GHS implementation (and GHS- like implementation) in the “rest of Asia” September, 30, 2014; Washington, DC Dr. Piyatida Pukclai 1
Agenda Thailand: Hazardous Substance Act Malaysia: Occupational Health and Safety Act, CLASS and EHSNR Philippines: Department Administrative Order No. 29; Department Order No. 136-14 Indonesia: Regulation Ministry of Industry No.23/M-IND/PER/4/2013 Singapore: Work Safety and Health (General Provisions) Regulations, SS 586 Vietnam: Decree No. 108/2008/ND-CP; Circular No. 28/2010/TT-BCT; Circular No. 04/2012/TT-BCT Activities on ASEAN level 2
South Korea: Implementation complete China: Implementation complete Japan: Implementation complete Taiwan: Implementation complete Vietnam: Implementation complete GHS will be mandatory for mixtures as of March 30, 2016 Thailand: Implementation complete GHS will be mandatory for mixtures as of March 13, 2017 New Zealand: Implementation complete Singapore: Implementation complete GHS will be mandatory for mixtures as of July 1, 2016 Indonesia: Implementation complete GHS will be mandatory for mixtures as of December 31, 2016 3
Thailand GHS Thailand Hazardous Substance Act B.E. 2535 Issued first in the year B.E. 2535 (1992) revised twice in B.E. 2544 (2001) and B.E. 2551 (2008) Issued under the responsibility of the Ministry of Industry Due to the diverse characteristics and usage of the substances, enforcement is split over 6 agencies: Department of Agriculture (DOA) Department of Fisheries (DOF) Department of Livestock Development (DLD) Food and Drug Administration (Ministry of Public Health) Department of Industrial Works (DIW) Department of Energy Business (DOEB) 4
Classification of Hazardous Substances The Hazardous Substance Act B.E.2535 (1992) Class 1 Class 2* Class 3* Class 4 Hazardous substance Hazardous substance Hazardous substance Hazardous substance • Totally Banned • Notifying of the • Product Registration • Product Registration Volume and product • Notifying of • Licensing (Permit) information; manufacturing, for manufacturing, • Producer, Importer, import, export or import, export and Exporter and possession for possession for Possessor professional use professional use For the link of the Notification of Ministry of Industry “List of Hazardous Substance” B.E. 2556 (2013) go to: http://eis.diw.go.th/haz/pdf/announce56.pdf 5
Registration procedure All producers, importers, carriers and persons in possession of listed HS must check the status of chemicals with the “ Hazardous Substance Control Bureau of DIW” For Type 2 and 3, applicant shall; Check status of substance via online system and discuss with DIW authorities Submission of application and related documents: 100% composition, MSDS, etc. Checking of application and its dossiers by DIW officers Evaluation process Approval from the authorized officer Issuance of registration certificate For the official DIW guideline go to: http://eis.diw.go.th/haz/hazard/Libary/hazcert.htm 6
THAILAND: GHS Status In March 13 2012 GHS Notification rule was gazette following the 3 rd revision of UN GHS, with a transition period of one year for substances and five years for mixtures Some differences in terms of implemented hazard categories and classes Transitional period; For substances mandatory from March 13, 2013 For mixtures mandatory from March 13, 2017 7
THAILAND: GHS Status Classification: Physical hazard which is classified into 16 classes 1. Health hazard which is classified into 10 classes 2. Environmental hazard which is classified into 2 classes 3. Labelling: The basic elements on labels required in Thailand (B.E. 2555 Annex, Table 1) are to be consistent with the 3rd revised edition of the UN GHS SDS: English or Thai (follow the government form) Hazard Classification and Communication System of Hazardous Substances B.E. 2555 (2012): https://cdn.chemlinked.com/file/Notification_Thailand%20GHS.pdf 8
Malaysia GHS Department of Health and Safety (DOHS) Occupational Safety and Health (Classification, Labeling and Safety Data Sheet for Hazardous Chemicals) Regulation 2013 ["CLASS"] To replaces the CPL-Regulation of Hazardous Substances1997 Adopts 3 rd revision of UN-GHS Additionally, EHS Notification and Registration scheme (EHSNR) by DOE (Dep. Of Environment) GHS National Coordinating Committee (NCCGHS) GHS Technical Working Group (TWGGHS) Industrial Workplace Pesticides Transport Consumer Products (DOSH) (PB) (MOT) (MDTCC) 9
