GHS Chemical Labeling Compliance Requirements & Solutions www.visionid.ie integrating people, products and processes
GHS Chemical Labeling Compliance Introduction Worldwide instructions on the use of chemicals have been put into effect by the United Nations Economic and Social Council, under an agreement called the Globally Harmonized System of Classification and Labelling of Chemicals, or simply GHS for short. This was made official in 2003 and was overseen by the United Nations (UN) and the International Labor Organization (ILO), The move is important in harmonizing chemical hazard communications and specifically for chemical labels and regulations to ensure their safe usage. Globalization has meant a greater spread of industry across the world and with it, the greater use of chemicals in different regions. These new regulations not only cover the use and warning of such chemicals but aim to ensure the safe manufacturing of said chemicals along with ensuring that selling and transporting is done correctly and ethically. Most importantly, the regulations break down any communication barriers with chemical properties so all parties are fully aware of their content, and consequences, to avoid any human or environmental hazards. Here you will find the necessary information for the new GHS regulations of chemical labeling and communication. GHS Label Changes Changes in detail and accompanying costs The new Globally Harmonized System (GHS) regulations will require all chemical manufacturers to re-work their current systems of manufacturing, documenting and labeling of their chemical products by a strict deadline imposed by the GHS. Previous Material Safety Data Sheet (MSDS) documentation will need to be vigorously updated in order to meet the new standards set by the GHS. There are a series of new symbols, color codes, product identifiers as well as hazard and precautionary statements devised by the GHS that will need to be adhered to and all chemicals, labels and packaging will need to meet this criteria. There are 16 new classifications of Physical Hazards in the GHS criteria that will also require new laboratory testing and verification, which the GHS expects will take much time on the part of each manufacturer as supply chain partners and internal quality management systems will all be involved. The GHS recognizes the challenge this will pose and the European Chemicals Agency will allow a limited grace period to give manufacturers a chance to update their operations to meet the new standards on products manufactured before Decembers 1st 2010, which can be sold in Europe until December 1st 2012. See Deadlines for Compliance for more information. Benefits of the new regulations The onus and financial costs of updating their systems will be on the manufacturer; the GHS ensures the industry that it will benefit from the changes in the long term. The globally recognized system of labeling and documentation will make exporting and importing a less arduous task as manufacturers will not be burdened by different standards for different countries, instead all countries will work within the one system. The GHS also ensures that while there will be initial start-up costs in updating operations, both time and costs will be saved in future business. Deadlines for Compliance The GHS regulations are now legal in the European Union as well various parts of Asia and currently the regulations are being adopted in the USA and Canada. Each region is responsible for implementing the regulations and has imposed phases for completion and relevant deadlines to do so, many of which are dependent on each type of chemical. As of December 1st 2010, all chemical products manufactured, imported, exported or advertised within Europe, or to Europe from elsewhere, will require GHS approved labeling. Deadline dates for the US and Canada have yet to be outlined and confirmed. European Union Countries: Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Netherlands and the United Kingdom Pure Chemical Substances, including explosives, flammables, DSD/DPD, Country-specific standards December 1st 2010 pyrophoric, oxidizing liquids and solids, chemicals corrosive to metal Countries must submit notification of Chemical Substances Placed on N/A January 3rd 2011 the Market as of December 1st 2011 to European Chemicals Agency Transition period for substances manufactured Before December DSD/DPD, Country-specific standards December 1st 2012 1st 2010 (see grace period above) Mixtures of chemicals, including cosmetics, adhesives, solvents, DSD/DPD, Country-specific standards June 1st 2015 paints, laboratory supplies, cleaning agents Chemical mixtures manufactured and released before June 1st DSD/DPD, Country-specific standards June 1st 2017 2015; transition and grace period for GHS standards Pesticides FAO, DSD/DPD, WHO June 1st 2015 2
