Christine Lepisto looks at the differences and special requirements of the many international versions of GHS labels.
Seeing the term “GHS”, the Globally Harmonized System of classification and labelling, raises visions of simplicity and consistency. Perhaps finally one label with a couple of translations suffices to accompany a chemical product on its journey through global commerce?
In reality, the GHS, as adopted by the Competent Authorities of various countries and regions, can require very different labels. Employees handing chemicals in global commerce need to know what differences arise and what special requirements must be met for labels under regional implementations of the globally harmonised system.
What GHS labels have in common
The UN GHS does establish standards aimed at ensuring that workers across the planet will receive sufficient and comprehensible information about the hazards of and precautions for using chemicals. The following information will be found on all GHS labels.
Because the label elements for each hazard class are prescribed by the UN GHS standard, a great improvement in label consistency will be achieved. This simplifies training of workers and communication of hazards between remote geographical divisions of global companies.
Why GHS “harmonised” label elements differ
Although the elements of labelling are harmonised, many circumstances contribute to a lack of harmony in the information that appears on the same chemical product when labelled in different countries. Three main inconsistencies stand as obstacles to hopes for a truly harmonised system.
Governments publish lists to harmonise the substance classifications for their country or region. But these lists can differ significantly. Take 2,4-dinitroaniline (CAS 97-02-9), for example; its classification for acute oral toxicity is listed as category 2 (Fatal if swallowed) in Europe, category 3 (Toxic if swallowed) in Korea, and category 4 (Harmful if swallowed) in Japan. A skull and crossbones, with the signal word “Danger” appears on labels in Europe or Korea, while Japan will display the exclamation mark and “warning”.
The UN GHS system allows countries to adopt different rules for classifying mixtures. For example, a mixture with 0.1% of a chemical classified as a category 2 reproductive toxin will be labelled as a reproductive toxin under US OSHA’s version of GHS. But in Europe, the mixture can contain up to 3% of the same reprotoxic ingredient before the product is labelled as a reproductive toxin.
Different regions adopt different “building blocks” of the UN GHS. For example, a product that is merely toxic (ie category 2, not category 1, very toxic) to the aquatic environment with no long term effects would be labelled as such in China but not labelled in Europe or the USA.
Unfortunately, many of the efficiencies (and savings) companies hoped to realise under GHS remain elusive due to this state of affairs. There is hope that a UN-led substance list can ameliorate the first issue, but the resistance of the Competent Authorities to either reduce their current standards of protection or to adopt a worst-of-all-cases scenario will continue to block the path to true chemical hazard harmony.
Special GHS label requirements
The regulations in various jurisdictions establish requirements that go beyond the basic elements of the UN GHS. Companies complying with the UN GHS need to be aware that a simple GHS label may not meet all of the requirements for placing their product on specific markets. Furthermore, training programs for employees working within each jurisdiction should address the special labelling requirements to which employees will be exposed.
Below, we look at the main requirements specific to some of the key jurisdictions in the chemicals industry.
European CLP labels
In Member States of the European Union, GHS goes under the acronym CLP (ie the Regulation on Classification, Labelling and Packaging of substances and mixtures).
The CLP retains substantial portions of the older European legislation, the Dangerous Substances Directive and Dangerous Preparations Directive, which are not addressed in the UN GHS system. Thus, a European GHS label may have statements like “Reacts violently with water” or “Repeated exposure may cause skin dryness or cracking” which must appear in the supplemental information section. However, these hazards may not be considered by the person creating labels in another country. (In best practice, such hazards will be mentioned in s.2.3 of the SDS in any region as additional information or “hazards not otherwise classified” and may also appear in the supplemental information section of labels outside of the EU).
Two statements that appear especially often on EU labels are:
EUH208, “Contains [name of sensitising substance]. May produce an allergic reaction.” This supplemental labelling statement appears for sensitisers contained at quantities between one tenth of the classification threshold and the classification threshold.
the second amendment of CLP requires this statement even when the mixture is classified as sensitising due to another ingredient present above the threshold quantity.
EUH210 , “Safety data sheet available on request.” This statement appears on the label if a mixture is not classified as hazardous according to CLP, but it contains hazardous substances above the exception threshold.
Another major difference in the appearance of a European label stems from the part of the CLP stating that “normally, not more than six precautionary statements shall appear on the label, unless necessary to reflect the nature and the severity of the hazards.” Thus, labels in other jurisdictions may have long lists of advice for a product with several hazards, but the EU label will show a smaller set of precautionary statements. The lack of precise guidance on how to cut the long list back to “not more than six” also implies that labels may differ for products with the same hazards, depending on the manufacturer’s best judgments.
GHS labels in Asia-Pacific
Like most jurisdictions, China has not set a specific label format — but the Chinese standard GB 15258-2009 does require a black border line on the outside edges of the label. Inside that black border line, specific Chinese elements will be found.
The percentage or percentage range of ingredients contributing to the hazards of a mixture must be shown on the label, typically for up to five components.
An emergency telephone number of a company located in China must appear on the label.
The label must remind the user to “Please refer to the Safety Data Sheet”.
Japanese and Korean labelling requirements for GHS follow the general guidelines of the United Nations’ model Purple Book fairly closely. However, both nations have an extremely complex range of additional regulations that affect labelling. When shipping chemicals to be placed on these markets, care must be taken that labels show hazardous ingredients in compliance with specific laws on toxic or priority substances, and special labelling statements may be required by other laws as well.
Australia and Singapore have published regulations very similar to Europe’s CLP and labels on chemicals arriving from these countries will appear very similar to European labels.
US OSHA GHS labels
Companies making US OSHA GHS labels must be prepared to print four health hazard pictograms instead of three, although printing of the environmental pictogram is voluntary as OSHA does not regulate for environmental hazards. While most countries allow the exclamation mark to be removed when the skull and crossbones is displayed, thereby ensuring that never more than three of the four health hazard pictograms appear simultaneously, US OSHA edited the GHS precedence provision as follows.
If the skull and crossbones pictogram is included, the exclamation mark pictogram shall not appear where it is used for acute toxicity.
Therefore, an exclamation mark assigned due to skin or eye irritation, sensitisation, or specific target organ toxicity effects must still appear on the US OSHA label but will not appear for Europe, China, Japan, Korea, or other jurisdictions.
US OSHA has also stated that it will be amending the Hazard Communication Standard prohibition in Appendix C.2.3.3 so that DOT transport diamonds and the corresponding GHS pictogram (ie where both display the same symbol graphic) may both be shown on the container — something that should generally not happen under 188.8.131.52.1 of the UN GHS standard (see figure 1). In any case, especially on single receptacles, the mix of transport labels and GHS pictograms should be reviewed in assessing a product’s hazards.
The non-harmonised application of the UN harmonised system is probably here to stay, certainly for many years. Companies can eliminate some redundancy using the harmonised elements of GHS, but should stay attentive to the fact that label requirements remain subject to local and regional differences.
Last reviewed 27 March 2013