The key objective of GHS is to facilitate protection of human health and the environment by providing chemical users and handlers with consistent information on chemical hazards via a single, globally harmonised system. This is to be achieved via standard elements (e.g. symbols or hazard pictograms) and statements on product labels and safety data sheets (SDS). It is anticipated that GHS will provide a consistent framework for classifying and simplifying hazard communication resulting in safer handling, transport, and use of chemicals. It will also potentially serve to promote safe and sound chemical management at the global level especially for countries currently without the pre-requisite regulatory framework. In terms of trade compliance, GHS can also facilitate trade by reducing the need to comply with multiple industry or geographic-specific hazard labeling systems. Last but not least, GHS will potentially reduce the need for testing and evaluation of chemicals via a global harmonised classification system.

The very nature of GHS is to change the current status quo and bring about a new world order as far as chemical management is concerned. As with any such changes on a global scale, this will potentially result in some misconceptions about GHS especially among downstream players in the chemical value chain.

A very common misconception about GHS is that it is a global regulation or standard that automatically applies to all countries. This is not the case. GHS is a system to classify chemicals according to their intrinsic properties or hazards. The system consists of a set of recommendations for chemical classification. No country is obligated to adopt all or even any part of the GHS system. Instead, countries can choose to voluntarily adopt all or pieces of the GHS system into their own regulations according to their own specific needs.

Such an approach can potentially lead to challenges that GHS is supposed to overcome. Even in a single country, different governmental agencies may implement GHS differently. For example, in South Korea, the Ministry of the Environment (MoE) revised the Toxic Chemicals Control Act in Nov 2007 to implement GHS for toxic chemicals. According to the revised regulation, toxic chemicals should be labeled according to GHS from July 2011 for single substance and from July 2013 for mixtures. However, the Ministry of Labor had previously revised the enforcement regulations in September 2006 to adopt the UN GHS for hazardous chemicals. The same transitional period was given for mixtures but not for single substance, which was enforced one year earlier (July 2010). Not only that, the building blocks were not harmonized resulting in the different regulations having slightly different building blocks for GHS. To further compound the complexity, the National Emergency Management Agency has prescribed a public notice in November 2008 to introduce GHS for dangerous materials (e.g. explosives, flammable substances etc.). However, the GHS classification here is not mandatory and both existing and GHS classification and labeling are allowed for use (4).

The provision for authorities to adopt different building blocks and cut-offs can result in a certain amount of inconsistency in the adoption and adaptation of GHS. This is not only unique to South Korea but occurs in many other countries. For example, there are specific requirements for non-GHS elements in Australia (special combustible category) and New Zealand (unique hazard class numbering system) (5). In addition, some countries have reported that they won’t adopt GHS in certain sectors. In the case of Singapore, consumer goods are currently outside the scope of GHS (6). As such, these goods are not required to be labeled according to GHS although proper labeling including safe handling of the products still needs to be adhered to ensure adequate protection of consumer health. However, in Thailand where GHS was published into law on March 12, 2012, itis potentially applicable to consumer and household products as well (7). This may potentially create artificial barriers to trade once fully implemented. Consumer goods that are compliant to regulations in Singapore may need relabeling if exported to Thailand. This will add additional costs and uncertainty to inter-country trade. However, the trend seems to be moving towards GHS classification for consumer goods. In the Philippines, the Department of Health (DOH) in the Philippines has recently issued a draft administrative order to implement the Globally Harmonised System for Classification and Labelling (GHS) for household hazardous chemicals and consumers products that are regulated by the DOH (8).

Another example of a potential country specific requirement may come from the US. On Jan 11, 2012, the US Chemical Safety and Hazard Investigation Board (CSB) recommended that “unclassified hazards” to remain in the final hazard communication rule that was subsequently released by OSHA on Mar 20, 2011 (9). The final rule pertains to the alignment of the Occupational Safety and Health Administration’s (OSHA) hazard communication standard (29 C.F.R. 1910 Subpart Z) with GHS. Unclassified hazards is a hazard category included within OSHA’s proposal but not in the latest revision of GHS and it would cover substances, which may pose risks to workers based on scientific evidence identified during the employer’s classification process but not with GHS criteria. Combustible dust was cited as an example of an unclassified hazard in the proposal. The CSB noted that this hazard is very common in the industry but GHS would be unable to effectively provide information about its presence or prevention without an unclassified hazards’ category. It is understandable that such country-specific requirements may be necessary and relevant but it does add another layer of complexity to a global harmonized system.