Contact Us: Republic of Ireland +353 (0)52 618 1858 Northern Ireland +44 (0)28 9099 8504 Call Us On LoCall 1850 923 633 Asia Countries: China, Japan, Korea, Indonesia, Malaysia, Philippines, Singapore, Taiwan, Thailand, Australia, New Zealand Pure Chemical Substances, including explosives, flammables, pyrophoric, oxidizing liquids and solids, chemical corrosive to metal Mixtures of chemicals, including cosmetics, adhesives, solvents, paints, laboratory supplies, cleaning agents Pesticides Australia NOHSC, SWA Japan CSCL, ISHL Philippines OSHS Singapore EPMA, WSHA Australia NOHSC, SWA Australia AVCCA, NOHSC, SWA Japan (PDSCL) Implemented China, Japan, Korea, New Zealand, Singapore, Taiwan 2012 Australia 2011 Thailand 2008 Malaysia Unknown Indonesia, Philippines 2012 Australia, Singapore 2011 Thailand June 30th 2013 Korea, Malaysia 2012 Australia Canada Pure Chemical Substances, including explosives, flammables, WHMIS Already implemented pyrophoric, oxidizing liquids and solids, chemical corrosive to metal Mixtures of chemicals, including cosmetics, adhesives, solvents, WHMIS, CPSB Yet to be established paints, laboratory supplies, cleaning agents Pesticides PMRA, CPSB, WHMIS Yet to be established Hazardous goods, transportation Transport Canada, WHMIS Yet to be established United States of America Pure Chemical Substances, including explosives, flammables, ANSI, EPA, OSHA Estimated at 2015 pyrophoric, oxidizing liquids and solids, chemical corrosive to metal Mixtures of chemicals, including cosmetics, adhesives, solvents, ANSI, OSHA, EPA Yet to be established paints, laboratory supplies, cleaning agents Pesticides ANSI, EPA, OSHA Yet to be established Hazardous goods, transportation ANSI, DOT, OSHA Yet to be established New label elements according to GHS standards Product Identifier The Product Identifier is intended to help workers, or anyone else handling the chemicals, to be able to accurately identify a chemical, its effects and hazards. The Product Identifier must contain the ingredient name or the chemical mixture or the number of the pure chemical substance. All technical names must be listed on the MSDS sheet and harmonized with the IUPAC (International Union of Pure and Applied Chemistry) and CAS (Chemical Abstracts Service). If a chemical is under the regulations of the United Nations Recommendations on the Transport of Dangerous Goods (UNRTDG), then it must also be harmonized with the UN Proper Shipping Name. GHS Pictograms GHS Pictograms, diamond shaped symbols, are required on all chemicals under GHS regulations. Pictograms are colored red, black or white and convey important information about the chemical s properties. See below GHS Label Pictograms and Requirements for GHS label sizes on containers for more details. If necessary, more than one pictogram can be used on a chemical and should be paired with signal words such as Danger, Caution or Warning. This should prevent accidents or exposure. Signal Words Signal Words are important in alerting the handler of the chemical to the severity of the hazard. Signals Words like Danger and Warning should be used on all chemicals but they should also be paired with either the number 1 or number 2. This is to convey just how dangerous a chemical is. For example: Danger 1 presents a hazard while Danger 2 is a much more significant and potentially lethal hazard if mishandled. 3
GHS Chemical Labeling Compliance Hazard Statements & Precautionary Statements These are statements presented on the chemical that detail the properties effects and hazards. Hazard Statements are mandatory and must be labeled clearly, especially when a mixture is involved, which will present more than one hazard. Examples of statements include notifying the handler if heating the chemical will cause an explosion. Precautionary statements are the relevant phrases paired with the pictograms to prevent hazards and are limited to a maximum of six. For example, if storing a chemical next to others is dangerous, this should be detailed in the statement. Information about Supplier Chemical containers, packaging, crates and cases must include a GHS label that details the Supplier Information. This information needs to include the supplier or manufacturer s name, address and telephone