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This document outlines the implementation of the Globally Harmonized System (GHS) in the chemical industry, highlighting key impacts and initiatives across various countries. It discusses the U.S. regulatory agenda, government proposals, and industry-specific challenges in aligning with GHS standards. The overview includes timelines for compliance, the need for training, and strategies for collaboration between governments and the private sector to foster successful GHS adoption. Ultimately, it emphasizes the importance of information sharing and partnerships for effective implementation.
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Implementation of GHS An industry view
Outline • Impacts of implementation • Industry initiatives • Timeframes • Way forward
Implementation of GHS Impact of implementation
USA OHS • government's semi-annual regulatory agenda published in 2005 includes GHS. • an advance notice of proposed rulemaking will be published this year. EPA • white paper on implementation of the GHS for pesticides being consulted. CPSC • work done on a situational analysis on consumer products DOT • planning to adopt the necessary changes to be consistent with the GHS in 2007, and have them go into effect in 2008.
Scope • Substances: • EU: 30 000 subject to REACH • Japan: 26 000; 1 500 require MSDS by law • Mixtures: • EU: 2 000 000
EU Chemical Industry Structure • 98% of Enterprises are SMEs (including Micros) • > 75% of SMEs are formulators only • > 55% of SMEs are not members of a Trade Association
EU: GHS Implementation Issues Timetable R E A C H R e g I s t Year +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 -1 -2 -3 Classification Options Other CA Options Draft Legislation Revise REACH Substance Classification Mixture Classification Downstream Legislation Annex I Reclassify to GHS Annex I/Transport Differences Nota/SP Harmonisation Substance Inventory Draft Guidance GHS Training
Challenges • Significant legislative amendments • Co-ordination across fragmented national systems • Number of substances in market • Chemical industry structure • Training
Challenges • Decisions on discretionary elements • Substances vs mixtures • Translation into non UN languages
Implementation of GHS Industry initiatives
Responsible Care • Occupational health and safety • Risk management requires hazard classification • Pollution prevention • Classification of waste • Product stewardship • Hazard communication down value chain
Capacity building • Raising awareness at enterprise level • Support for international initiatives • Sharing of best practice and data • Generation of hazard data: HPV • Global portal
Technical support • Contribution to end point testing • Participation in OECD technical committees
Industry activities • Participation in UN Subcommittee • Advocacy at national and regional level • Raising awareness at enterprise level • Supporting capacity building activities • Developing implementation plans in line with national legislation
Implementation of GHS Timeframes
Implementation of GHS Way forward
Partnerships • Successful implementation will depend on • co-operation amongst countries • partnerships between Government and private sector • sharing information amongst companies • Trade facilitation