Harmonised GHS List Project ‘at Crossroads’

The UN project to create a global list of harmonised GHS classifications is "at a crossroads", according to an internal paper prepared for discussion by the GHS sub-committee in December.

"The time has come for the sub-committee to make the fundamental decision about whether to move forward with the development of a global list," the paper says.

Industry has been interested in the idea, which aims to aggregate and, wherever possible, harmonise GHS classifications from different regions. Early indications from a poll set up by Chemical Risk Manager indicates overwhelming support for continuing the work, which several respondents note will simplify compliance to GHS.

However, the development process has been slow and is complex. One industry source, close to the work, notes: "In theory, the concept ‘one substance, one classification’ is great, but there are major hurdles ahead before reaching it. The pilot study has shown how difficult it is to derive a harmonised GHS classification for a specific substance. Further, the downstream legal consequences of such a list must be carefully assessed. That is, when a classification on such a list is diverging from a legally binding classification in a country or region."

The European Chemical Industry Council, Cefic, does not have a position on the issue.

"We are hoping for a positive outcome at the UN," says the OECD's Bob Diderich, whose team has been involved throughout the project. "I doubt that it can be picked up elsewhere. We worked at the OECD on the feasibility and the reasons for differences in classifications between countries. But we could never get our members interested in developing a harmonised list of classifications."

The next meeting of the GHS sub-committee is scheduled for 6-8 December.

Regional comparison

The informal correspondence group, working on the harmonised list, is currently comparing two significant regional lists of classifications, those based on:

> Annex VI of the EU's CLP Regulation; and

> Japan's GHS list agreed by the ministries for industry, environment and labour, which trigger activities under the Industrial Safety and Health Law (ISHL), and other regulations.

None of the 89 substances common to both lists has identical sets of classifications.

The GHS provides a comprehensive framework for UN member states, but it is not directly legally binding. Member states implement new versions locally according to their own schedules, meaning that, at any one time, two states are not necessarily operating under the same version.

Furthermore, states frequently deviate from the GHS during implementation, creating local discrepancies.

If the project goes ahead, the resulting classifications would not be legally binding.