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Thailand GHS: 100% Component Disclosure could be the Hurdle in Preparing SDS

Thailand GHS, which adopts the UN GHS 3rd revision, has been implemented for single substance (used as industrial chemicals) since Mar 13th, 2013. Mixtures have to comply with GHS requirements by Mar 13, 2017. Currently, DIW (Depart. of Industrial Works) is the first and only department in Thailand to implement GHS. Compare your chemicals against those listed in ANNEX 5 to make sure whether your company should be affected or not.

One of the unique features incorporated in the Thailand hazardous chemicals management system is the well-known 100% composition declaration requirement. For industrial usage chemicals, 100% composition has to be declared to DIW for evaluation. Besides the confidentiality concern shared by companies, this requirement brings unwanted burden on the SDS management work due to the fact the authority (especially the Thai Customs) would inspect the concentration ranges provided on SDS, to make sure that the information are consistent with those on the 100% concentration declared by the industry. Imagine tons of work has to be done updating company’s SDS to comply with Thailand GHS, which is especially true for manufacturers of products with varying formulation. Those who are well informed of the 100% concentration disclosure requirement are still quite conflicted with various concerns, the one which seems to be a hanging dagger is that the company has to take its own risk if they decided that their chemicals are not hazardous and therefore prefer to keep the non-hazardous component information to themselves. (More details about the 100% concentration disclosure, please click here to access our Thailand webinar materials)

Besides the 100% concentration disclosure requirement, other worth mentioning points are listed below for your reference:

  1. For chemicals with no less than 98% component concentration, the chemicals should be handled as pure substances;

  2. To fill in the section 1.2 supplier information on the SDS, two scenarios have to be taken into account: 

  • If the manufacturer of the chemicals prepares the SDS, the manufacturer’s information has to be provided in the section 1.2 of the SDS;

  • If the manufacturer of the chemicals authorize some other parties to prepare the SDS, information of the SDS preparation party should be provided on the section 1.2 accordingly.

Other departments such as FDA (Food and Drug Administration) which regulates household and agriculture chemicals, DOLD (Depart. of Livestock Development) and DOA (Depart. of Agriculture) will soon follow the suit and it could be expected that GHS will be adopted in a much broader sense in Thailand in the visible future. (ChemLinked News)

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