More than 50 people joined the conference on GHS - the Globally Harmonized System on Classification and Labeling of Chemicals - which was run by the Chem-Academy in April. Though it seems there is sufficient time for implementing GHS, speakers emphasized that this might be a false conclusion. Speakers both from authority and industry pointed out that projects need to be set up immediately in order to meet relevant timelines, first of all for substances.

Even if details on enforcement policy have yet to be clarified there is some pressure from Asian customers and suppliers. The fact that there is no real global harmonization doesn't make things easier. Supply chains have to deal with various elements of the building blocks and have to check details thoroughly. There are more aspects to be aware of: GHS or CLP (classification, labeling, packaging) means that processes have to be defined again, including things like transport regulation, printers being used, coordination with Reach, training of employees, etc. That includes risks: companies need to understand that there is no easy way to implement the GHS within a few months. Since there is an ongoing overlap between GHS and Reach, companies face opportunities as well as risks. Opportunities, because Reach requires certain aspects in terms of communication, data management, internal training, which are applicable for GHS. Risks because the workload can not be overestimated and non-compliance will create veritable business risks.

Speaker's Statements

CHEManager Europe asked conference speakers about their opinion on GHS:
"A system like GHS is crucial in order to take all precautionary measures when handling dangerous products that are shipped around the world. Even if it takes some time to implement, it is the best way to have globally consistent rules and regulations for risk assessment and transport across the board and to also assure an acceptable level of workplace safety - globally.
In my opinion, the intention of the GHS is good, but it will be very difficult and time-consuming to find compromises for the classification of dangerous products. There are many challenges to work through. For example, hazard assessment and the transport of dangerous goods have very different aspects to consider, even if they relate to the same issue. In addition, it will be very difficult for people and organizations to give up well-known procedures and processes and to invest in new strategies allowing complete harmonization."

Eckhard Baum, Clariant:
"With the GHS we have for the first time a coordinated basis to introduce a world-wide system for the classification, the labeling as well as the transport of hazardous materials. Due to the fact that in certain regions of the world (e.g. the U.S., Canada, Japan, Europe etc.) successful classification and labeling systems have already been existing for a long time, the implementation of the GHS will take many years.
One of the problems of the implementation of the GHS is that many companies are already very busy with introducing Reach and therefore have no capacities left. Additional problems occur due to the introduction of fully automated labeling systems. It would be helpful if the European Commission would give clear responses to technical questions regarding the adaption of the labeling systems (arrangement of symbols on the labels etc.)."

"The GHS is a new tool for chemical hazard classification and communication, incorporating harmonized chemical hazard classification criteria and provisions for standardized labels and safety data sheets. The worldwide implementation of GHS was slow in the beginning and has gained pace with the EU implementing GHS. Major countries like the U.S. haven't published any firm implementation schedule yet and so the effect of GHS remains limited. We would certainly prefer a more harmonized implementation schedule.
Since the harmonization is limited (building block principle, additional classification criteria in the EU, lists of substances with legal binding classifications, specific thresholds for substances, etc.) the implementation of GHS is first of all a technical challenge for a globally active company. As GHS requires more information to be put on a label - both in terms of numbers of pictograms as well as of hazard and precautionary statements - it is even more challenging to create small labels. To satisfy the goal of harmonization we would prefer a list of substances with legal binding classifications (similar to the UN number list for transportation) and furthermore the communication platform showing the progress of implementation should be updated more frequently. The information for Asian countries is often available in the ­local language which makes it difficult to interpret."

Dr. Eva Keßler, 3M Europe:
"At the moment each country or ­region has its own way to implement the GHS. This needs to be coordinated and harmonized in future. Especially lists of chemicals with their classification in different countries cause confusion. There is the need for a global list of classified chemicals."

Jürgen Pagel, Henkel:
"In my opinion the GHS is absolutely necessary. But the implementation process itself and, as it becomes more and more apparent, also the realization into national solutions drifts apart. First because of different implementation periods, and secondly because of different lists. (which are sometimes also intended by industry to "save" the former classification. But this saves also former differences). You can see these efforts also in Europe, but with different lists also in Japan etc. This forces you to observe these national regulations as before. This is not in the spirit of the GHS, but reality.
Up to now we are still at the beginning of the implementation and in ­Europe it is often overlapped by Reach. Criteria are mainly implemented in the transport regulations. Here problems appeared because of missing data because the data is specifically determined according to EU-regulations for which much longer transitional periods exists. Primarily, problems will appear in the downstream consequences like warehousing or production affairs."