At the United Nations, the Sub-Committee of Experts on the Transport of Dangerous Goods (TDG) have unanimously granted observer status to the Dangerous Goods Trainers Association (DGTA).
This means, that as a non-governmental agency (NGO), DGTA will be able to contribute and comment on proposals and changes to the model regulations. Members of DGTA will be able to share their vast wealth of knowledge and experience with this regulatory body.
Dr. Bob Richard (Labelmaster) was insturmental in writing up the application and presenting at the UN. The chair of DGTA, Leif Soderman (Optimal Assistans Sweden), will be representing DGTA at the TDG meetings.
For more information on the DGTA, please go to www.dgta.org
In January 2011, OSHA proposed that in August of this year, they would publish the final rule to align the current Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The more recent DOL Spring semi-annual regulatory agenda released in June revisits the scheduling of the release of the HCS revision to an unspecified date in September of this year. September has now come and gone, and we are still without a final rule from OSHA.
This leads to the question of “If not now, then when?”. It is probably a safe assumption that OSHA’s lack of implementation of GHS to date will be a major topic of discussion at the October 1st – 5th Society for Chemical Hazard Communication (SCHC) fall conference in Washington, DC. Many health and safety professionals, myself included, will be impatiently waiting for word of a revised deadline.
In June of 2011, the fourth revised edition of the UN’s Globally Harmonized System of Classification and Labelling of Chemicals (GHS, Rev.4) was issued.
The changes in the latest revision include two new hazard categories : chemically unstable gases and non-flammable aerosols. These new categories account for hazards not previously addressed where special precautions are needed when handling, storing or transporting these items. Acetylene, a commonly used welding gas is an example of a ‘chemically unstable gas’. Acetylene is unstable and can explode without an ignition source at pressures as low as 25 psi (172 kPa). For that reason, Acetylene is normally sold ‘dissolved’ in porous Acetone to allow for higher pressures. Additionally, a non-flammable aerosol, still presents a pressurization hazard and can explode if heated, even though it is not technically ‘flammable’.
The 4th Revised Purple Book provides additional clarification of some of the hazard criteria, such as for gases under pressure or mixture cutoffs for Category 1 Carcinogens; and further rationalization of precautionary statements, such as ‘P251 – Do not pierce or burn, even after use’ for non-flammable aerosols as well as flammable aerosols.
Also added, is a new special labelling arrangement for materials that are only corrosive to metals and not corrosive to the skin and eyes. The new option for the Competent Authority is to allow the hazard pictogram for the ‘Corrosive to metals’ category to be dropped on the label for a product that is in the finished state and packaged for consumer use.
These changes in the 4th Revised Edition will still require implementation in those Countries or Agencies that have implemented, or have begun to implement, the GHS into current systems.
For further information on all of the revisions in the 4th Revised Purple Book, please consult the United Nations Economic Commission (UNEC) website at:
If you have any questions regarding the changes in the 4th Revised Purple Book, or on the GHS, please contact ICC Compliance Center Inc at 1-888-442-9628 (USA) or 1-888-977-4834 (Canada).
by Barbara Foster on August 5, 2010 at 4:28 pm · in Barbara's Blog
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). 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 PDF version of the Purple Book at unece.org. The download is free and you do not have to register. Hard copies are available through our online store (US | Canada).
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:
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 unitar.org. This document steps the reader through classification, hazard communication and general application.
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 ipieca.org.
National and International Implementation Guides
One of the main overviews of international implementation of GHS comes, once more, from the UN. Their implementation site 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.
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 ec.europa.eu.
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 website 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.
Health Canada’s website summarizes Canadian activity. Unfortunately, no specific dates for implementation are listed, and some of the information may be rather outdated.
The Japanese government’s website on GHS 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.
Work Safe Australia has a website listing proposed amendments to their hazard communication regulations that will incorporate the GHS.
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.
Already, the GHS is having a growing impact on exporters to the global market. We constantly monitor the state of GHS around the world, so if you have questions about how it may affect your operations, or need assistance in preparing for its implementation, you’re always welcome to contact us.
Canada Gazette, Part II, EXTRA Vol.143, No. 3 is the proclamation proroguing Parliament to March 3, 2010. As a result of this proclamation, the Government of Canada virtually comes to a standstill: Parliament does not meet, committees are suspended, etc. In other words, TDG Amendment 8 is delayed yet again.
I often get the impression the international community is beginning to look at Canada as a banana republic. Schedule 1 of the TDG Regulations is at the 11th Edition of the UN Recommendations and everyone else is working on the 15th Edition. And we are not making any headway.
If you received a shipment marked UN3471 and looked it up in Schedule 1 of the TDG Regulations, you will notice that it is not listed. Do you know where to go to see if it is a valid UN number?
So, Prime Minister—once Parliament resumes on March 3, what are your plans to get the government working? Are you going to direct the Minister of Transport, John Baird, to get the lead out and publish Amendment 8? Will Minister Baird direct Marie-France Dagenais to expedite amendments to fix Amendment 6 and bring Canada into line with the international community, i.e. 15th Edition of the UN Recommendations? Why is this so hard?
Prime Minister—New Year’s resolution for you: I’m sure you have heard of Mike Holmes’ slogan, "Make It Right"; how about for the Government of Canada: "Make It Work".
