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GHS White Paper – Impact and Preparedness

Chem-Safe Australia Pty Ltd

June 2016

2 GHS White Paper – Impact and Preparedness

Chem-Safe Australia Pty Ltd (C) Copyright June 2016

1 GHS Impacts Chemical

Classification, Labelling

and Safety Data Sheets.

The United Nations have developed a global chemical management system that is called the Global Harmonization System or GHS for short. The deadline for Australian conversion to the GHS system is 31st December 2016. This White Paper explores the key issues of around this key change to Chemical Safety in Australia. We explore the impact to Manufacturers, Distributors and Users of chemicals in Australia.

GHS provides a detailed framework of providing global uniformity of how we classify a chemical hazard and how we communicate this chemical hazard via GHS format chemical labels and GHS format safety data sheets. GHS has been developed by the United Nations with a focus on improving the understanding of health and environmental effects of chemicals. Over 50 countries signed up for GHS and it was recognized globally on 1st January 2012. Australia has committed to meet the UN requirements of GHS by the end of December 2016. The detailed requirements for Australia are contained within the WHS Regulations. GHS chemicals will be known as Hazardous Chemicals in Australia and replace the current system of Hazardous Substances and Dangerous Goods.



Under the GHS System all chemical hazards are viewed from a Physical, Health and an Environmental perspective. There are the following number of Hazard Classes under the GHS System: Physical – 16 x Hazard Classes Health Hazards – 10 x Hazard Classes Environmental – 2 x Hazards Classes Section 2 of the Safety Data Sheet called Hazard Identification will provide clarification as to which Hazard Classes apply to the chemical. A Hazard Statement will provide a more detailed description of the chemical hazard and will be the letter H plus a number will also be found in Section 2 of the SDS: Example - H301 Toxic If Swallowed There are over 70 possible Hazard Statements. Chemicals can have multiple hazards and more than one GHS symbol to signify this.

2 GHS Views Chemical

Hazards from a Physical,

Health and

Environmental

Perspective

GHS has identified Chemical Hazard Classes from three different perspectives:

Physical Hazards

Health Hazards

Environmental Hazards

Each identified Hazard has with it a GHS Pictogram, which is shown as a diamond with a red border. There are 9 possible GHS Pictograms. The objective of GHS is then to communicate this identified chemical hazard via GHS Labels and GHS Safety Data Sheets (SDS). The Dangerous Goods Diamond System previously focused primarily on immediate physical impacts and did not represent Health and Environmental impacts well. The aim was to provide a more comprehensive coverage of chemical hazards in the workplace from which improved safety decisions could be made.



Severe health

hazards

Health hazards

Acute toxicity

Explosive

Flammable

Oxidising

Corrosive

Gases under

pressure

Environmental

hazard

3 GHS has 9 Pictograms to

identify the type of

Chemical Hazard to

communicate on the

product label.

Chemical Manufacturers and Distributors will need to ensure the appropriate pictogram is on each chemical. The pictogram will highlight an identified Chemical Hazard which will be explained in more detail within the Safety Data Sheet. The aim of the pictogram is to highlight an identified hazard of the chemical in a visual way which will then prompt the chemical user to check more details in the SDS..

Labelling of Workplace Hazardous Chemicals Code of Practice – December 2011 provides more detail on label sizes and information required, relative to pack sizes which should be referenced for exact details.



Under the GHS System there are 10 x identified Health Hazards Classes. Each one will attract a GHS Pictogram on the label. The categories are:

Acute Toxicity Irreversible Skin Corrosion or

Irritation Reversible Skin Irritation Serious Eye Damage or Eye Irritation Respiratory or Skin Sensitisation Germ Cell Mutagenicity Carcinogenicity Reproductive Toxicity Specific Target Organ Toxicity for

Single and Repeated Exposure Aspiration Toxicity

The relevant category will be shown in Section 2 of the Safety Data Sheet. The GHS Pictogram shown above represents a Severe Health Hazard – this is the highest rank of chemical health risk, sometimes with chronic effects.

The WHS regulations also provide a list of chemicals where formal Health Surveillance is

required.

4 One of the priorities of

GHS is to help workers

identify chemicals with

Negative Health

Hazards.

