GHS requirements along with adoption by international organizations such as FAO, ILO and WHO. Meanwhile transportation sector conform to the UN-RTDG requirements which will include the GHS criteria and elements that related to transport sector.

The main problems for the GHS implementation within government institutions as well as private sector are lack of human resources in term of knowledge and legislation aspects, limited fund and lack of expertise for conducting GHS training. Without any doubt, there will be only multinational and large national industries which have adequate capacities and capabilities in GHS implementation, whereas small and middle enterprises might have difficulties. KNRCI as the prominent organization in the industrial sector that has deep interest in implementing GHS could become an effective partner for the government to encourage the GHS implementation in Indonesia.

Training on GHS technical aspect is a very important activity to enhance human resources capacity in GHS implementation. Nevertheless, due to limitation of fund and expert this activity is not very often conducted in the country. The existence of several trainings on this matter until now is supported by foreign aid. The training is divided into 3 different levels i.e. advance, intermediate and elementary level. It has been recorded that to date, Indonesia has 22 people graduated from advance level and 25 people graduated from intermediate level and 14 people graduated from elementary level. This is actually a very small number of trained personnel as compare to the complexity of GHS implementation that will be conducted nationally.

Chemical hazards communications is a pivotal tool for public awareness raising. To date the forms of hazard communication that have been conducted so far are through radio talk show and dissemination of printed form such as leaflets, brochures and posters. Most of these activities are conducted by government with limited target audiences. Related NGOs and associations

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which have function in chemical hazard communication are expected to involve. In fact, the NGOs couldn’t give significant contribution because they usually have limited fund. Therefore, their contribution for GHS implementation is really dependant to the capability of government to provide sustainable fund for them to socialize the GHS. Meanwhile, socialization for students which are supposed to be a strategic target has not conducted yet. Nevertheless, the one of most possible ways for initial introduction of GHS to the students are by inclusion this material into the school curriculum or as an extra curriculum activity.

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7. Next Step 1. It is necessary to conduct trainings and socialization activities in order to

confer knowledge and understanding of the GHS to related stakeholders and down to those that are directly in contact with hazardous chemicals, e.g., loading and unloading labors at ports.

2. Attain agreement from all stakeholders about parts of the GHS requirement that must be a mandatory obligation and which parts of it could be voluntary requirement, based on respective interest.

3. Law enforcement has to be intensified, in terms of giving penalty to those who violate the law. In this case, the first thing to be conducted prior to intensifying law enforcement is socialization of the regulations itself. Then, there must be a regular inspection conducted by authorized institutions in their respective sectors to see the implementation of regulation in reality. Documentation of data violators and good businessmen is a must. Penalty must be given according to that data in order to encourage the obedience of all stakeholders.

4. Information network amongst related stakeholders needs to be created. 5. It is necessary to create information system of GHS management.

6. A priority scale is needed in the context of implementing GHS. For example, agricultural sector will start the GHS implementation for pesticides as long as the FAO/WHO regulation already adopted GHS in their system. While product consumers sector will start the GHS implementation for a group of products that are commonly used products such as household cleaning products, paints, thinners, inks, printing substances, crayons, and gas in container. Whereas, industrial sector will start the GHS implementation for single substances only. Transportation sector will follow each regulation issued by UNRTDG in relation to GHS implementation..

7. Improvement of co-operation amongst stakeholder.

8. It is necessary to establish an agency/institution that is explicitly responsible for the implementation of the GHS.

9. Adequate and sustainable financial supports are needed.

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ANNEXES

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Annex I

Requirements on Labelling in SNI (Indonesian National Standard) for Several Consumer Products

Indonesian National Standard

SNI 06-0080-1987 on Bleaching Liquor Quality and Test • Object name • Content • Supplier’s name and address SNI 06-1842-1995 on Floor’s Cleaning Agent/ Desinfectant • Product name • Content of active ingredients • Direction of use • Product code • Supplier’s name, address and logo • Valid regulation SNI 06-2588-1992 on Liquid Synthetic Detergent for Hand Cleaning • Trade name • Manufacturer • Net Volume/weight • Product content • Special requirement SNI 14-3344-1994 on Paper Tissue Napkin • Manufacturer or trade name • Phrase: ”Paper Tissue Napkin” • Size, with the notation order of width (mm) x length (mm) • Number of sheet SNI 16-4772-1998 on Baby’s Dummies • Trade name • Number of Content • Manufacturer’s name • Manufacturer’s address • Dealer’s License Number • Production Code • Storage • Direction of use and cleaning care • Signal word • SNI number (Indonesian National Standard number) SNI 16-4773-1998 on Shampoo for Carpets • According to valid regulation • Warning about possible damage in case of misuse, including prohibiton of use on specific

materials

66

SNI 06-4903-1998 on Clothing Softener • In accordance with Ministry of Health Decree No. 96/Menkes/ Per/V/ 1997 on Container,

Wrapping, Labelling, and Cosmetics and Health products Advertisement • Warning : ”Attention! Keep out of reach of children” SNI 06-4904-1998 on Cleaning Powder for Hard Surfaces • In accordance with Ministry of Health Decree No. 96/Menkes/ Per/V/ 1997 on Container,

Wrapping, Labelling, and Cosmetics and Health products Advertisement SNI 16-4946.1-1998 on Mosquito Repellent, Lotion • In accordance with Ministry of Health Decree No. 96/Menkes/ Per/V/ 1997 on Container,

Wrapping, Labelling, and Cosmetics and Health products Advertisement • In accordance with Ministry of Health Decree No. 376/Menkes/ Per/VIII/ 1990 on

Substance, Coloring agent, Preservation agent, and Sunlight protecting agent on Consmetics

• Ministry of Agriculture Decree No. 429/Kpts/um/9/1973 on Conditions for Packaging and Labelling of Pesticides

SNI 16-4946.2-1998 on Mosquito Repellent, Gel • In accordance with Ministry of Health Decree No. 96/Menkes/ Per/V/ 1997 on Container,

Wrapping, Labelling, and Cosmetics and Health products Advertisement • In accordance with Ministry of Health Decree No. 376/Menkes/ Per/VIII/ 1990 on

Substance, Coloring agent, Preservation agent, and Sunlight protecting agent on Consmetics

• Ministry of Agriculture Decree No. 429/Kpts/um/9/1973 on Conditions for Packaging and Labelling of Pesticides

SNI 16-4946.3-1998 on Mosquito Repellent, aerosol • In accordance with Ministry of Health Decree No. 96/Menkes/ Per/V/ 1997 on Container,

Wrapping, Labelling, and Cosmetics and Health products Advertisement • In accordance with Ministry of Health Decree No. 376/Menkes/ Per/VIII/ 1990 on

Substance, Coloring agent, Preservation agent, and Sunlight protecting agent on Consmetics

• Ministry of Agriculture Decree No. 429/Kpts/um/9/1973 on Conditions for Packaging and Labelling of Pesticides

• Warning: • ”Attention !Avoid contact with eyes or other selaput lendir lain and do not inhale” • ”Attention ! Presurized container, may explode at temperatures exceeding 50oC. Do not

pierce, do not place in heated areas, near fire, or dispose of into incinerator.

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Annex II

Mechanism of Information Service on Poison Cases

NETWORK OF SIKer (POISON INFORMATION CENTER) OF NADFC

(BADAN POM)

NATIONA L SIKerPIOM

NADFC

REGIONAL SIKer

LIK, NADFC

REGIONAL GOVT’S

HOSPITALS & LOCAL CLINICS

POLICE

COMM

UNITIESIN

TRA-

SECT

ORAL

INFORMATION ON THE MOTIVE OF

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