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INTERNATIONAL COUNCIL OF CHEMICAL ASSOCIATIONS |
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INTERNATIONAL COUNCIL OF CHEMICAL ASSOCIATIONS |
ICCA COMMENTSONGLOBALLY HARMONIZED SYSTEM FOR CHEMICAL CLASSIFICATION AND LABELING |
INTRODUCTION
Background
The International Council of Chemical Associations (ICCA) is a council of leading trade organizations and their member companies representing chemical manufacturers in Japan, Australia and New Zealand, Europe, and North and South America. ICCA represents approximately eighty percent of worldwide chemical production. ICCA’s focus is on developing global chemical industry positions and evolving programs on issues of international significance to the industry in areas such as health, safety, and the environment; international transport safety; intellectual property; trade policy; and industry efforts to eliminate chemical weapons and diversion of illegal drugs. ICCA also promotes and coordinates Responsible Care® and other voluntary chemical industry initiatives. The chemical associations in forty-five countries implement ICCA’s Responsible Care® initiative.
In September 2000 the ICCA published a paper setting out its comments on Globally Harmonized System for Chemical Classification and Labeling (GHS). The paper focused on the benefits of globally harmonizing chemical product hazard communication systems. The principal statement made in the paper is the following:
ICCA supports efforts related to the global harmonisation of hazard classification and communication systems for chemicals (GHS)…. [W]e believe that the implementation of the non-binding GHS in a consistent manner is necessary to promote the safe use of chemicals world-wide and global free trade. This would also eliminate any uncertainty or ambiguity arising from apparently different classifications or information being given in hazard communication for the same goods originating in different countries and are traded internationally.
The negotiations to develop the GHS were completed in 2001. These negotiations were a result of the commitments made at the United Nations Rio Conference on the safe management of chemicals initiatives. The negotiations are directly related to the work program in Agenda 21 Chapter 19, which ICCA supports.
The GHS now resides in the United Nations Economic and Social Council (UN ECOSOC) and is managed by the Sub- Committee of Experts on the Globally Harmonized System of Classification and Labelling. The Sub-Committee on GHS is currently reviewing the Globally Harmonized System for Hazard Classification and Communication approved by the Inter-Organisation Programme for the Sound Management of Chemicals (IOMC) Coordinating Group for the Harmonization of Chemical Hazard Classification and Labelling. The Sub-Committee on GHS will adopt a GHS document in December 2002.
This paper serves as a companion to the ICCA’s September 2000 paper by describing the key elements of the GHS that competent authorities should be aware of when implementing the system.
There are several key concepts addressed in the GHS classification scheme that national and regional bodies need to incorporate into their systems:
GHS classification for chemicals and chemical mixtures in the workplace is based on hazard classes (commonly referred to as endpoints like acute toxicity or flammable) and categories (categories make further distinctions within classes based on the level of hazard). GHS does acknowledge that current national and regional systems may convey classification information differently depending on the sector audience or category level. National and regional systems should begin the process to implement the GHS as soon as feasible after its adoption by the United Nations Sub-Committee on GHS in December 2002. Full implementation of the GHS will depend on the particular circumstances of each national and regional system.
GHS prescribes specific elements for communicating hazards associated with chemicals and chemical mixtures. These standardized elements cover hazard symbols (including shape, border color and background color), signal words and hazard statements. ICCA supports the use of standardized label elements to ensure the safe transport and use of chemicals and chemical mixtures world-wide.
Chemicals and chemical mixtures classified using the GHS should be labeled according to the system. It is also important that the system continue to recognize that national and regional differences may require the use of non-standardized or supplement information. National and regional systems should begin the process to implement the GHS as soon as feasible after its adoption by the United Nations Sub-Committee on GHS in December 2002. Full implementation of the GHS will depend on the particular circumstances of each national and regional system.
ICCA supports and encourages national and regional competent authorities to adopt the 16-heading Safety Data Sheet approach in the GHS. A globally harmonized approach for sds will facilitate trade, and improve worker and end-user safety in the handling of chemicals and chemical mixtures. National and regional systems should begin the process to implement the GHS as soon as feasible after its adoption by the United Nations Sub-Committee on GHS in December 2002. Full implementation of the GHS will depend on the particular circumstances of each national and regional system. Additionally, it will be necessary to review and revise a number of internationally recognized standards that provide guidance in the preparation of a SDS. (Examples of these standards include: Recommendation 177 on Safety in the Use of Chemicals at Work, the International Standard 11014-1 of the International Standard Organization (ISO), the European Union Safety Data Sheet Directive EEC/91/155 and the American National Standard Institute (ANSI) standard z 400.1.)
It is anticipated that the GHS will be formally adopted and published within the UN structure in July 2003 by the UN ECOSOC. The implementation of the GHS should be considered in light of national and regional circumstances. The IFCS “Priorities for Action beyond 2002” encouraged all countries to adopt the GHS as soon as possible with a view to have the system fully operational by 2008, but the actual implementation timeframe is country specific. Competent authorities in consultation with affected stakeholders should determine a realistic timetable for implementation. Implementation should consider both domestic production and chemical imports, and resources available for the implementation and maintenance of the system.
There are two aspects of implementation that need to be considered.
All countries, particularly those with existing systems, should be encouraged to adopt the GHS. Initially this may mean that in order to facilitate uptake of the GHS, national governments or regional organisations may make extensive use of the 29 competent authority allowances in the GHS. This will inevitably mean in the first instance that there will be diverging national/regional implementations of the GHS.
However in the longer term, national and regional competent authorities should be encouraged to adopt the GHS in a consistent manner, and we would be looking for converging national/regional implementations of the GHS.
This would enable industry to classify its products once regardless of where it is used in the world. ICCA hopes that over time as GHS becomes more prevalent in national and regional chemical classification and hazard communication systems that this consistency among all jurisdictions will occur. In addition, over time non-standardized information, where appropriate and applicable, should also move towards a standardized approach.
For systems in transition and until national and regional consistency of the GHS has occurred accommodations within national or regional systems are necessary for product labeling. The practice currently used in some countries for imported chemicals could serve as a model for the GHS. For example, an importer who imports hazardous products that comply with UN transport requirements for labeling but do not comply with national workplace/consumer labeling, must label the product in accordance with national requirements, a) where the product is delivered to the address of the importer for his use or sale, before the product is used or sold (e.g., distributor), or b) where the product is imported to the address of the person to whom the importer has sold the product, before the product is used by that person (e.g., customer).
An alternative practice is that the person to whom the importer has sold the product undertakes to apply a label that the supplier may generate to the product.
To ensure a transparent process when implementing the GHS within a national or regional system it is important for competent authorities to understand and build relationships through an open dialog with suppliers of chemicals and chemical mixtures and other parties that support national and regional efforts to manage chemicals.
ICCA believes that the GHS can ultimately achieve two of the principal aims of Agenda 21, Chapter 19, the promotion of sustainable development and the facilitation of international trade. Within this context it is recognized that chemical use is essential in many aspects of life, and that the safe use of chemicals is a prerequisite for the promotion of sustainable development. The aim of the GHS is to ensure consistency of hazard information and the safe handling and use of chemical products. If we are to achieve true global harmonization consistent with the objectives of Agenda 21 Chapter 19, we need a commitment by all countries to implement the GHS in a consistent manner. Where implementation necessitates changes to existing systems, these should be introduced over a realistic timeframe. Although the co-existence of differing major classification systems may not have given rise to unacceptable risks, ICCA recommends that:
· countries with existing legislation change to the harmonized system on an agreed time-scale; and
· countries without classification and labeling schemes use the opportunity to apply the harmonized system.
11 April 2002