number. Other Important Information There is Supplementary Information that may be necessary to include on the chemical, which is done so voluntarily on the part of the supplier and/or manufacturer. These statements are welcomed provided that they do not conflict with or contradict GHS standards. Requirements for GHS label sizes on containers Below you will find relevant information on the necessary size for labels depending on the size of the container that the chemical is in. Capacity of container Label Dimensions by GHS standards Capacity of container Label Dimensions by GHS standards 3 liters or 3.17 quarts 52mm x 74mm or 2.04 x 2.91 3-50 liters or 3.17 13.2 gallons 74mm x 105mm or 2.91 x 4.133 50-500 liters or 13.2 132 gallons 105mm x 148mm or 4.133 x 5.82 500 liters or 132 gallons 148mm x 210mm or 5.82 x 8.26 Printing GHS Labels Information on In-House Printing Chemical manufacturers may print their own GHS labels in-house for use on their products. Should the manufacturer choose to do so, they have three options to avail of. Barcode Printer A barcode printer can be used to print the relevant pictograms, contact information and signal words in black. Labels will also require some color; usually this is red to signal a warning. Red labels should be pre-printed onto a roll of labels. The pre-printed roll is the placed inside a thermal transfer barcode printer. Two Color Printer Digital two color label printers will allow the manufacturer to print different colors in one printing task and may not be as time consuming as a barcode printer. The manufacturer will need to change the setting on their digital printer to ensure the correct colors and information is presented on the label and must also be wary that their digital printer will run off labels according to the sizes detailed above. The two color printer may also be the most cost effective measure for the manufacturer and the best option for meeting the UN Recommendations for the Transport of Dangerous Goods (UNRTDG). Full Color Printer Full color digital printers will offer manufacturers a wider range of functions for printing GHS labels. If also manufacturing cleaning or household products, the manufacturer will be required to print the full ingredients list. With more requirements, a full color printer is the better option to meet all the details, whether they are for GHS or private or custom labeling needs. Also, full color printers can be used to print a wider variety of label sizes, including 210mm (or 8.3 inches) wide labels, the largest label sized required by GHS. The manufacturer will also be able to manage all kinds of label production, GHS or otherwise, and address an Enterprise Resource Planning (ERP) system. This will narrow any margins of error that may occur in printing labels. 4
Contact Us: Republic of Ireland +353 (0)52 618 1858 Northern Ireland +44 (0)28 9099 8504 Easy to understand pictograms Call Us On LoCall 1850 923 633 The new labeling standards imposed by GHS require all chemicals to carry color-coded and easy to understand visual warnings. These warnings must be universally understood, regardless of language barriers or illiteracy. There cannot be any jargon or vague phrasing or images; the pictograms must be accessible to everyone. GHS regulations will ensure that such warnings are used worldwide and no potential hazards can go undetected in different regions. Most GHS labels include a white background inside a red diamond-shaped frame with a black symbol detailing the warning. Transport labels are an exception and may use other colors, under the UN Recommendations on the Transport of Dangerous Goods. GHS Label Pictograms more information Each pictogram must be combined with a signal word and number (1 or 2) to indicate hazard level, standardized hazard statements corresponding to health, physical, and environmental hazard class, precautionary statements, and the name, address, and the telephone number of the chemical manufacturer, importer, or other responsible parties. More information about GHS pictograms is available at the UN Economic Commission website, Annex I, Allocation of Label Elements. Pictograms need to be paired with the appropriate signal word and number (see Signal Words above), which alerts the handlers to the level of risk with the chemical. The pictogram and signal word and number and statements must also correspond to health, physical and environmental hazard class while also feature precautionary statements and supplier information and other relevant parties. Explosive; Heating may cause fire or