Introduction to the Implementation of GHS in Asia Pacific Countries

Over the last several years there has been a global focus on development of stronger more scientific regulations on chemical safety management. Over the years, many countries and organizations have enacted laws, regulations and standards for classification and labelling of chemicals, but there are differences in terms of classification standards and labeling patterns in each region. The inconsistent classification standards result in different hazardous classification and labelling information in different countries for the same product, which brings great potential risks to the people who use chemicals. Therefore, it is necessary to establish a global uniform classification and labelling system in order to uniformly understand chemical hazards worldwide, to improve the awareness of chemical protection, and to reduce the cost of international trade. This article focuses on the relevant regulations and standards of hazardous chemicals in the Asia Pacific countries, to help enterprises deal with compliance work, avoid technical barriers in trade, and reduce their compliance costs and compliance risks.

1. United Nations GHS generation and main content 

In 1992, the United Nations Conference on Environment and Development (UNCED) and the International Forum on Chemical Safety (IFCS) passed a resolution to recommend countries conducting international coordination work of classification and label of chemicals, in order to reduce the harm to human and environment caused by chemicals, and simultaneously to reduce the compliance cost of cross-border trade in different countries. Therefore, the International Labor Organization (ILO), the organization for economic cooperation and development (OECD), the United Nations Committee of Experts on the Transport of Dangerous Goods (UNCETDG) jointly drafted Globally Harmonized System of Classification and Labelling of Chemicals, (short for GHS). The United Nations passed and officially announced this systematic document in 2003, and required countries to implement GHS before 2008. The United Nations Committee of experts on GHS regularly revise and update the GHS system every two years. The latest edition is the revised seventh version of 2017.

The United Nations GHS system mainly includes the unified classification standards of chemical hazards and the unified chemical hazards communication tools:

• The unified classification criteria of hazards: 17 physical hazards (the sixth revised version of the GHS system added "desensitized explosives"), 10 health hazards and 2 environmental hazards. 

• The unified chemical hazards communication tools: label and Safety Data Sheet. (SDS). 

2.  Progress in implementation of GHS in Asia Pacific countries

Since released and implemented, the GHS system has been used to instruct countries to develop chemical management strategies. More than 60 countries and regions around the world have carried out the implementation of the GHS system, including the most of the Asia Pacific regions except Kampuchea, Brunei, Laos, Burma, etc. According to our experience, the typical patterns of localized GHS implementation in different countries are as follows:

• Release of independent regulations or revision of existing regulations for introduction of GHS system, publication of relevant SDS/ label / classification standards;

• The applicable scope of chemical inventories, or the implementation of all hazardous chemicals;

• Phased-in implementation, set up of transitional period for gradual implementation;

• The voluntary adoption of UNGHS version and specific hazard categories by Authorities.

GHS implementation in the Asia Pacific reagions are summarized as follows:

Table 1 general situations of GHS implementation in Asia Pacific regions

According to table 1, Apart from the fact that the Department of Environment and Natural Resources in Philippines has not yet fully implemented GHS for the control of toxic substances, until now, many countries in the Asia Pacific regions have begun to implement GHS. The GHS system concerns the hazards of chemicals, and is expected to inform all potential individuals exposed to chemicals through the use of SDS and label, thus, chemical production, transportation, storage, usage and waste disposal throughout the whole life cycle are suitable for GHS system. GHS system can be adopted to determine the hazard classification standards, SDS or label requests. Although UN GHS is the global gold standard, each country can voluntarily implement its own GHS. It is important to understand that each country has its own characteristics of GHS. There can be differences in the implementation area, implementation time, implementation contents, classifications of building blocks, SDS and labeling requirements.

