Q: Is it possible to create a “universal” Safety Data Sheet that can be used for a product that is shipped to numerous countries in Asia, Europe and North America instead of having individual SDSs for each country?
A: No, for a couple of reasons. The first reason why using one universal SDS is impossible has to do with the ‘language issue’. SDS and labels are instruments for ‘hazard communication’ and are designed to ensure the safety of people who’ll come in contact with substances. Communication being key, good translations of phrases for each target country is very important, and in most cases, is a strict legal obligation.
An other reason preventing one from using a single ‘universal label and SDS’ is the fact that country specific regulations still exist and, which must be addressed on a safety document (i.e. WGK in Germany, PRTR in Japan).
Finally, Japan, Korean, New Zealand and Europe published their own indicative or mandatory lists of ‘official’ substance classification. Since these are not harmonized, one will have to create localized documents.
Q: We ship products in 1000 lb cartons with label information on the carton. The products are then shipped to Asia Pacific countries such as Japan, Korea and China as well as many countries in Europe. Can we include “R phrases” as required in Europe along with GHS info?
A: This is not an option. You must add risk phrases, as these are mandatory until June 1st, 2015 in Europe. The CLP classification must also be added on top of this.
Q: Leaving some red diamonds blank “is” necessary because thermal transfer label printers can only print 1 color. On the label, would it be OK if we leave, say, the other two red diamonds blank, provided it has only two classifications?
A: There are no ‘official positions on this’. It may be ‘fine’ to leave red diamonds blank (some of our customers are doing that), unless OR until a country specifies something more stringent. But as far as we know, this hasn’t been the case. One can print a black square over the red diamond, thus leaving no room for ‘interpretation’ (i.e.: did the printer fail?)
Q: Does the GHS regulation change every two years? Are the changes fairly consistent in terms of revisions or do the regulations have flexibility to change more frequently?
A: GHS is a creation of the United Nations, just as the Transport Model Regulation (aka: the Orange Book), which is updated every two years. We anticipate that GHS will be updated every two years as well (as it’s been the case so far). Keep in mind that GHS is a ‘model’ and so, it is up for individual countries to keep up with it.
Q: Is GHS applicable for all countries? I understand REACH has integrated GHS. Does the EPA and OECD use it?
A: GHS is not applicable for all counties. It’s a model regulation that countries are free to adopt (and adapt to some degree). REACH and GHS have no real association to each other, apart from the fact that REACH requires a Safety Datasheet, and GHS specifies the classification scheme, format and content of an SDS.
The EPA in the US will be impacted by GHS, since they do enforce labeling requirements (for pesticides). See the information below on the United States.
OECD (Organisation for Economic Co-operation and Development) is an intergovernmental organization in which representatives from 30 industrialized countries in North America, Europe and Asia Pacific meet to co-ordinate and harmonize policies, discuss issues of mutual concern, and work together to respond to international problems. The OECD itself does not ‘implement’ GHS. OECD member countries have/will adopt GHS as part of their individual local legislation.
Q: What GHS implementations does Atrion support?
A: Atrion provides Managed Regulatory Content, which covers Europe, Japan, South Korea, Taiwan, Thailand and New Zealand.