Malaysia GHS Certain chemicals are exempt from the requirements of the regulation, including: Radioactive materials 1. Scheduled waste 2. Cosmetics and drugs 3. Chemicals for the use of scientific research and development 4. Manufactured items not in the form of fluid or particle 5. Pesticides and chemicals in transit prior to export 6. 10
CLASS Regulation Gazetted on 11 th October 2013 Take effect on 12 th October 2013 Regulate the supply of hazardous chemicals for use at workplace Prescribe requirements for classification, packaging, labelling, SDS and inventory Introduce Principal supplier and subsidiary supplier Introduce duty of importer and manufacturer to submit inventory Submit an ONLINE inventory to DOSH http://www.lawbc.com/share/chemcon2014/Conference%20Handouts/3%20April%202014/Se ssion%208_topic%202.pdf 11
CLASS Regulation Partially harmonized with the GHS’s 3 rd revised edition and includes provisions on • Hazardous chemicals classification (part II); • Packaging (part III); • Labeling (part IV); • Safety data sheet (SDS) compilation (part V) • Inventory of Hazardous Chemicals (part VI); • Confidential business information (part VII) 12
CLASS Regulation Draft “Industry Code of Practice (ICOP)” is available The SDS shall be prepared in both the Malay and English languages Oct 11 th 2013 April 16 th 2014 April 17 th 2015 March 31 st 2016 CLASS 2013 gazetted ICOP 2014 gazetted Full compliance of First inventory CLASS 2013 submission 1 year transition 2013 2014 2015 2016 13
Environmentally Hazardous Subst. (EHSNR) The Department of Environment (DOE) is embarking on the Environmentally Hazardous Substances (EHS) Notification and Registration (N&R) Scheme The objective of the EHS N&R Scheme is to collect information from industry about the EHS that are imported and manufactured in Malaysia The data collected will be useful for risk assessment and management of EHS in the future EHS is defined as ‘substance that is included in the EHS reference list, or if not in the list, must be assigned a hazard category under the GHS classification scheme, as implemented by the Department of Occupational Safety and Health (DOSH) Malaysia ’ The EHS reference list is based on the Annex VI to the EU Regulation 1272/2008 on classification, labelling and packaging of substances and mixtures 14
EHSNR: under the Scheme Covers all substances not covered by other notification/registration schemes in Malaysia and present on the EHS fulfilling the criteria for classification as hazardous according to GHS, or until GHS is fully implemented, the classification according to the current classification requirements for chemicals in Malaysia Substances included in EHSNR: 1. Petrochemicals including plastic & resins 6. Industrial gases 2. Chemicals in fertilizers 7. Paints and paint products 3. Soaps and detergents 8. Basic industrial chemicals 4. Organic chemicals 9. Rubber industry chemicals 5. Oleo-chemicals 15
The Notification Process The Notification of EHS to DOE by chemical industries shall be done in 2 stages: Basic Notification : must first be made by all manufacturers & importers Detailed Notification: A follow-up detailed notification is also required, if the EHS is not the EHS Reference List The notification and registration shall be done on- line through the DOE’s official website at www.doe.gov.my 16
Difference between Basic and Detail Notification Basic Notification Detailed Notification 1. Substance Identification 1. Information required in the basic (CAS No., chemical name, EC No.) notification 2. Annual tonnage in metric tons 2. EHS identification (molecular formula, 3. Use of the substance molecular structure, molecular weight) 4. Concentration interval of substance in 3. Physico-chemical properties raw materials or finished products 4. Physical hazards (maximum & minimum concentration) 5. Health Hazards 5. Country of export 6. Environmental Hazards 7. Overall GHS classification 17
Proposed Road Map for EHSNR Scheme Decision - Advocacy - Enforcement Proposed regulation on controlling EHS Baseline data collected - Evaluate & analyze risk assessment - Identify the needs Establishing EHS Register (voluntary) Activities - Awareness/ Outreach - Develop skill in Risk Assessment - Assessment https://www.e-ehs.doe.gov.my/files/GUIDANCE_FOR_THE_INDUSTRY_3_final.pdf 18
Summary MALAYSIA CLASS-Regulation was published in October 2013 implementing GHS and a chemical inventory Environmentally hazardous substances should be notified within EHSNR (voluntary at the moment) (excluding pesticides … ) 19
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