GHS Implementation – A Quick Guide for International Suppliers

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Courtesy of The Compliance Center (ICC)

Slowly but surely, the Globally Harmonized System (GHS) is becoming “the way things are done” for hazard communication around the world. Many countries have already implemented internal versions of the GHS. Others, such as the United States and Canada, are on the verge of introducing their own. How does one keep track of who’s doing what? Here’s a list of some of the most vital resources for those concerned about hazard communication worldwide.

 The UN “Purple Book” (Globally Harmonized System of Classification and Labelling of Chemicals (GHS)). This document is the basis of the GHS around the world. It is developed by the UN Subcommittee of Experts on the Globally Harmonized System (UNSCEGHS). The GHS Subcommittee has been tasked with producing biennial updates to this document; currently, the book is in the third revision (2009-2010). You can obtain a downloadable version of the Purple Book at http://www.unece.org/trans/danger/publi/ghs/ghs_rev03/03files_e.html. The download is free, and you do not have to register (files are in Adobe .pdf format).

  1. UN Guidance documents. Although the Purple Book is, at first glance, written in reasonably clear language, some of the sections are very technical. The UN has provided some guidance documents that can help readers understand the rules in more general terms. These guides include:
    1. Understanding the Globally Harmonized System of Classification and Labeling of Chemicals (GHS): A Companion Guide to the Purple Book. This document is published by the United Nations Institute for Training and Research (UNITAR), and can be downloaded at http://www2.unitar.org/cwm/publications/pag_ghs/pag13/PAG_13-3_Guide.pdf.  This document steps the reader through classification, hazard communication and general application.
    2. Guidance on the application of Globally Harmonized System (GHS) criteria to petroleum substances. This document, as its title implies, specifically addresses the impact of GHS on petroleum producers and suppliers, addressing issues such as chemicals commonly found in petroleum products, and testing protocols that avoid unnecessary use of live animals. It’s available from the IPIECA, an international organization of petroleum companies,  at http://www.ipieca.org/publication/guidance-application-globally-harmonized-system-ghs-criteria-petroleum-substances.

  2. National and International Implementation Guides.
    1. One of the main overviews of international implementation of GHS comes, once more, from the UN. Their implementation site at http://www.unece.org/trans/danger/publi/ghs/implementation_e.html includes details for 67 countries and covers sectors involved, relevant regulations (usually with links to the actual text) and current or projected time frames. Unfortunately, the information is not always the most up to date, but it is an essential starting point for researching regulations in specific countries.
    2. The European Parliament and Council has adopted a new Regulation on the Classification, Labelling and Packaging of Substances and Mixtures which will eventually replace current directives on hazard communication with one based on the GHS. Information on this regulation and implementation can be found at http://ec.europa.eu/enterprise/sectors/chemicals/documents/classification/#h2-guidance-and-helpdesks.
    3. In the US, the Occupational Safety and Health Administration (OSHA) has published a notice of proposed rulemaking regarding replacing the current workplace hazard communication system with one based on the GHS. Check out their webpage at http://www.osha.gov/dsg/hazcom/global.html for links to the proposal text, as well as links to GHS reports from other US agencies such as the Environmental Protection Agency (EPA), and other countries, such as Canada.
    4. Health Canada has a webpage at http://www.hc-sc.gc.ca/ahc-asc/intactiv/ghs-sgh/index-eng.php that summarizes Canadian activity. Unfortunately, no specific dates for implementation are listed, and some of the information may be rather outdated.
    5. The Japanese government’s website on GHS at http://www.safe.nite.go.jp/english/ghs_index.html includes some interesting documents, including a list of approximately 1,500 chemicals classified by the Japanese GHS Inter-ministerial Committee. While these are not mandatory classifications, and are described as being “conservative” (that is, assuming the worst hazard likely when classification was not clear), they are safe classifications to use in the Japanese market.
    6. Work Safe Australia has a page listing proposed amendments to their hazard communication regulations that will incorporate the GHS at http://www.safeworkaustralia.gov.au/swa/HealthSafety/HazardousSubstances/Proposed+Revisions/.
    7. The Society for Chemical Hazard Communication (SCHC) is part of an alliance with OSHA to improve hazard communication in the US. They have a number of technical fact sheets, such as one comparing GHS labels to current OSHA requirements, at http://www.schc.org/schc-osha-alliance

 

Already, the GHS is having a growing impact on exporters to the world market. If you would like more information on the GHS, please contact ICC.

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