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In order to enhance the safety of human health and the environment, the GHS (Globally Harmonized System of Classification and Labeling of chemicals) was issued as a recommendation from the United Nations in 2003. The purpose of implementing GHS is for the provision of a recognized framework for countries without an existing system, to reduce the need for testing and evaluation of chemicals and to facilitate the international trade in chemicals whose hazards have been properly assessed and identified.
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Packaging Labels for Dangerous goods" -GB 190-2009.
This standard stipulates the classification pictogram, size, color, methods of usage and so on of the package labeling of hazardous goods. The aim of the standard is to implement the 15threvised edition of the UN recommendations on the Transport of Dangerous Goods. It entered into force in 2009.
2) Classification and Hazard Communication
"General rules for classification and hazard communication of chemicals" - GB 13690-2009
This standard entered into force on May 1 2010.
3) Precautionary Labeling
"General rules for precautionary label for chemicals" - GB 15258-2009
This standard entered into force on May 1 2010.
Recommended Standard
4) Safety Data Sheets
"Safety data sheet for chemical products: Content and order of sections" - GB/T 16483 -2008
This standard was published in June 2008 and entered into force in February 2009. It specifies the requirements of MSDS/SDS preparation in line with China GHS for manufactures, importers, downstream users and other users in the supply chain. The major differences between the two previous standards (GB/T 17519.1-1998 and GB 16483-2000) are as follows:
The order of 16 sections of the SDS information has been revised;
The definition for ‘substance’ has been added;
In Appendix A, part A3.2, the summary of danger has been revised to be consistent with the classification GHS.
‘China REACH’ New Chemical Substance Notification & China GHS
This new chemical regulation entered into force in October 15 2010 and affects all chemical companies manufacturing in or exporting new chemicals into China. Non-Chinese manufacturers must submit the notification through a Chinese legal entity or appoint a Chinese representative agent to submit the notification. For hazardous new chemicals, the notification dossier should also include China GHS classification and labeling.
Amendment to Hazardous Chemicals regulations (State Council [2002] No. 344 Decree) and the ‘Hazardous Chemicals Catalogue’
The current administrative law “Regulations on the Safe Management of Dangerous Chemicals”, is regarded as the basis for official GHS implementation covering labeling and SDS/MSDS requirements for industry in China. It was enacted by the State Council in Jan 2002 and took effect in March 15 2002. It is currently regarded as the principal legislation for the management of hazardous and dangerous chemicals in China. Manufacturers and importers are required to prepare material safety data sheets and labeling for chemicals listed in “Hazardous Chemicals Catalogue”9 and the “Highly Toxic Chemicals list”. If manufacturers or importers of these chemicals obtain any further hazardous information on the chemicals, a public notice should be made immediately and MSDS and labeling should be revised accordingly.
However, the current regulation is still based on the old classification system and has not yet incorporated GHS. Thus, SAWS has been authorized by MITT to amend this regulation for it to become the main implementation legislation in China concerning GHS.
In addition, SAWS is working on amending the “Hazardous Chemical Catalogue” as well as the “Highly toxic Chemicals list”, which will be integrated into “Hazardous Chemical Inventory”. This Inventory is principally aimed to be compatible with UN GHS as well as EU, USA, Japan and other countries’ classification criteria.
The amendment was once expected to be completed by 2008. However, as a result of various reasons including the argument about the transportation of hazardous and toxic chemicals via inland rivers, the amendment was postponed. The authorities are evaluating whether the relevant departments can manage the risk and control the exposure when transporting dangerous and toxic chemicals inland. The State Administration of Work Safety has recently confirmed that these issues have finally been agreed upon by all relevant departments. Thus a major roadblock for the No.344 Decree has been lifted.
The revised “Regulations on the Safe Management of Dangerous Chemicals” and “Hazardous Chemicals Inventory” are expected to be published in 2011. Imported and manufactured substances or mixtures listed in the Inventory will be required to provide SDSs and label in line with China GHS criteria. Therefore only after the publication of this legislation can GHS be implemented in practice in China.
Other GHS Activities by Other Relevant Ministerial Departments
The “Regional Workshop on Chemical Hazard Communication and GHS Implementation for Countries of East and Central Asia”, was held in September 2010 in Beijing, China. The purpose of the workshop was to discuss experiences with chemical hazard communication in East and Central Asia and consider concrete measures related to GHS implementation, in particular the coordination of implementation among regional trading partners.
Difficulties in Implementing China GHS
As previously mentioned, almost 10 departments are involved in implementing China GHS. A coordinated approach among the various departments is yet to be formulated. In addition, the relevant chemical management regulations still need to be refined to accommodate GHS.
Furthermore, in order to implement GHS in the whole country apart from the SDS and label regulations, several other relevant administrative regulations and national standards require amendments to cover the workplace, transportation, consumer product safety, etc.
For example:“Law of the People's Republic of China on Prevention and Control of Occupational Diseases” , “Regulations of the People's Republic of China on Monitored and Controlled Chemicals” (promulgated by the State Council in 1995), “Regulations of the People's Republic of China on the Control of Agricultural Chemicals”(Promulgated by the State Council in 1997, Amended in 2001), “Regulation on Work Safety Licenses” (Promulgated by the State Council in Jan. 2004), “Regulations on Labor Protection in Workplaces Where Toxic Substances Are Used” (Promulgated by the State Council in April 2002), “Regulations for Administration of Precursors and Chemicals used in Production of Narcotic Drugs and Psychotropic Substances” (Promulgated by the State Council in May 2005), “Measures for the Administration of Hazardous Chemicals Operation Permit” (published in 2012 as SAWS Order) etc.
Although the Chinese authorities have made major developments in implementing GHS, a lot more work is required for full implementation of China GHS.
