As an additional section of Enhesa’s GHS tracking service, Enhesa has added information related to barriers to chemical shipments presented by countries that have not yet implemented the Globally Harmonized System for Classification and Labeling of Chemicals (GHS). Information spans the globe with data for Turkey, Saudi Arabia, Ukraine, Canada, India, Israel, and many more. Until now, Enhesa’s GHS tracking service focused on identifying progress towards GHS implementation, but information recently added provides descriptions of classification and hazard communication requirements in countries that have not adopted GHS. These countries may present unique barriers to chemical shipments.
A significant barrier to shipments may be found in the Canadian chemical classification system. The system classifies chemicals with six physical hazards: compressed gas (Class A); flammable and combustible material (Class B); oxidizing material (Class C); poisonous and infectious material (Class D), corrosive material (Class E) and dangerously reactive material (Class F). These contain endpoints that vary from related GHS physical hazards. Tests must be conducted according to prescribed testing methods. Classification is specified in the Federal Hazardous Products Act and the accompanying Controlled Products Regulations. Canada generally requires a nine heading format, as described in Schedule 1 of the Controlled Products Regulations. However, the sixteen heading MSDS format may be used to meet Canada’s MSDS requirement.
Latin American countries
Latin America presents a less significant barrier than Canada. Prior to GHS, many Latin American countries used the nine physical hazards from the UN Recommendations on the Transport of Dangerous Goods, Model Regulations. This system is still used in Chile, Colombia and Venezuela. Laws in these countries do not present a significant barrier to shipments classified according to GHS, where physical hazards are included. This is so because Colombia, Chile and Venezuela do not specify endpoints or tests. The laws reference the UN Recommendations, providing companies with flexibility in endpoints. The law also states that companies must consider health hazards and provide toxicity data where possible. Health hazard classes provided in GHS may be used, but are not necessary to meet legal requirements.
What about the Middle East?
With consciousness about chemical safety increasing in the Middle East, the Gulf Arab states have coordinated efforts to implement GHS. Qatar has published a notification of GHS adoption with other Gulf Arab states expected to follow soon. In identifying barriers to GHS implementation, Enhesa has added information for Saudi Arabia, Egypt, Algeria and Morocco. Egyptian law does not specify hazard classes, but does require an MSDS in Arabic with specified information regarding contents and handling of a hazardous chemical. Morocco has implemented a voluntary standard with chemical lists of classified substances. Morocco classifies dangerous substances as: explosive, oxidizing, extremely flammable, easily flammable, flammable, very toxic, toxic, harmful, corrosive, irritating and environmentally-hazardous.
Developments in Asia Pacific
Enhesa has also added information for several countries in Asia including Pakistan, India, Hong Kong, Philippines and Thailand. Classification requirements in Hong Kong present a significant barrier to chemical shipments. Hong Kong implements two detailed standards for classification that vary from GHS, Cap. 295AB and Cap. 59AB. Cap. 295 AB is a general classification standard that affects both transport and workplace storage. Cap. 59 AB applies to workplace storage only. Chemicals that are classified under the general standard, Cap. 295AB, are exempt from requirements of Cap. 59AB. However, certain chemicals may meet hazard criteria under Cap. 59AB that do not meet hazard criteria under Cap. 295 AB. Such chemicals must be classified under Cap. 59 AB.
Similarly, India uses a combination of lists and laws to classify chemicals. However, the barrier to shipments is significantly less than Hong Kong, since the Indian requirements are compatible with GHS. Companies must reference its GHS classifications against the official Indian classifications in Schedule I (i.e. Annex I) of the Manufacture, Storage and Import of Hazardous Chemical Rules, 1989 (as amended in 2000). This law does not implement GHS. Schedule I contains classifications by three general classes: toxic, flammable and explosive. In practice, GHS classifications are used in India, provided that a label contains data regarding toxicity, flammability and explosivity, as required in Indian national law. Explosives must be further classified pursuant to the Explosives Rules, 2008.
As can be seen by these examples, companies sending shipments are often riddled with a matrix of overlapping classification requirements. Countries that do implement GHS are in varying stages of implementation working from varying GHS revisions. Countries that have not implemented GHS sometimes present other barriers to shipment with unique classification requirements. New information in Enhesa’s GHS tracking service assists companies in navigating this matrix.
For current subscribers to the service, information regarding barriers to shipment is available in the third tab of table, “Global Summary Table of GHS Implementation.” If you are interested in obtaining more information on Enhesa’s GHS service, please contact us by sending an email to email@example.com.
– Riaz Zaman, EHS Regulatory Consultant