GHS Around the World – Get Ready.

The Globally Harmonized System of Classification and Labelling (GHS) began in 1992 at the United Nations Conference on Environment and Development (UNCED). In 2009, the GHS has begun to be implemented around the world, including in Japan, New Zealand and the European Union (EU). And in the United States, proposed regulations are expected out in the fall of this year.

Hazard communication status in the United States

Over the last several years, the Occupational Safety & Health Administration (OSHA) has been steadily working on the revision of its current Hazard Communication Standard (HCS) for the GHS. In 2006, OSHA published its Advance Notice of Proposed Rulemaking (ANPR), and since that date, has been working to revise the HCS based on comments and concerns raised by Industry and other interested parties. OSHA has now completed their revisions and is preparing to publish its Notice of Proposed Rulemaking (NPRM), which is expected sometime around October of 2009.

OSHA does continue to deliberate on various issues such as, possible implementation periods, with some suggestions including whether there should be 3 or 5 year implementation phase ins.

Some of the highlights of the changes that will appear in the NPRM include:

• Sixteen section GHS-style safety data sheets (SDS) will become part of the HCS. However, specific sections of the SDS will be identified as not falling under the jurisdiction of OSHA (e.g. Section 14 will fall under the jurisdiction of the U.S Department of Transport, Section 12 will fall under the jurisdiction of the Environmental Protection Agency). The content of those sections, therefore will not fall under the HCS.
• OSHA substance and hazard specific standards will all show changes to take the GHS into account.

The Advance Notice of Proposed Rulemaking (ANPR) will be available for public comment following its publication.

Hazard communication status in the European Union

The new Regulation on classification, labelling and packaging (CLP) of substances and mixtures has now been formally adopted by the European Council and Parliament as of November 28, 2008. The adopted acts were submitted to the Official Journal of the EU on December 16, 2008, and were formally published in the Journal on December 31, 2008. The text of the publication can be found at the following link:
http://eur-lex.europa.eu/JOHtml.do?uri=OJ:L:2008:353:SOM:EN:HTML

Of importance currently, is that the previous harmonized Annex I list of classifications has now been repealed by the new CLP regulation and replaced by the new list that is found in Annex VI of the CLP. This new list of harmonized classifications does not yet include the revisions that were introduced in the old Annex I list through the 30th and 31st Adaptations to Technical Progress (ATP's) of the Substance Directive 67/548/EEC. The first ATP of the CLP Regulation, however, has been introduced in March of 2009 which will bring the changes found in the 30th and 31st ATPs of the substance directive. All suppliers, manufacturers and importers are being encouraged to adopt the new and additional classifications that are found in the 30th and 31st ATPs even though, those changes are not yet in force.

Other parts of the new EU CLP Regulation are also in force, but some parts do not apply as of yet. The parts that do not apply include those for new GHS classifications and labelling. Those parts of the CLP Regulation will come into force as the transition periods to convert all classifications and label information to the GHS, end.

The deadlines for substance re-classifications remains December 1, 2010, and for mixtures, June 1, 2015.

Other new Hazard communication highlights

China

• The mandatory standards GB20575-20594 which introduced GHS hazard criteria, classifications and labelling requirements became effective December 31, 2008.
• The voluntary Safety Data Sheet standard also because effective in 2008.
• The voluntary labelling standard became effective February 1, 2009.
• The mandatory labelling standard GB15258 is expected to become mandatory sometime in 2009.

Singapore

• Singapore has now revised three parts of their regulations for the GHS.
• Singapore's transition periods are multi-tiered and include 2 and 4 year transition periods for manufacturer's and supplier's (ending in 2010 for pure substances or 2012 for mixtures); and 3 and 5 year transition periods for end users (ending in 2011 for pure substances or 2013 for mixtures).
• GHS building blocks that have not been picked up by Singapore include Category 4 flammables, and Category 5 acute toxics, as well as other 'low hazard' health categories.

Malaysia

• Draft GHS regulations are expected to be released in 2010. Transition periods discussed include only a one year transition for pure substances and a three year transition for mixtures.
• Of interest in Malaysia is that the government is looking at a European REACH-like reporting requirements which will incorporate its GHS requirements.

Japan

• Japan is now proceeding with risk-based labelling for consumer products. A guidance document in English will be available soon.

Australia

• The first GHS proposal introduced in Australia came out in 2006. Following that proposal, the Australian government received a large number of comments from industry, and then released a second proposal in 2008. The second proposal removed any mention of implementation dates.
• The National Drugs and Poisons Scheduling Committee has decided to keep their current standard for drugs and poison, which does not include GHS Classifications, GHS hazard statements or pictograms, until such time as the two systems become further aligned.

Every label in Canada, the United States and around the world will have to be changed to accommodate the GHS, as well as all Safety Data Sheets. The Sales, Customer Service and Regulatory Staff at ICC The Compliance Center Inc. will be happy to help you in all of your GHS needs. For more information on the GHS, contact us and/or visit our website today at www.thecompliancecenter.com.

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