[ID] => 7470
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[post_date] => 2017-01-07 11:54:40
[post_date_gmt] => 2017-01-07 11:54:40
[post_content] => The UN Sub-committee of Experts on the Globally Harmonised System of Classification and Labelling of Chemicals (GHS) held its 31st session in Geneva from 5 to 8 July 2016. The meeting was chaired by Maureen Ruskin (US) with Robin Foster (UK) as vice-chair. It was attended by experts from 22 countries, an observer from Switzerland and representatives from the International Maritime Organisation (IMO), the UN Institute for Training and Research (Unitar), the European Union and 19 non-governmental organisations.
The meeting took place immediately after a joint session of experts from the GHS Sub-committee and its sister body, the Sub-committee of experts on the Transport of Dangerous Goods (TDG). The first major agenda item was to review the work of the TDG Sub-committee in areas of relevance to GHS.
The TDG Sub-committee’s Working Group on Explosives had identified that the physical hazards posed by some substances can vary during their lifecycle and may depend on parameters other than those substances’ intrinsic properties. This is certainly true of explosives, the risks of which during transport are influenced by factors such as quantity, configuration, packaging and confinement, but it is equally true of other substances.
The GHS Sub-committee did not feel comfortable with introducing a very general statement to limit the scope for physical hazards in Part 1 of the GHS. Scope limitations might need to be addressed on a case-by-case basis; guidance could be developed for specific aspects such as packaging configurations. Any proposals on this topic should be forwarded to both Sub-committees.
The GHS Sub-committee was pleased to hear that their TDG counterparts had tentatively agreed on the proposal for revision of Chapter 2.8 of the Model Regulations, which achieves better alignment of corrosivity definitions between the Model Regulations and the GHS. It was hoped that this issue could finally be settled at the December 2016 session.
The adoption of Test N.1 for readily combustible solids was also expected to be confirmed by the TDG Sub-committee at the December session. The GHS experts noted that this will require amendment of 188.8.131.52 of GHS as well.
The US presented a lengthy paper summarising the outcome of the informal correspondence group on practical classification issues; for the most part the proposals contained in the paper were adopted by the Sub-committee. These involved the deletion of some definitions in Chapter 1.2, the amendment of Table 3.1.1 with acute toxicity estimate vales and the addition of a new sentence at the end of 184.108.40.206:
In cases where data from human experience (i.e. occupational data, data from accident databases, epidemiology studies, clinical reports) is also available, it should be considered in a weight of evidence approach consistent with the principles described in section 220.127.116.11.9.
The correspondence group did not feel it necessary to include a definition for the term “Substances of unknown or variable compositions, complex reaction products and biological materials (UVCBs)” in the GHS but thought there might be value in clarifying the terms “complex substance” and “complex mixture”.
The correspondence group has been asked to consider the possible amendment of the criteria for the hazard category “effects on or via lactation” as an informal paper from the US did not receive support. It was stressed that a new hazard statement should only be suggested if it was considered to bring added value.
The International Paint and Printing Ink Council (IPPIC) advised that it would submit a paper on the viscosity criterion for classification of mixtures for aspiration hazards at the next session. The IMO is already working on this subject and was to submit a progress report at the December meeting.
A joint paper from the Australian Explosives Industry and Safety Group Incorporated (AEISG) and the Sporting Arms and Ammunition Manufacturers’ Institute (SAAMI) sought to clarify the classification criteria for desensitised explosives in the GHS. With some amendment this was accepted. The text at the start of 18.104.22.168 will now read:
Any explosive while in a desensitized state shall be considered in this class unless, in that state:
The following sub-paragraphs and Note 1 have been subject to minor editorial amendments.
An informal paper from the Europe Industrial Gases Association (EIGA) and the European Chemical Industry Council (Cefic) suggested there is a need in GHS for a new chapter covering chemicals under pressure, since the TDG Sub-committee has adopted provisions for such materials in the Model Regulations.
There was some support for the proposal but it was felt more information was needed. Some experts thought it might be possible to accommodate these products in existing hazard classes. The two associations promised to provide more information and invited those interested to cooperate with them to draw up a sensible solution.
A joint paper from the Netherlands and the UK addressed alternatives to animal testing for the classification of health hazards. The paper was well received and the Sub-committee asked the two countries to lead an informal correspondence group on the issue.
