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UN to pilot global list of GHS classified substances

A UN expert committee is moving ahead with its work to develop a global list of chemicals classified according to the UN’s Globally Harmonized System (GHS) for chemicals classification and labelling. Emma Chynoweth reports on this and other issues discussed at the committee’s most recent session.

The Sub-Committee of Experts on the GHS, a body established by the UN Economic Commission for Europe (Unece), hopes to reach decisions on updating the GHS, including improvement of its annexes, by the end of 2012. The subcommittee, which held its most recent meeting on 7-9 December, is also examining hazard communications and implementation issues, developing guidance on the application of the GHS criteria, and planning further capacity building projects.

Pilot group of chemicals

Comparison of different bodies’ substance classifications conducted according to the GHS sometimes shows inconsistent results. To address this, a set of guiding principles (see box) for how the development of a list of chemicals classified in accordance with the GHS should proceed, was agreed by a subcommittee “informal group”. It also agreed to move forward with a pilot group of chemicals. It is understood that the substances to be considered pose serious health, physical and/or environmental concerns and are among the most commonly used and transported worldwide. The group is also looking at which end-points need to be considered and how classifications might be updated. The work, which is being led by the US, will also review existing chemical lists, such as those published in the EU and Japan, and compare them to the guiding principles (CW 19 July 2011).

Although some member countries are keen to develop such a list, the work is also the most challenging issue before the subcommittee, says subcommittee chair Kimberley Headrick, who works in the GHS implementation division of Canada’s federal health ministry, Health Canada. “A list of classified chemicals has been identified by a number of developing countries and countries with economies in transition as assisting them with their GHS implementation,” she says. But the list’s development is a complex process that will require careful deliberation, and there is no guarantee it will be ready for adoption by the end of this year, as scheduled. One issue, says Marie-Hélène Leroy of the French Chemical Industry Federation, who was representing the European Chemical industry Council (Cefic) at the session, is that it is not always clear how the classifications for chemicals on existing lists were derived, or on which data sets they are based.

The Purple Book

Activities are also under way to improve the text of the GHS “Purple Book”, including an editorial revision to chapters 3.2 on skin corrosion/irritation and 3.3 on serious eye damage/eye irritation, and the improvement of annexes 1, 2 and 3. Progress was made in both areas, says Ms Headrick.

Looking at the specific work areas, the following progress was made at the December meeting:

• Physical hazards

On the subject of self reactive substances and organic peroxides, a decision was taken to pursue an option designed to provide greater consistency between transport regulations and the GHS. A new proposal will be presented at the next meeting of the subcommittee on 4-6 July.

The sub-committee agreed with that on the transport of dangerous goods that work should continue on the testing and classification of water-reactive substances, and on the improvement and standardisation of the relevant test method to improve the determination of the gas evolution rate and increase its precision and sensitivity. The US has secured funds for a research project to review existing procedures and classification criteria for water reactive substances.

The group on dust explosion hazards presented its work in developing the option of addressing dust explosion hazards in the safety data sheet. It is tackling the generation of information to be included in Annex 4 to the GHS and, as a next step, will develop a possible template to collect the information.

Little progress was made on the supply and use of desensitised explosives because of a lack of data; however, a number of meetings are coming up, notably one of the working group on explosives at the end of June. Similarly, a revised proposal will be considered at the next session on substances and mixtures with explosive properties which are exempted from classification as explosives.

• Health hazards

In addition to the amendments proposed to chapters 3.2 and 3.3 of the Purple Book, the sessions discussed improvements to annexes 1, 2 and 3. An informal group on the rationalisation of precautionary statements reported on its work, which is looking at the development of further guidance to aid the selection of appropriate precautionary statements for use labels, potentially including an order of precedence for individual statements. The group will submit proposals to the subcommittee in the future. The group will also continue to develop proposals to improve and rationalise the precautionary statements for physical hazards.

It also had an initial discussion of various suggestions to restructure annexes 1, 2 and 3 that are designed to improve the way in which information is presented. Most of the group were in favour of exploring a number of options in more detail, although some wanted to consult with their stakeholders on how the annexes were used before the proposals were taken further.

The group is also working to address a number of editorial errors relating to precautionary and hazard statements that have been identified in annexes 1, 2 and 3. It will prepare a working document containing proposals to correct these errors.

• Hazard communication issues

Some progress was achieved in the area of labelling of small packages. Based on the general principles of small packaging agreed as part of the 3rd revision of the Purple Book, five examples are being developed to illustrate the principles’ application: a cardboard box containing five ampoules; a styrofoam box filled with 25 glass ampoules; a cleaning pen with blister; cleaning pads in a dispenser box; and a box containing ampoules and reagents

Cefic is leading the work group. Ms Leroy says the meeting agreed a common template on which to base the examples and she hopes the examples will be ready for possible adoption by the end of the year. She says there is a lot of interest from industry, and from the European Commission which may consider adapting the CLP Regulation if the examples are incorporated into the Purple Book. However guidance on the application of the guiding principles of small packaging would be premature as there is no agreed definition of a small package.

