- The GHS system proposes harmonised system for labelling of hazardous chemicals and is applied to many different classifications of chemicals, including pesticides.
- The GHS system will, if implemented correctly, provide a common basis for labelling and data sheets that will greatly facilitate safety during handling, transportation and usage that will contribute to human and environmental safety.
- The GHS process must be science and risk based and not undermine existing regulations in place.
Governments (regulators) and industry should work together when label classification is considered to facilitate harmonisation and alleviate potential trade barriers.
The Global Harmonised System of Classification and Labelling of Chemicals (GHS) addresses classification of chemicals by types of hazard and proposes harmonised hazard communication elements. These communication elements include for examples the labels (pictograms and others) on pesticide products, and hazard data sheets that accompany bulk chemical shipments. The GHS also provides a basis for harmonisation of rules and regulations on chemicals at national, regional and worldwide level.
The Global Harmonised System of Classification and Labelling of Chemicals, GHS, dates back to 1989 when the International Labour Organisation, ILO adopted a convention on Safety in the Use of Chemicals at Work. Adoption of this convention required a country to have a system for hazard classification and labelling. Following substantial review of existing national systems, endorsement through the UN Conference on the Environment and Development, Rio 1992, Chapter 19, Agenda 21, the UN Committee of Experts for the Transportation of Dangerous Goods and the Globally Harmonised Systems of Classification and labelling of Chemicals adopted GHS in December 2002 with a desired implementation by 2008.
The objective with GHS is to develop a single, globally harmonised system to address classification of chemicals, labels, and safety data sheets. It aims at ensuring that information on physical hazards and toxicity from chemicals be available in order to enhance the protection of human health and the environment during the handling, transport and use of these chemicals. The GHS also provides a basis for harmonisation of rules and regulations on chemicals at national, regional and worldwide level, an important factor also for trade facilitation.
The GHS system was approved by the UN in July 2003. At the moment regulatory authorities in the different countries are working on the implementation of the system. They work in close contact with the UN-Subcommittee of Experts on the Globally Harmonised System of Classification and Labelling of Chemicals.
The technical work on the various issues is coordinated by “The Interorganization Programme for the Sound Management of Chemicals (IOMC). International Organsations such as OECD, ILO and UNECE work with IOMC on the various technical issues such as physical hazards, health & environmental hazards as well as risk communication.
During the development process the following principles of harmonisation provided the basic working framework for GHS implementation.
- Protection will not be reduced
- To be based on existing systems
- Based on their intrinsic hazards, all chemicals will be covered
All existing systems to change to accommodate the new system.
Why does GHS exist?
The objective of the system is to guarantee and improve operator’s safety dealing with chemicals as well as the protection of the environment. Chemical crop protection products are used all over the world by people of all sorts of languages, literacy rates and education levels. Through a concise, clear and harmonised labelling and risk communication system they all can access relevant safety information. Aside from the safety aspect of labelling of CPPs there is also the matter of international trade.
At present, multiple labels and safety data sheets are required for the same chemical product on the market in multiple markets. Consequently this leads to higher production costs that need to be paid by the final user. Smaller manufacturers may not be able to bring products to market for this reason. Through a harmonised categorisation of hazards the sound management of chemicals is secured.
Classification Criteria and Risk Communication
GHS includes harmonized criteria for classifying substances and mixtures depending on their health, environmental and physical hazard. It also includes hazard communication elements as well as labelling and safety data sheets. GHS does not involve uniform test methods or any supplementary testing to address adverse health outcomes. GHS does not intend to harmonise risk management/ assessment procedures.
Risk Communication
For each hazard category various labelling elements are allocated. They use signal words such as “Danger” or “ Warning”. Precautionary phrase are not yet harmonised and GHS seeks to address this.
GHS implementation
GHS is a non-mandatory UN treaty but it is expected that it will be implemented up to a certain degree by the developed countries by end of 2008. Some countries such New Zealand have incorporated GHS into their new chemical legislation. For WHO and EU it is expected to be implemented by 2005.
The Plant Science Industry and GHS
For Government regulatory authorities to implement GHS effectively, CropLife International believes that the following measures should apply:
- The implementation of GHS allows a designated authority to use discretionary powers when classifying a product.
- CropLife International strongly encourages all governments to work with their appropriate pesticide regulatory authority to ensure continuous consistency in product labelling.
- When substantial classification changes are proposed for a product label the authority should consider the value of such changes to the end user and as such consider the risk and benefit in adopting the changes.
- Where substantial changes to the existing label classification are recommended then appropriate communication needs to be made to all end users and existing products relabelled.
- When test data are available they should always be used in preference to that extrapolated from other scientific sources.
- When similar, but non-identical products are considered, governments should establish preferably through the use of FAO Specification that the products could be adjudged as similar before applying classification criteria.
- CropLife encourages all Governments to work closely with neighbouring countries to ensure consistency in assessment so as not to impede recognised and regulated trade in CPP.
- Whilst safety is a cross cutting issue it is important to recognise and maintain the rights of registrants to their intellectual data and property, submitted in support of classification and labelling
CropLife International supports the smooth introduction of GHS and the development of appropriate capacity to achieve sound science based evaluations, classification and labelling.