The Swedish expert reported on a meeting of the informal group looking at the revision of Chapter 2.1. This meeting had examined a proposal for labelling of explosives that included introducing categories for classification and generalisation of the hazard communication elements. More work will be undertaken before a proposal is made to the Sub-committee.
The informal correspondence group on labelling of small packagings had reached agreement on an example for fold-out labels; this was to be presented in a formal document at the December meeting. The group will continue working on the development of examples for sets or kits.
Sweden returned with a formal proposal to add ‘hearing protection’ to the list of personal protective equipment contained in precautionary statement P280. This was agreed without demur. There are some consequential amendments in other parts of the GHS text.
The EU asked for clarification on the terms “medical advice/attention” in the precautionary statements. It would be helpful to understand exactly what is meant and the difference between ‘advice’ and ‘attention’ when translating the precautionary statements. Some experts favoured deferring this question to the next biennium but the Secretariat considered it an urgent matter.
The Sub-committee could not immediately find a rationale for the distinction during the session and experts were invited to provide comments so that a proposal could be readied for the December session.
The UK reported on progress being made by the informal correspondence group on the improvement of annexes 1 to 3 and said that a formal proposal would be made at the December session.
Belgium and Japan submitted a paper on behalf of the informal working group on classification criteria for flammable gases. This group has been looking at implementation of the agreed sub-categorisation of current category 1 into category 1A and 1B, with category 1B addressing gases with a lower flammability limit greater than 6 per cent or a fundamental burning velocity of less than 10 cm/s. The group had agreed the hazard communication elements for 1B flammable gases and proposed to submit a final paper following further discussion prior to the December session.
The US expert provided a report on the progress of the pilot classification project designed to verify the development of a list of chemicals classified in accordance with the GHS. It is expected that the Organisation for Economic Cooperation and Development (OECD) will submit its report and final draft classifications soon.
The work seems to be supporting the GHS approach and the project will continue into the next biennium. The experts are aware of the potential for classifications adopted by the GHS might have implications for regulations or recommendations prepared by other bodies, not least the TDG Sub-committee. One likely change will affect dicyclopentadiene, which might warrant a reclassification in transport regulations, from flammable liquid packing group III without subsidiary hazard, to toxic by inhalation packing group II with subsidiary hazard of flammable liquid. This would have considerable downstream effects.
The Sub-committee noted that, following the alignment of the Workplace Hazardous Materials Information System (WHMIS) with the GHS in 2015, Canada was developing technical guidance for its implementation. This was expected to be completed by the end of 2016.
The Sub-committee noted that the 5th revised edition of the GHS has been implemented in the EU through the 8th adaptation to technical progress (ATP) to the Classification, Labelling and Packaging Regulation (CLP Regulation). The new rules entered into force on 4 July 2016 and will become mandatory from 1 February 2018. The list of “harmonised classification and labelling of hazardous substances” contained in Annex VI to the CLP Regulation has also been updated and became applicable on 1 January 2017.
Argentina’s Ministry of Labour, Employment and Social Security approved the implementation of GHS in workplace safety regulations in 2015; the necessary provisions were being phased in to take effect between April 2016 and January 2017.
Unitar informed the Sub-committee that a government decree to implement the GHS had been adopted in Kyrgyzstan and that Tajikistan had agreed on actions to mainstream the GHS into national legislation.
The Responsible Packaging Management Association of Southern Africa (RPMASA) advised that a new national standard based on the fourth revised edition of GHS was expected to be released before the end of 2016 and that a revision to this standard for alignment with the 6th revised edition of the GHS was foreseen.
The Sub-committee also heard that a number of capacity-building and awareness raising projects had taken place during the first half of 2016 in Bolivia, Burundi, Chile, Colombia, Democratic Republic of Congo, Guatemala, Haiti, Mexico, Tunisia and South Africa.
The 32nd session of the GHS Sub-committee was held in Geneva from 7 to 9 December 2016. A report on this meeting will be included in a forthcoming issue of HCB Monthly.
[post_title] => GHS: Purple patch
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GHS: Purple patch
// By Peter Mackay on 7 Jan 2017
If one thing will be remembered from the current biennium's work on GHS it is likely to be the greater degree of cooperation with the TDG Sub-committee
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