About GHS

GHS is the Globally Harmonised System of Classification and Labelling of Chemicals.

The underlying idea is that if everyone in the world classifies and labels their chemicals for supply in the same way, it will be much safer for the end user, and also promote international trade in chemicals.

The UN have already brought in a system for classification of Dangerous Goods for Transport which has been adopted by nearly every country in the world, and they would like to see GHS being adopted in a similar way.

Version of GHS current in the EU

In the EU, GHS has been adopted through the CLP regulation, and the EU is currently using Revision 5 of GHS (2013) as the basis of CLP.  A copy of Revision 5 is available at: ST-SG-AC10-30-Rev5e

However, there is also GHS Revision 6 (2015): ST-SG-AC10-30-Rev6e , and GHS Revision 7 (2017): ST_SG_AC10_30_Rev7e .  Please note that there may be amendments to these GHS revisions, you should check the UNECE website at https://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html.

Problems with GHS and its implementation

Despite GHS being designed with good intentions, there are a number of problems with GHS and the way it is being adopted and implemented.

Firstly, Transport adoption is mandatory in all parts, with only limited scope for specific countries to change parts of it.  This is not the case with GHS, which can be adopted in part by individual countries or jurisdictions (like the EU).

Example: the EU has chosen not to adopt Flammable liquids and vapour category 4, H227, Flammable liquid and vapour, so this information does not appear on CLP labels.

Secondly, Transport adoption is mandatory in all parts of the world at the same time, so everybody is working on the same version at the same time.  However, under GHS, countries can adopt a version (“revision”) and not update it until they want to, which can lead to different countries working on different revisions, and there can be significant differences between their versions of GHS because of this.

Thirdly, most chemical classification systems have a set of mandatory classifications for chemicals which don’t conform to the normal classification rules, and can either be more hazardous or less hazardous than the rules would indicate.  For example, in Transport, mandatory classifications are given in the List of Dangerous Goods.

However, there is no mandatory list of classifications under GHS, although one has been proposed, see https://chemicalwatch.com/9871/un-to-pilot-global-list-of-ghs-classified-substances (a 2012 article), and the results of the pilot study were reported in 2016 and can be viewed here: http://www.oecd.org/chemicalsafety/risk-management/classificationandlabellingofchemicals.htm .  The process checked 3 substances, and found that a great deal of time and expert input was needed to achieve agreement.  Any list of mandatory GHS classifications is likely to be several years away, if not longer.

What this means is that individual countries are able to use their own mandatory classification list, which can lead to variations in chemical classification between GHS jurisdictions – the very situation GHS is supposed to prevent!

CLP does contain a list of mandatory classifications, see here: https://ttenvironmenta.wpengine.com/clp-knowledgebase/harmonised-classifications-under-clp .    Other jurisdictions with different lists of mandatory classifications include China and South Korea, among others.

Fourthly, GHS permits countries to add extra requirements to their own version of GHS, e.g. labelling information, leading to differences between labels and SDSs.  The EU have done this with CLP, and they have carried over some CHIP-only hazard descriptions.

The overall effect of the decisions to implement GHS in a piecemeal fashion is that it is “neither global, nor harmonised, nor really a system”, as a late friend of ours used to say.

GHS is not the only “parent” of CLP

The overall effect of how CLP has been written means that it has two parents, GHS and CHIP.

For information on the parts of CLP from GHS, see here: https://ttenvironmenta.wpengine.com/clp-knowledgebase/ghs-within-clp/ .

For information on the parts of CLP from CHIP, see here: https://ttenvironmenta.wpengine.com/clp-knowledgebase/chip-within-clp/ .

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