GHS implementation is relatively simple when only one country is involved. American manufacturers and dealers of chemicals deemed hazardous in any degree must have a safety data sheet that complies with OSHA guidelines. For those companies involved in cross border trade, it becomes much more difficult unless they have professional help in compilation of SDS to various standards.
The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) aims to ensure greater safety during production, storage, transport, handling and use of chemicals. Further, countries are free to implement any set of recommendations using the building block approach and they are responsible for implementation within their jurisdiction. This freedom also creates issues of standardization and uniformity.
The situation is complicated by implementation of various GHS Editions by various countries. First released in 2005 the GHS has undergone five revisions with the last, 6th edition of 2015 yet to be implemented anywhere. East and West European block, Sweden, UK, Uruguay, Zambia and Abu Dhabi among other countries have adopted GHS Edition 4. Argentina, Canada and Mexica have opted for GHS edition 5. Australia, Korea, Malaysia, New Zealand, Thailand, Vietnam, Turkey, Serbia, Switzerland and the US have opted for edition 3 while Ecuador and South Africa still follow the 2nd edition. The EU has REACH and CLP and is likely to adopt the 6th revision. Each country may incorporate its own set of rules as well. As can be seen, this situation complicates matters for manufacturers, dealers and exporters of chemicals. Apart from complying with local GHS for classification, they must also comply with the country they deal with.
As an example, USA and Canada have clarified how matters stand as regards GHS classification and compliances. It has been agreed that only one safety data sheet and label would be acceptable in both countries as a way to keep workers protected. There are minor changes. One is that the SDS and labels must be in English and French. The supplier identifier must appear on the label and the SDS for Canadian markets and the label must also disclose HNOC hazard element. What is superfluous for one country will be acceptable in the other provided their basic requirements are met. This does simplify matters but American exporters do need to have bilingual documents that do not lose anything in the translation while keeping in mind specific idiosyncrasies of local laws of Canada. It is likely there will be more such bilateral collaborations between countries to truly harmonize GHS classification and documentation.
The current situation for American chemical companies engaged in cross border trade is that they must have OSHA compliant GHS SDS and must also have a different SDS complying with the country with which they trade. Translation is just one aspect; the company entrusted with the GHS compliance documentation must also understand the GHS edition in force and the specifics of each country’s laws. Expertise and experience of a company engaged in this field come into play and greatly help manufacturers. The consignment moves rapidly from source to destination with safety for everyone in the chain and no delays due to any compliance discrepancy.
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