GHS is a hazard-based classification system. It has a harmonized criterion for defining physicochemical, health and environmental hazards. GHS provides guidance on how labels and SDS should be developed to convey information on chemical hazards and some basic instructions on handling the chemicals. It does not provide any information on the risk of handling such chemicals. In order to distinguish this point, there is a need to understand the difference between hazard and risk. Hazard is not equitable to risk. Hazard describes the intrinsic properties of a chemical. For example, corrosiveness is an intrinsic property of sodium hydroxide. It does not mean that sodium hydroxide has a high safety risk. Risk can be defined by the classic equation:

Risk = Hazard x Exposure

If the exposure to sodium hydroxide is minimized, there is minimal safety risk especially when proper precautions are taken (e.g. using PPE, following instructions for safe use etc.). Such instructions for safe use play a key part in ensuring workers‟ safety in an occupational setting and some components can be seen in the Safety (S-phrases) phrases incorporated in the MSDS (e.g. S:36 Wear suitable protective clothing). This will typically be replaced by the GHS precautionary statements (10). However, such instructions typically will not inform the worker of the magnitude of the risk in a specific exposure scenario nor the specific ways to minimize the risk (e.g. what kind of protective clothing/PPE should he/she be using). This has to come from proper chemical management/ product stewardship training that will be beyond the scope of the MSDS or label.

This needs to be clarified because there are still some misconceptions that the GHS SDS or label alone is sufficient to protect workers from chemical hazards. It is a key component in chemical management and product stewardship but it is not the only component.

However, it is important to note that GHS is not totally silent on chemical risk assessment. In the second revised edition of GHS (Annex 5), it is provided that if the risk of adverse chronic health effects in the consumer product use setting is insignificant, then the chronic health hazards do not need to be included on the product label for consumer use. It will be left to the individual countries to decide on whether to adopt such a risk-based approach for consumer products. In Asia, Japan has initiated such an approach in 2011 on a voluntary basis for certain consumer products (e.g. detergents and paints) (11). Such chemical risk assessment initiatives will play a significant role in chemical management and product stewardship. The development of such local expertise is to be encouraged.

It has already been mentioned above that in Singapore, consumer goods are currently not within the scope of GHS whereas in Thailand and the Philippines, this may not be the case. Indeed, in many countries, specific goods e.g. cosmetics, therapeutic goods, food and agricultural chemicals are not within the scope of GHS. In ASEAN, cosmetics are regulated by the ASEAN Cosmetic Directive and are not required by law to be labeled according to GHS requirements (12). In agriculture, the regulations are linked to UN WHO and FAO standards with their own regulatory requirements. However, due to country specific implementations, there may be confusion over a globally harmonized approach. For example, in Australia, under the NationalModel Code of Practice for the Labeling of Workplace Hazardous Chemicals, products that are exempted from hazard labeling such as cosmetics, therapeutic goods or food that are packed and sold as end-use product will be subject to hazard labeling if it is related to work activity (13). This can potentially be confusing to the end-users and the decision to apply such hazard labeling should take into consideration the end-user’s understanding of hazard and risk.

The objective of GHS is such that it will confer a significant advantage to countries that choose to adopt this system in terms of protection of human health and the environment as well as facilitating trade between countries. Theoretically, with the implementation of GHS, hazard classification of chemicals will be harmonized and workers globally will be accorded the same protection. Ideally, this system will do away with multiple interpretations of chemical hazards whereby for example, one country considering a specific chemical as toxic while another country consider it as non-dangerous.

However, with such a massive international initiative, there are bound to be misconceptions due to various factors especially at the local levels (cultural, historical, different levels of technical expertise etc.). Such misconceptions need to be overcome before GHS can truly become a globally harmonized system. Country-specific differences can potentially be resolved via greater efforts by international organizations to align with GHS. Chemical risk assessments should complement GHS in chemical management and product stewardship. In this regard, capacity building for such expertise should go hand in hand with GHS implementation especially in the developing countries.

