HSNO Group Standards

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HSNO Group Standards

• Andrea Eng
• ERMA New Zealand

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Overview

• What is a Group Standard?
• Assigning a product to a Group Standard
• Group Standard Conditions
• Inventory of Chemicals

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What is a Group Standard?

• Hazardous substance approval for
• Existing substances (NOTs)
• New substances that fit the scope of the Group
  Standard
• Previously transferred or approved substances
• For future use to include manufactured articles,
  waste or manufacturing by-products that
  are/include a HS

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Group Standards

• Hazardous substances of similar nature, or type
  or circumstance of use can be grouped e.g.,
• Cleaners
• Aerosols
• Cosmetic products
• May be issued by ERMA on its own initiative or on
  application by any other party

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Group Standards

• Developed around primary hazards or combination
  of hazards
• Not all hazards covered
• Explosives, 3.1A, 3.2, 4.1.2, 4.1.3, 4.2A, 4.3A,
  5.1.1A, 5.1.2A, 5.2A, 6.1A, 8.2A excluded
• Restrictions on CMRs
• No new single component chemicals

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Assigning a Product to a Group Standard

• Is the product hazardous?
• What is the product type?
• What are the primary hazards?
• Does the product meet the scope of the Group
  Standard?

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Is the product hazardous?

• HSNO criteria explosive, flammable, oxidising,
  toxic (includes acute and chronic effects),
  corrosive, ecotoxic
• If product is hazardous in Australia, then
  hazardous in NZ
• Some products not hazardous in Australia are
  hazardous in NZ

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Primary Hazards

• Flammable/combustible
• Corrosive
• Oxidising 5.1.1
• Toxic 6.1 B or C
• Toxic 6.7

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What is the product type?

• 200 group standards issued July 2006
• http//www.ermanz.govt.nz/hs/groupstandards/gslist
  .pdf
• Cover 30 product specific substances or
  generics
• No group standards for
• Pesticides
• Veterinary medicines (other than nutritional
  products)

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Scope of the Group Standard

• Typically specifies the product type
• Defines the hazard boundaries (HSNO
  Classification Regulations)
• Primary and subsidiary hazards
• Provides for group specific restrictions

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Example - Cleaning Products

• Solid or liquid substances that are imported or
  manufactured for use as a cleaning product
• Primary hazard (must have) e.g., skin corrosive
• Subsidiary hazards (may have)
• Substances excluded from the group standard e.g.,
  
• CMRs
• Components not listed on the Inventory of
  chemicals

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Example - Cleaning Products

• Cleaning Products (Combustible)
• Cleaning Products (Corrosive)
• Cleaning Products (Corrosive, Combustible)
• Cleaning Products (Flammable)
• Cleaning Products (Flammable, Corrosive)
• Cleaning Products (Oxidising 5.1.1)
• Cleaning Products (Oxidising 5.1.1, Corrosive)
• Cleaning Products (Subsidiary Hazard)
• Cleaning Products (Toxic 6.7)

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Conditions

• A Group Standard applies conditions to the
  substance, not controls
• Based on HSNO regulations, but some differences
• More user friendly
• Prescriptive but allow for alternative means of
  compliance

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Group Standards Landscape

• No compliance required with the HSNO regulations,
  unless
• Allowed for as alternative means of compliance
  or
• Regulations incorporated by reference inc. Tank
  Wagons, Tracking, Compressed Gas Regulations
• How the components interlink

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Site and Storage Conditions

• Compressed gases
• Aerosols
• Class 3.1 flammable liquids
• Class 4 substances
• Class 5.1.1 oxidising substances class 5.2
  organic peroxides
• Toxic, corrosive ecotoxic substances

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2010 Condition

• As part of the alternative compliance measures, a
  2010 provision is provided for
• Labelling
• Packaging
• Child Resistant Packaging
• Permanent Identification
• Provisions expire 31 December 2010

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2010 Condition Why?

• Recognises NZ implementation of GHS is ahead of
  other countries
• Alignment with international best practice
• Removes the need for relabelling or repackaging
• Minimises compliance costs
• Reflects the submissions received from the
  consultation

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2010 Condition Labelling

• Compliance not required with the prescriptive
  group standard labelling condition if labelling
  complies with
• the relevant current labelling requirements of
  Australia, USA, Canada, the European Union or any
  other country as approved by the Authority, as if
  the substances were for sale or supply in those
  countries, and the requirements of subclause
  (2).
• Condition expires 31 December 2010

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2010 Condition Packaging

• The requirement for child resistant packaging
  does not need to be met if
• (a) the substance complies with the
  requirements for child resistant packaging (if
  any) of Australia, USA or the European Union or
  any other country as approved by the Authority
  and
• (b) the substance is not
• (i) a HNSO 6.1D substance or
• (ii) an aspiration hazard.
• Condition expires 31 December 2010

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2010 Condition Packaging

• Permanent identification of packaging not
  required
• if the substance container meets the container
  requirements for that substance of Australia, the
  European Union or any other country as approved
  by the Authority.
• Condition expires 31 December 2010

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Keeping a record

• Requirement to keep a record when assigning a
  substance to a group standard
• Assigning a product to a Group Standard
• (1) The manufacturer or importer of a substance
  who determines, or is otherwise independently
  advised, that the substance complies with clause
  4 of this Group Standard must keep a record of
  that determination or advice and have that record
  available for inspection.
• (2) The record must contain sufficient
  information to allow for independent verification
  that the substance complies with clause 4 of this
  Group Standard.

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Using Group Standards - Advantages

• Flexible, allow for some formulation changes
• Fewer applications required for new products
• More concise documentation
• Improved guidance
• Fewer approvals to keep track of
• Lower compliance costs for industry

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New Group Standards

• No database of substances approved under a Group
  Standard
• ERMA not expecting to develop new group standards
  one off programme for NOTS
• Other parties can make an application to ERMA
• - application forms being developed (check web
  site)
• - contact Applications Manager
• - cost negotiable

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Inventory of Chemicals

• Purpose of inventory is to have a list of
  chemicals known to be present in NZ
• Group standards place a requirement to notify
  ERMA of new chemicals
• Notification is not an approval, and the
  inventory is not a list of approvals
• No fee or charge for notification

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Inventory

• Align the inventory with overseas inventories,
  notably the AICS
• Non hazardous chemicals included. Encourage
  notification of non-hazardous substances
• Notification form on our website

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Resources

• Group Standards web page
• http//www.ermanz.goct.nz/hs/groupstandards/index.
  html
• List of group standards
• http//www.ermanz.goct.nz/hs/groupstandards/gslist
  .pdf
• Labelling of Hazardous Substances Hazard
  Precautionary Information
• http//www.ermanz.govt.nz/hs/groupstandards/standa
  rds/ss/hplabelling.pdf
• Inventory of Chemicals
• http//www.ermanz.govt.nz/hs/compliance/inventory.
  html
• Information on labelling advice Safety Data
  Sheets
• http//www.ermanz.govt.nz/hs/applications/labellin
  g.html