The United Nations have prioritized the improvement in the understanding and communication of chemicals with identified negative health effects.

GHS has created a range of pictograms to help us identify 10 x possible Health Hazards for a chemical.

This will help us, in conjunction with the Hazard Statement in Section 2 of the Safety Data Sheet to manage those chemicals that can affect people’s health in the workplace.

Once the Health Hazard has been identified then organizations must develop the appropriate controls to keep the risk identified to an acceptable level of risk.

This is the biggest focus area for GHS in Australia and how we manage these chemical hazards – these labels were not in place previous to highlight these risks.

This part of GHS has altered significantly the risk profile of the chemicals people use in the workplace. Organizations will now have to review their chemical risk profile opposite this focus area of potential health risks.

GHS has over 30 different identified Health Hazard Effects that are grouped into ten categories.



5 For Transporting

Chemicals in Australia

the Dangerous Goods

Diamond labelling

system takes priority.

For the Transportation of chemicals in Australia the Dangerous Goods Class Diamond must also be in place. The Australian Dangerous Goods Code will take priority over GHS, just for the Transportation of Chemicals in Australia. Given the requirement is to have GHS labels on the inner package for workplace identification and communication of chemical hazards, we are likely to see both Dangerous Goods Diamonds and GHS Pictograms on chemicals in Australia. The relevant label required for Transport is found in section 14 of the SDS. With the GHS label in Section 2 of the SDS. Both must be in place for Distributors of chemicals in Australia. If materials are supplied in boxes then the Dangerous Goods Diamond must be on the outer packaging, with GHS labels on inner packages. Distributors must ensure this area of compliance as a priority to avoid problems in

the transportation of their chemicals.



Under the GHS System there are 16 x identified sections in a Safety Data Sheet. Each one must be in the format and sequential order below: The sixteen SDS categories are:

1. Product and Supplier Identification 2. Hazard Identification 3. Composition and Ingredients 4. First Aid Measures 5. Fire Fighting Measures 6. Accidental Release Measures 7. Handling and Storage 8. Exposure Controls and PPE 9. Physical and Chemical Properties 10. Stability and Reactivity 11. Toxicological Information 12. Ecological Information 13. Disposal Considerations 14. Transport Information 15. Regulatory Information 16. Other Information

The SDS still have a 5 year life span and must be reviewed and communicated when any changes or reviews are made.

6 Under GHS, the MSDS is

replaced by the Safety

Data Sheet.

Under the GHS System the document designed to communicate the key hazards of the chemical and safe working practices is known as the Safety Data Sheet. It has additional safety information for emergency response for health physicians and fire brigade to help with key response actions. The aim is for the SDS to be much more focusses on safety information and less focussed on some of the technical data. The format of the SDS has little impact change in Australia, with our 16 section format used as a base for the GHS SDS format. To help organizations the government has created the Preparation of Safety Data Sheets for Hazardous Chemicals Code of Practice – December 2011. The only major change is the terms and changes in chemical hazard descriptions. The base principle still applies to manufacturers and distributors to supply SDS to customers and for workplaces to hold SDS for every chemical stored and handled on site. GHS formatted SDS must be in place for everyone by the end of 2016. Old MSDS must be replaced with SDS for this deadline. Over 85,000 MSDS are issued in Australia each year.



7 GHS Labels have a

defined Structure and

Format.

This is probably the biggest area of change for manufacturers and distributors in that GHS prescribes a very specific and mandatory structure to its labelling requirements.

All chemicals supplied to customers from manufacturers and distributors must meet this key requirement for compliance. Full details can be found in the Labelling of Workplace Hazardous Chemicals Code of Practice – December 2011.

The aim of the new GHS label is to provide more safety information on the chemical hazards of the product in a mandatory format so that everyone can see, before they use the chemical what the identified hazards, precautions and warnings are. The label should be used in conjunction with the details of the SDS.



GH

S Manufacturer

Distributor

Customer

Co

mp

lian

ce

Classification

Label

SDS

8 GHS sets new

challenges for

Manufacturers and

Distributors in

Australia.

