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International Consistent Hazmat Management - Possibilities and Limits

The use and transport of chemicals are important economic aspects. Equally significant is a well-functioning hazardous substance management in importing and exporting companies. After all, only a flawless flow of information can minimize the risks and dangers emanating from hazardous substances. An optimized hazardous substance management also helps companies to expand their structures. As an economically important topic, hazardous substance management has long since become a political issue. The EU regulations REACH and CLP have introduced measures to harmonize existing structures and obligations in the labeling of hazardous substances. The aim on a worldwide level is the establishment of an internationally consistent hazardous substance management with the GHS regulation.

GHS and the Enforcement Problems

The goal of the GHS regulation is primarily a global harmonization of the hazardous substances legislation. However, due to frequent updates and necessary adjustments, quite the contrary is the case. The modular approach in the implementation of the GHS into national law also proves problematic.  Accordingly, not all modules must be adopted. Countries also have the option of considering their own valid national regulations (left-overs). However, the implemented modules are to be taken over 1:1 and must not conflict with the GHS standard. Nevertheless, different regulations regarding the handling of hazardous substances continue to apply on all continents. Even from country to country, there may be serious differences.

English SDB Worldwide?

At international level, English functions as one of the most important business languages. The fact that the language could also contribute to the aspired harmonization in the area of ​​hazardous substances legislation is mistakenly assumed regarding the creation of Safety Data Sheets (SDS). In practice, English is already reaching its limits in the EU since SDS have to be written in the local language as prescribed in the REACH/CLP regulations. Conclusion: a Safety Data Sheet written in English does not meet the country-specific requirements and is at most suitable for examination purposes.

Country-Specific Hazmat Management Exemplified on UK and USA

Striking content and formal differences in the creation of Safety Data Sheets are already apparent in English-speaking areas. Adetailed comparison of thedirectives that apply to the United Kingdom and the United States shows different requirements to the SDB format. While in the United Kingdom, Safety Data Sheets according to REACH Regulation (EC) No. 1907/2006 have to be prepared taking into account the Annex to Regulation (EU) No. 2015/830, in the USA the ANSI standard Z400.1 is used. This results in different classification limits for mixtures and country-specific additional hazard definitions (labeling). Both are associated with more effort in the preparation of Safety Data Sheets, because possibly different ratings and, linked to that, separate records come into play.

Intercontinental Hazmat Management

The state of implementation of GHS differ throughout the world. In particular, there are noticable differences in the area of ​​hazmat management. In the United States, for example, OSHA HazCom applies since 2012, WHMIS/HPA in Canada, NOM-018-STPS-2015 in Mexico and NBR 14725: 2014 in Brazil. The contents of the SDS must be adapted to national regulations. What they all have in common is that they require far less exact formats than the European REACH. The GHS implementation in the Asia-Pacific region is proceeding particularly slowly. Especially the different revisions of GHS, varying classification limits for mixtures, country-specific additional labeling and regulations, as well as differing occupational exposure limit values ​​and standards for protective equipment, become particularly problematic.

Conclusion - Are Equal Classifications Possible Worldwide?

Due to the existing conditions, an internationally consistent hazardous substance management remains a project for the future. The implementation of the classification and labeling of chemicals required by GHS is not yet well advanced. However, the current arrangements for an adequate transport of hazardous substances is a first tangible success and paves the way for the desired global standardization of regulations.