explosion Oxidizer, may intensify fire; Oxidizing gas; Flammable gas; Flammable Aerosol; Flammable Liquid; Flammable Solid; Heating may cause a fire In contact with water, releases flammable gas; Self-reactive Substance or Mixture; Self-heating; Catches fire spontaneously if exposed to air Gas under pressure Corrosive to Metals; Causes Serious Eye Damage Acute Toxicity Oral; Acute Toxicity Skin; Causes Skin Irritation; Causes Serious Eye Irritation Germ Cell Mutagenicity, Carcinogenicity; Organ Damage; Birth Defects; Aspiration Hazard; Breathing Difficulties, Allergies, or Asthma if Inhaled Aquatic Environmental Toxicity Acute; Aquatic Environmental Toxicity, Chronic Harmful if Swallowed; Toxic if Inhaled; Harmful in Contact with Skin; May Cause an Allergic Skin Reaction; May Cause Respiratory Irritation 5
GHS Chemical Labeling Compliance Transport Label Pictograms (valid under GHS) Explosive, Division 1.1, Self-reactive Explosive, Division 1.2 Explosive, Division 1.3 Explosive, Division 1.4 Explosive, Division 1.5 Explosive, Division 1.6 Flammable gas, Flammable aerosol Oxidizer, Oxidizing liquid, Oxidizing solid Gas under pressure Gas under pressure Flammable liquid and vapor Flammable Solid, Self-reactive Substance or Mixture Pyrophoric Liquid, Pyrophoric Solid, Self-Heating Substance or Mixture Substance Emits Flammable Gases Organic Peroxides Corrosive to Metals XXX XXX Visit the UN Economic Commission website for more information. Printable labels are available on UN website also. 6
Material standards for labels and packaging GHS regulations also demand that packaging material is up to standard and consistent with all its safety measures to contain and prevent any chemical hazards. There are a number of guidelines that need to be complied with under the CLP (Classification, Labelling and Packaging) Regulation in Europe, overseen by the European Chemical Agency under EC Regulation No 1272/2008. Packaging must prevent the chemical from escaping The strength of the packaging must not be affected or compromised by the chemical The packaging must also be able to maintain repeated handling and movement Furthermore, under GHS label regulations, all labels must be resistant to the chemical itself, weather resistant, UV light resistant, abrasion-resistant, and must also use a marine-grade label adhesive to ensure a strong and durable label. Chemicals may be transported by sea but are subject to strict standards for their safe transportation. GHS standards require that certain products meet the standards set out by the International Maritime Dangerous Goods Code (IMDG). The code aims to prevent any damage or pollution that can be caused by dangerously transporting chemicals by sea. IMDG and GHS require that chemical labels are in line with the British Standard BS 5609, which means that printed label materials must be able to survive three months submerged in saltwater without the text on the label fading or the adhesion to container coming undone. MSDS Documentation required by GHS MSDS (Material Safety Data Sheet) data sheets are subject to GHS regulations also, which will provide new information on the management of chemical safety in the workplace and the use of labels. The format is established under EC No 1272/2008. This new format for MSDS data sheets is similar to previous ISO, EU, and ANSI safety data sheet format but with a select number of differences. The new format has 16 sections, which includes new details on Transport Information, Ecological Impact, Disposal Consideration, and Regulatory Information. These new regulations must be adhered to by the deadlines given above. Additional reading and information on GHS Labeling and Label Printing can be found at the following links: European Questions & Answers on GHS Classification, Labelling, and Packaging (CLP) - European Chemicals Agency USA Guide to GHS Labeling Implementation US Department of Labor (OSHA) Canadian GHS Labeling Implementation Schedule - Health Canada website: Head Office: Limerick Office: Dublin Office: Northern Ireland Office: www.visionid.ie Unit 4C Gurtnafleur Business Park, Clonmel, Co. Tipperary, Tel: +353 (0)52 618 1858 Fax: +353(0)52 618 1860, Email: info@visionid.ie Annacotty Business Park, Annacotty, Co. Limerick, Tel: +353 (0)61 514 683 Fax:+353 (0)61 749 873, Email: midwest@visionid.ie 3013 Lake Drive, Citywest Business Campus, Dublin 24, Tel: +353 (0)1 524 1586 Fax: +353 (0)1 443 0560, Email: dublin@visionid.ie 20 Adelaide St. Belfast, BT2 8GB, Northern Ireland, Tel: +44 (0)28 9099 8504, Email: ni@visionid.co.uk