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

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  • Global Status of GHS Presented by Paula Laux Senior Regulatory Specialist Wercs Professional Services
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  • Why was GHS developed? So that a system exists where hazards are identically communicated to all those exposed
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  • Why was GHS developed? Today same product requires multiple MSDSs and labels in international trade Today there are different classification schemes between Environmental, Industrial, Transportation, and Consumer sector - even in same country Today the same substance/preparation requires different warnings based on jurisdiction
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  • Who is the target audience? Governments Companies Workers Emergency Responders Member of the Public Consumers
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  • What types of Chemicals are Regulated? Hazardous Chemicals Substances Products Mixtures Pesticides Consumers Products
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  • What is GHS? Globally Harmonized System of Classification and Labeling Defines health, physical and environmental hazards Establishes classification scheme using available data Establishes a common hazard communication method Explains how to apply the system Supplies building blocks for countries to develop own laws
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  • Published Guidance documents Published by the United Nation Economic Commission for Europe (UNECE) First publication in 2003 Revision 1 edition published in 2005 Referred to as UN Purple Book
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  • What GHS Isnt? A regulation or a standard Not mandated until it becomes law in a given region May require various regulatory authorities within region to pass laws
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  • *Summary of Slide Provide by Michelle Sullivan General Implementation Guidelines GHS: Voluntary international document- not binding treaty When countries adopt GHS into their systems, there will be binding regulatory changes for industry No international implementation schedule Different systems/sectors require different time frames for GHS implementation
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  • *Summary of Slide Provide by Michelle Sullivan Canada Implementation Looking for harmonization between NAFTA countries Sectors WHMIS, Consumer Chemical, Pesticide control, and Transportation Published, Comparison of Sector Interim Recommendations or Preferred Options (Feb, 2006) Next steps: Consultation with trading partners; Economic analysis, Development of final recommendations, Decision making, Draft regulations, Regulatory process, Phasing in implementation May revisit based on US and Mexican work.
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  • *Summary of Slide Provide by Michelle Sullivan EU Implementation As per REACH, GHS SDS formats required already June 1, 2007 Sections 2/3 should be inverted Transition period for GHS implementation 3 years for substances, 7-8 years for mixtures Will require extended SDS for certain material with varying phase-in period
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  • *Summary of Slide Provide by Michelle Sullivan Japan Implementation GHS labeling of ISHL (Industrial Safety and Health Law) 1-Dec- 2006 GHS labeling technically applies to only 99 of the denoted ISHL materials GHS classification manual does exist in English 1500 GHS classification of chemicals regulated in Japan Industrial labeling and SDS system based on GHS Have approved risk based labeling for consumer products (Not consistent with GHS)
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  • *Summary of Slide Provide by Michelle Sullivan Other Asia-Pacific Countries Australia, Bahrain, Bangladesh, Brunei Darussalam, China, Cambodia, Fiji, India, Indonesia, Islamic Republic of Iran, Japan, LAO, Malaysia, Maldives, Mongolia, Myanmar, Oman Philippines, QATAR, Republic of Korea, Sri Lanka, Thailand, Vietnam, Yemen 20/23 Countries have plans to implement GHS Several (New Zealand, Bahrain, & Mauritius) countries have already adopted GHS
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  • *Summary of Slide Provide by Michelle Sullivan Other Asia-Pacific Countries New Zealand GHS has been adopted in a legislative sense (GHS 2003) Revisions based on 2005 GHS (rev 1) expected in 2007 Implementation not planned before 2008 List of GHS classified chemicals Labeling being handled separately in order to align with major trading partner. (2010)
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  • *Summary of Slide Provide by Michelle Sullivan Other Asia-Pacific Countries Australia GHS MSDS format was effective April 2006 GHS classification proposal- Addresses only workplace Draft National Standard for the Control of Workplace Hazardous chemicals Transition period: 5 years for SDS No intent to use GHS mixtures rule Want to address a revised GHS hazardous substances list Intent to make draft for labeling of Workplace Chemicals and Preparation of SDSs as well
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  • *Summary of Slide Provide by Michelle Sullivan USA Implementation DOT For harmonization of transportation (US DOT) voluntary compliance is now authorized, the provisions become mandatory on 1-Jan-2008 Exception to above for Division 3 and 6.1- old packing groups can be used until 1-Jan-2012 Environmentally hazardous substances will be considered for change in a separate rulemaking proceeding
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  • *Summary of Slide Provide by Michelle Sullivan USA Implementation OSHA Under a Notice of Proposed Rulemaking (12-Sept-2006) OSHA considered modifying HCS to include: Changing criteria for classifying health & physical hazards Adopting standardized labeling requirements Requiring a standardized order of information for MSDS Final Rule anticipated at the end of 2008
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  • *Summary of Slide Provide by Michelle Sullivan USA Implementation Other Agencies EPA/FIFRA: Federal Register 25-Aug-2004 (situational analysis and white paper) Stakeholder meeting 19-Oct-2006 CPSC: Beginning work on situation analysis Current regulation includes consideration of risk, but not environmental endpoints.
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  • Best Source Of Implementation Information www.unece.org/trans/danger/publi/ghs/implementation_e.html
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  • Comparison of various regulations and pieces of GHS classification accepted *Compiled from multiple slides prepared by Michelle Sullivan, Ph.D
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  • Why was GHS developed? So that a system exists where hazards are identically communicated to all those exposed
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  • Other Challenges Ingredient Disclosure (Purple book leaves it Competent Authority) Additional Country Specific information that is outside classification Labeling (especially for Consumer Products that have been historically risk based)
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  • Global Status of GHS Questions/Comments?
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  • Global Status of GHS Contact Information: Paula Laux Senior Regulatory Specialist Wercs Professional Services 518 256-6774 paulal@thewercs.com