Also, the jury is still out on the ramifications of GHS in consumer products. Typically for such products, unless the consumer or end-user is familiar with the GHS elements on the label, such hazard-based labeling may potentially result in further confusion. In developing countries, cleaning workers in hotels or restaurants handling detergents or cleaners typically will not be conversant with hazard labeling or GHS elements. There needs to be a program instituted to ensure that these workers and the consumers at large are adequately trained to benefit from GHS labeling before GHS is implemented in consumer products. This in itself may potentially be a huge undertaking that requires substantial planning and investment.

At the end of the day, the foremost consideration of any regulation pertaining to chemical classification should ensure that human health and the environment are adequately protected. The speed and manner of implementation may vary between countries but the end-goal should remain the same. That in essence, will fulfill the objective of GHS irrespective of the instruments used to implement it. The GHS for the first time has provided global guidance for a broad base of hazard classes and classification criteria that will serve as a strong foundation for subsequent risk assessments of chemicals. This bodes well for chemical risk management in the coming years ahead.

1.   International Labour Organization, The Globally Harmonised System for Classification and Labelling of Chemicals (GHS), http://www.ilo.org/safework/info/WCMS_111336/lang–en/index.htm.

2.   The GHS and the Global Partnership: A success story from Rio to Rio, http://www.ilo.org/safework/info/video/WCMS_183351/lang–en/index.htm.

3.   UNECE, About the GHS, http://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html.

4.   South Korea has several classification and labelling systems for chemicals. Among the most important ones include the Toxic Chemicals Control Act (TCCA) issued by the Ministry of Environment, the Industrial Safety and Health Law (ISHL) issued by the Ministry of Labour and the Hazardous Material Safety Act issued by the National Emergency Management Agency. The TTCA regulates the manufacture, import and use of industrial chemicals whereas the ISHL regulates workers’ health and safety aspects in the workplace. The MSDS for hazardous chemicals are covered by the ISHL.

5.  Safe Work Australia, Guidance on the Classification of Hazardous Chemicals under the WHS Regulations, www.safeworkaustralia.gov.au and Environmental Protection Authority (New Zealand), Correlation between GHS and New Zealand HSNO Hazard Classes and Categories, http://www.epa.govt.nz/Publications/hsnogen-ghs-nz-hazard.pdf.

6.   Singapore National GHS Task Force, Labelling of Workplace Chemical Containers – The Globally Harmonised System (GHS) Label, https://www.wshc.sg/wps/themes/html/upload/cms/file/03_GHS%20Label_Final.pdf.

7.  Progress on the Implementation of GHS in APEC Economies – APEC Chemical Dialogue Virtual Working Group on GHS, May 2012, page 2. See also UNECE’s GHS Implementation – Thailand (http://www.unece.org/trans/danger/publi/ghs/implementation_e.html). According to Thailand’s status report, the Food and Drug Administration (FDA) had finalized the drafting of Ministry of Public Health’s Notifications for GHS implementation for household or public health use chemicals and the public consultation period concluded in July 2011. The FDA is in the process of completing the process to have the notification submitted for consideration of the Hazardous Substance Committee and its final endorsement by the Ministry of Public Health.

8.  The draft was opened for comments through January 28, 2013 and the draft administrative order is available in English   at: http://www.fda.gov.ph/DRAFT/DRAFT%20AO%20PROCEDURAL%20RULE%20AND%20REGULATIONS%20IMPLEMENTING%20GHS.pdf

9.  US Occupational Safety & Health Administration, Modification of the Hazard Communication Standard (HCS) to conform with the United Nations’ (UN) Globally Harmonized System of Classification and Labeling of Chemicals (GHS), http://www.osha.gov/dsg/hazcom/hazcom-faq.html.

10. S-phrases are originally defined in Annex IV of European UnionDirective 67/548/EEC: Safety advice concerning dangerous substances and preparations. The list was subsequently updated in Directive 2006/102/EC and eventually will be replaced by the Classification, Labeling and Packaging of Hazardous Substances and Mixtures (CLP) regulations.

11. National Institute of Technology and Evaluation (NITE), Guidance on a Consumer Product Risk Assessment for GHS Labelling, http://www.safe.nite.go.jp/english/ghs/pdf/guidance_e.pdf.

12.  ASEAN Cosmetics Association, ASEAN Cosmetics Directive, http://aseancosmetics.org/default/asean-cosmetics-directive.

13.  Safe Work Australia, Model Code of Practice – Labelling of Workplace Hazardous Chemicals, http://www.safeworkaustralia.gov.au/sites/swa/about/publications/pages/labelling-hazardous-chemicals-cop.