European Commission

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European Commission
General Principles - GHS ISPRA, JRC Informal
Stakeholder Discussion 18 November 2005 Dr.
Uta Jensen-Korte European Commission DG ENTR G 1


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General Principles

• GHS is a top down approach
• GHS provides common basis for classification for
  all the different target audiences including
  consumers, workers, transport and emergency
  responders
• GHS provides a single hazard communication
  message for the different target audiences
• GHS includes optionalities to facilitate
  implementation, but a common approach applicable
  for all sectors

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General Principles

• GHS Optionality
• Building Block Approach
• Classification cut-offs for Mixtures
• Competent Authority Options

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GHS Application

• Harmonisation of the application of the GHS
• GHS ST/SG/AC.10/30/Rev.1, 2005
• 1.1.3.1.1 The goal of the GHS is to identify the
  intrinsic hazards found in a chemical substances
  and mixtures and to convey hazard information
  about these hazards. The criteria for hazard
  classification are harmonised. Hazard statements,
  symbols and signal words have been standardised
  and harmonised and now form an integral hazard
  communication system
• Competent authorities will decide how to apply
  the various elements of the GHS based on the
  needs of the competent authority and the target
  audience.

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GHS Building Block Approach

• Building block approach
• GHS ST/SG/AC.10/30/Rev.1, 2005, 1.1.3.1.5
• Consistent with the building block approach,
  countries are free to determine which of the
  building blocks will be applied in different
  parts of their systems . . . . While the full
  range is available to everyone,., the full range
  does not have to be adopted.

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GHS - Building Block Approach

• Further clarification provided in
  ST/SG/AC.10/C.4/2005/6 -
• Proposal to be discussed at the Dec. 2005 UNSCE
  GHS
• 1.1.3.1.5.1 The selection of which hazard classes
  and appropriate hazard categories for a
  particular sector,, are at the discretion of the
  CA.

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GHS - Building Block Approach

• Further clarification provided in
  ST/SG/AC.10/C.4/2005/6 -
• Proposal to be discussed at the Dec. 2005 UNSCE
  GHS
• 1.1.3.1.5.2 There are two considerations to the
  BBA
• (a) Is each CA expected to adopt each GHS hazard
  class?
• No, not all hazard classes are applicable to all
  target audiences/sectors.
• (b) Is each CA expected to adopt each category
  within each hazard class?
• No. If the current regulatory approach within a
  sector does not cover certain categories of lower
  hazard within a hazard class, the GHS BBA allows
  that sector to include only those categories
  currently covered in their system

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GHS - Building Block Approach

• ST/SG/AC.10/C.4/2005/6
• 1.1.3.1.5.3 it would be inconsistent with the
  GHS to split or re-combine categories within a
  hazard class
• 1.1.3.1.5.4 Standardized label elements which
  have been assigned to each category should be
  used only for that specific category.
• 1.1.3.1.5.5. Once a hazard class and category is
  chosen by a sector and if that sector provides
  hazard information for that particular hazard,
  then the standardized GHS label elements would be
  expected as part of GHS implementation

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GHS - Building Block Approach

• ST/SG/AC.10/C.4/2005/6
• 1.1.3.1.5.6 At the CAs discretion, label
  information can be based on risk rather than
  hazard (see 1.4.10.5.5.2 CAs may authoriserisk
  based labelling)
• 1.1.3.1.5.7 As long as the hazards covered by a
  sector or a system are covered consistently with
  the GHS criteria and requirements, it will be
  considered appropriate implementation of the
  GHS....it is hoped that the application of the
  GHS worldwide will eventually lead to fully
  harmonised situation.

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GHS Building Block Approach
Freedom to implement Examples

• hazard classes /or
• categories
• Transport
• no chronic hazard classes
• acute toxicity category 1to 3
• Supply use
• mild irritant category 3?
• acute toxicity category 5?

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GHS Optionality

• Building Block Approach/Competent Authority
  Options
• Building Block Approach allows for inclusion or
  exclusion of specific harmonised elements of GHS
• If included, harmonised application of GHS
  elements applies
• Competent Authority Options allows for inclusion
  of unharmonised GHS elements
• If included, unharmonised elements applies

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GHS Implementation

• Consistent implementation of the GHS
• At the structural/conceptional level the GHS
  calls upon applying the principles of the GHS
• At the level of individual elements e.g. choice
  of hazard classes and/or categories the BBA
  provides the lead structure
• If a hazard class and/or category is chosen the
  GHS rules apply
• However GHS provides the possibility to include
  hazards covered by national systems which are not
  yet covered by the GHS
• Consistency with transport needs to be ensured

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GHS EU system

• GHS Hazard Classes
• 16 classes for phys-chem
• 10 classes for human health
• 1 class for aquatic environment
• EU classification as dangerous so called
  categories of danger
• 5 for phys-chem
• 9 for human health
• 1 for environment
• Plus special labelling provisions

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GHS Implementation Conclusion

• The GHS with the BBA and some of the other
  optionalities provides the possibility to
  implement the GHS with a level of protection as
  desired
• higher or lower level than the existing EU system
• similar to the existing EU system
• The Commission White Paper WG recommended to
  follow existing EU system as close as possible
• The responses to the questionnaires circulated to
  MS and other stakeholders May 2004 expressed a
  similar view

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Thank you!
For further information, please, consult the
website http//europa.eu.int/comm/enterprise/reac
h/ghs_en.htm