For manufacturers and distributors of chemicals GHS create major challenges with a number of key compliance requirements:

The chemical is classified under the GHS criteria for Physical, Health and Environmental Hazards.

This information is transferred to the 16 section GHS Safety Data Sheet.

The chemical is labelled with the appropriate pictograms and label structure. It also takes account of the Dangerous Goods labelling requirements for Transport in Australia.

If products are imported into Australia the Distributor may need to add appropriate Dangerous Goods symbols to meet the requirements of the Australian Dangerous Goods Code.

All SDS supplied to customers must be GHS compliant by 31st December 2016.

New GHS SDS must be updated to customers for historic sales.

Exports must reflect local transport labelling in destination country.

Deadline for compliance in these key

areas is 31st December 2016.

8 GHS sets new challenges for

Manufacturers and Distributors in Australia.

For manufacturers and distributors of chemicals

GHS creates the biggest challenges with a

number of key compliance requirements:

The chemical is classified under the GHS criteria for Physical, Health and Environmental Hazards.

This information is transferred to the 16 section GHS Safety Data Sheet.

The chemical is labelled with the appropriate pictograms and label structure. It also takes account of the Dangerous Goods labelling requirements for Transport in Australia.

If products are imported into Australia the Distributor may need to add appropriate Dangerous Goods symbols to meet the requirements of the Australian Dangerous Goods Code.

All GHS SDS supplied to customers must be GHS compliant.

New GHS SDS must be updated to customers for historic sales.

Exports must reflect local transport labelling in destination country.



Do your staff understand the key requirements of GHS?

What-When-Why ?

Do you have GHS Compliant Safety Data Sheets from your supplier?

Are the chemicals in your site labelled correctly under GHS and Dangerous

Goods criteria?

Have You assessed the new risk profile of your chemicals now that GHS has added

Health and Environmental Hazards?

Have you consulted your staff and customers about the new hazards

identified under GHS?

9 Key Questions for GHS

Compliance in Australia

at your site?

In Australia by the end of December 2016 organizations must be able to provide answers to the questions on the right to be able to understand whether they are compliant with all the new requirements of the GHS System in Australia. How can Chem-Safe Australia help in this process? Please call General Manager Craig Watt on (08) 9581 1472 to see how we can help you through this challenge. Areas we can help are:

GHS Awareness Training. SDS formatting and authorising them

to Australian GHS requirements. Posters and Safety cards for staff

meetings and awareness. Label verification of product labels to

meet GHS standards. Chemical Risk Profiling of materials and

suggested control improvements. Site Audits and Improvement Plans. Which Placards do we need to display

around site. Licensing Requirements.

www.chem-safe.com.au [email protected]

http://www.chem-safe.com.au/

mailto:[email protected]



10 GHS will impact

Licensing and Placarding

Quantities

In Australia within the WHS Regulations a new table has been created to identify Placard and Manifest Quantities for GHS classified chemicals. Reference is also made to the Dangerous Goods chemical description to help people understand this key change. In some states in Australia the Licensing system has been relaxed and a Notification System is used to declare chemical types and volumes on site which are shared with government agencies and emergency services. This is the case is Queensland, NSW, NT with WA yet to decide the outcome. At placarding quantities certain signage must be in place to warn emergency services of the chemical hazards being stored. At manifest quantities there is a requirement of notification/licensing and an emergency plan document must be in place at the entrance to the site. This manifest can be used to make effective

decisions by the emergency services.



11 Placarding of Dangerous

Goods will still be

required for Emergency

Response

Under the requirements for Emergency Response within the WHS Regulations there is still a requirement to display Dangerous Goods placards. These will take priority over GHS pictograms for placards that are required for emergency response. An Emergency Information Panel will be required in the format above for all bulk storage tanks and containers where the capacity of the container is above 500 ltrs/kg. The UN number and Hazchem Guide will be used as the primary tools to help deal with emergencies with chemicals in Australia. The Australian Standard HB76 – Dangerous Goods Initial Emergency Response Guide has been amended in its detail to include the GHS System. It is strongly recommended all organisations have copies of this key Australian Standard. The book is an easy to understand guide about what to do with chemical spills and chemical fires. It is considered the new “bible” of chemical

emergency response.

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