Globally Harmonized System of Classification and Labelling of Chemicals Update for PPDC October 7-8, 2008

The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is a common, consistent approach to classifying chemicals according to their hazards and communicating hazard information on labels and safety data sheets.

It includes harmonized classification (hazard identification) criteria for physical hazards, health hazards, and aquatic toxicity; standard label elements associated with each hazard class and category of severity within that hazard class (pictograms, the signal words danger or warning, and hazard statements, such as “fatal if swallowed”); standard format and contents for safety data sheets, used primarily in the work place; and guidance on other label elements that are considered necessary to be consistent with the GHS, notably, precautionary statements and product and supplier identifiers.

The key goals of the GHS are to enhance health and environmental protection by providing clear and consistent information to people who are exposed to chemicals, and to reduce barriers to trade that result from the need to comply with multiple, inconsistent classification and labeling requirements imposed by different countries. (In some countries, including the U.S., domestic regulatory requirements are not harmonized.)

The U.S. chaired the group that managed the overall development of the system, which was adopted by a consensus involving governments, industry, and other stakeholders, after over a decade of complex negotiations.

In 2004, EPA solicited public comments on a White Paper outlining initial thinking on how the GHS might be applied to pesticide labels. Essentially, the paper contemplated adoption of the GHS for those hazards that we now require to be labeled based on hazard: physical hazards, acute health hazards, and acute aquatic toxicity.

EPA has been focusing its efforts on addressing the stakeholder concerns raised in public comments and in an October 2006 public workshop, and on improving communication and outreach through an upgraded web site and other means.

Pilot activities have been initiated (on a voluntary basis). We have not initiated rule-making activities or included GHS in the EPA regulatory agenda to date.

The Occupational Safety and Health Administration published an Advance Notice of Proposed Rule-Making in late 2006. The public comments have been analyzed and OSHA has placed a high priority on issuing a Proposed Rule this year to apply GHS to workplace labels and safety data sheets.

DOT has essentially completed the rule-making changes required for GHS implementation, except for aquatic toxicity. Currently, they are in a “voluntary compliance” period; mandatory compliance with the GHS changes takes effect in January 2011.

Other countries have also moved toward implementation. Notably, the European Union has issued a final regulation that was approved by the European Parliament in September. The regulation provides for implementation of the GHS for all chemicals, including pesticides, by December 2010 for substances and June 2015 for mixtures.

EPA coordinates positions for international GHS discussions with other key agencies, including OSHA, DOT, CPSC and the State Department. One of our goals is to minimize changes to the GHS text, to avoid its becoming a “moving target.”

The interagency group is tentatively planning a public meeting on November 18, in preparation for the December 2008 international meetings. (We will notify stakeholders of the details as soon as they become available.) Among the issues for discussion is proposed work to add terrestrial toxicity to the GHS.