2.1 Hazard classification

Different versions of UNGHS can be adopted by the countries of the Asia Pacific regions in accordance with the voluntary principle, such as China, Singapore, Indonesia, Japan and South Korea, adopted fourth revision, and Thailand, Philippines, Australia, Malaysia, New Zealand adopted the third revision. Therefore, these countries have issued their respective classification criteria for chemical hazards on the basis of the UNGHS. In addition, some countries have published their official catalogues and Classification Lists, for example:

• Chinese Mainland：《Inventory of Hazardous Chemicals（2015 version）》Implementation Guidance - the information table of Classification；

• Taiwan, China：OSHA GHS Classification List；

• Korea：MOE Classification List；MOEL Classification List；

• Japan：NITE Classification List；

• Thailand：DIW Classification List;

• Malaysia：EHS/CMR Classification List；

• Australia：Hazardous Chemical Information System (HCIS)；

• New Zealand：the Chemical Classification Information Database (CCID)；

Due to the adoption of the different revised editions of the UNGHS and different data collections, one substance can have different hazard classifications in different countries. When the same product is exported to different countries, it is necessary to comply with the requirements of the regulations in different destinations.

2.2 SDS and label

The Safety Data Sheet and label are two important tools under the GHS system to communicate hazardous information in the supply chain.  The label is a combination of written texts and pictograms indicating all hazards and general safety precautions of a chemical product which can be affixed, printed or attached to the outer packaging or on the container of the chemical product, including chemical identification, pictograms, signal words, hazard statements, precautionary statements, emergency phone numbers, supplier identification and prompts to consult reference material etc.

Although the information provided by the label is relatively limited, its main parts such as pictograms, hazard statements and precautionary statements, play a significant role in safety warning; and the emergency phone numbers and supplier information directly provide contact personnel with information consultation and access channel.  

• The Safety Data Sheet for Chemical Products (SDS) is a tool for suppliers of chemical products to transfer basic hazardous information of chemicals to their downstream recipients. The SDS provides information on chemical products (substances or mixtures) in the aspects of safety, health, environmental protection, etc. and recommends protective measures and response measures in case of emergencies, mainly including identification of the chemicals and the company, hazards identification, composition/information on ingredients, first aid measures, fire-fighting measures, accidental release measures, handling and storage, exposure controls/personal protection, physical and chemical properties, stability and reactivity, toxicological information, ecological information, disposal considerations, transport information, regulatory information, other information etc. (16 header format)

• Compared with label, SDS contains more information. The applications of SDS penetrate throughout the whole life cycle of a chemical and include information on production, operation, sales, management, and transportation. Enterprises should provide compliant SDS for the registration of hazardous chemicals, import and export inspection, customs declaration, shipping, air transportation, demand of domestic and foreign downstream customers, internal safety public notice and other circumstances.

SDS and label provide relevant information such as operation, storage, transportation and usage for chemicals, provide the necessary protective measures for safety, health and environmental protection and help reduce the risk of exposure to chemical population, so its necessity and importance are self-evident. But countries in the Asia Pacific regions have released their own standards, in addition to the requirements of the language, the content format has different requirements, such as emergency telephone number, label output format and size, component confidentiality requirements, the content requirements of titles and sub-titles, regulatory information and so on in SDS.

Table 2 the standard of GHS classification/SDS/label in Asia Pacific countries

3. Summary

The implementation of the GHS system is designed to improve at a global level: chemical safety protection, reduce the harm of chemicals to human health and environment, facilitate the trade of chemicals, and promote the healthy and sustainable development of petrochemical industry.

Based on multi-dimensional experience in global chemical compliance, Reach24H reminds enterprises that although all countries in the Asia-Pacific regions have fully implemented GHS in accordance with the requirements of the United Nations, there are still many differences in their own GHS systems compared to UNGHS and each country constantly updates their laws and regulations.

Enterprises must track and collect the relevant national laws and regulations in time, and actively accept the relevant training. For products, enterprises should collect as much information as possible, sort and confirm their respective hazard classification, ensure that SDSs and labels are completed in accordance with national standards, establish chemical safety management files and timely deliver information to downstream customers. At the same time, it should be noted that there are differences in regulatory requirements between different countries and different authorities. Under complex regulatory frameworks, there may be various obligations to ensure the implementation of GHS, usually including chemical registration, notification, business license, and customs legal review and so on. In the process of the import and export of products, enterprises shall pay close attention to the regulatory requirements of the corresponding countries and deal with compliance to ensure smooth trade.