Ms Leroy says industry is also closely watching the revision of section 9 of safety data sheets (SDS), which is being led by Germany. The work group has decided to develop guidance on the information to be included in section 9, and is revising the list of physico-chemical properties that must be included. From an industry perspective, Ms Leroy says, the revision is important as it addresses the “organisation” of chemical properties along with the need for information, the amount of information and the relevance of information.

Progress was also reported in the area of hazard communication in the supply chain for substances and mixtures classified as corrosive to metals.

GHS implementation

Besides discussing progress on the work to develop a list of chemicals classified on GHS criteria, a number of practical classification issues were discussed during the subcommittee session.

To improve consistency between the material safety data sheet Resolutions of the International Maritime Organization (IMO), the work group agreed on an option to add an appendix to Annex 4 on the guidance on the preparation of safety data sheets, and include information from IMO that goes beyond GHS in the appropriate GHS sections. It was also proposed to add a new paragraph to chapter 1.5 of the Purple Book referencing IMO Resolution (MSC.286.86) which provides recommendations for material safety data sheets (MSDS) for oil cargo and oil fuel.

There was discussion about clarifying the use of the terms “no data available”, “not applicable”, and “not classified”. While there was some support for this proposal, some experts said areas of the text required clarification and agreed to propose amendments to the text for the next session.

The meeting heard about GHS implementation in various countries and regions including Brazil, China, the EU, US and Zambia, and cooperation with other bodies or international organisations was also discussed. As well as noting the positive work of the joint Transport of Dangerous Goods (TDG)/GHS correspondence group on corrosivity criteria, the meeting heard about TDG subcommittee’s progress in areas including the classification of plastics evolving flammable vapours, and issues relating to the classification of fireworks. Information was also provided about preparations for the first evaluation of progress on implementation of Saicm, the UN’s Strategic Approach to International Chemicals Management (see pages 1-5 ).

Capacity building

The meeting also heard about GHS capacity building efforts, including UN programme activities in Jamaica, supported by the Swiss Government, in addition to national projects in Barbados, Gambia, and Zambia. New projects in Chile, Congo, Bolivia, Colombia, Guatemala, Mexico, Kyrgyzstan and Tajikistan are expected to start in Q1 2012, supported by the Saicm quick start programme trust fund. The EU has supported other projects in China, Indonesia, Malaysia, Philippines and Thailand.

In September and November last year twelve training sessions were organised in five countries belonging to the Association of Southeast Asian Nations (Asean), and in China, during which more than 1,000 participants received training.

In May 2012 Moldova intends to host a regional GHS workshop for central and east European countries and in November a sub-regional conference for the Caribbean region is planned in Jamaica.

BOX: Guiding principles for development of a global list of classified chemicals

• the process for developing and maintaining global list must be clear and transparent, follow the principles of the GHS. And include opportunities for stakeholders to provide input as well as a mechanism for expert review and conflict resolution;
• all GHS hazard categories and classes must be included in the list;
• only substances will be included;
• all substances must be accurately identifiable and described for each entry (eg including impurities and CAS numbers);
• the data sets forming the basis for the chemical classification must be included with the classification. The source of the information must also be readily available and publicly accessible;
• the list will be non-binding. As with the GHS itself, countries will have the option to make the list binding if they adopt it through their legislative or regulatory processes; and
• classifications should be done using the same data.

BOX: A view from inside Unece

Speaking at Chemical Watch’s GHS webinar in December, Rosa Garcia Couto, secretary of the GHS subcommittee, said that one of the main achievements of its implementation is that implementing countries are all using the same criteria for the first time.

Because there is a desire to gain experience with implementation before considering changes, the criteria are likely to remain stable, she said. The process for proposing amendments to the criteria can be a long one – sometimes longer than the biennium work programme. Only proposals addressing global concerns are likely to be considered by the subcommittee and any amendment proposals would need to be well justified and channelled through the subcommittee.

The building block approach used under the GHS, which allows implementers to select some elements of the programme, has been criticised for running counter to harmonisation, she said. But such an approach was critical to the programme’s success because it allows countries to choose the hazard classes and categories which best suit the needs of each sector – such as transport, workplace or consumers – in that country. Although it was developed to accommodate the specific needs of each sector, the GHS encourages countries to implement the same set of categories for a given sector.

From information officially reported to Unece, Ms Couto said, some common approaches can be identified. Most countries are using the building block approach; they are also ensuring the previous level of protection is at least maintained if not improved; they are staying as close as possible to the GHS in terms of format and terminology; they are establishing deadlines that are well aligned; and they are updating national or regional legislation to ensure it follows GHS revisions.

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