Since its first publication in 2003, over 50 distinct countries have adopted the Globally Harmonized System (GHS), which aims at standardizing the way chemical hazards are assessed and communicated. But because most GHS countries’ implementations incorporate adaptations and variations, the the dream of a single universal safety data sheet (SDS) or label for a given product has long been dispelled, and ignoring these differences in implementations can have serious adverse business consequences, according to a new white paper from IHS.
Variables of a country-specific GHS implementation could mean that the same end product may very well have different labeling depending on the country in which it is being marketed and sold. For example, limiting the number of precautionary phrases (or P-Phrases) is a variable that is different depending on country. In China, removing P-Phrases associated with hazards is strictly forbidden and they must all be shown on a label. In Europe and other countries, it is allowed and in cases even encouraged to remove selected P-Phrases, which are optional under certain conditions.
SDS requirements are different depending on the country, as well. In general, countries have embraced the 16 section format, but in some countries there are additional requirements to consider. In Malaysia, a safety data sheet must be provided in two languages. In Turkey, authors of the SDS must be certified by an accredited agency.
Consequences of not complying range from fines, citations, shipments being stopped at borders, and even imprisonment. Additionally, customers may refuse the products or turn to a competitor whose hazard documentation and labeling corresponds to their needs and expectations.
IHS product stewardship experts have received many requests for clarifications and knowledge sharing, the company says. It has created a white paper detailing a series of questions and answers meant to provide pragmatic guidance on some of the most important aspects of GHS variations and common issues.