CHEMSAFETYPRO NEWSLETTER May 2016: China RoHS 2 vs EU RoHS 2

As China is close to adopting its upgraded China RoHS regulation (China RoHS 2), we feel it necessary to look into this new regulation and compare it with EU RoHS 2.

• China RoHS 2 vs EU RoHS 2: Similarities and Differences

4 New Chemicals Listed under the Stockholm and Rotterdam Conventions and Their Impacts
28 May 2015
Let's take a look at those 4 newly added chemicals and analyze their potential impacts on your business. A complete list of candidate chemicals is also given.  Read more.. 

K-REACH's Leniency Program Is Now Official!
26 May 2015
According to Chemical Watch (subscription required), Korea is giving 6 months (May~Nov 2015) for companies who failed to notify new substances under TCCA in the past. 

Two New GHS Quizzes Launched (Pass Rate 60% and 10% Respectively).
13 May 2015
We have launched two new GHS quizzes (regular level and advanced level) to test your knowledge of GHS. You can take the anonymous quizzes here.

5 Free Underutilized Chemical Regulatory Tools You Should Know
11 May 2015
Here are 5 free tools that we think are among the most underused but very helpful tools for checking chemical regulatory lists and chemical safety data. Read more.

How to Find Occupational Exposure Limits (OELs) for Chemical Substances?
6 May 2015
This article will help you understand different types of occupational exposure limits and teach you how to find them easily. Read more...

A Comparison of NFPA, HMIS and HCS Labelling System in the United States
4 May 2015
Are you confused with various chemical hazard rating and workplace labelling system in the United States: NFPA, HMIS, and HCS/GHS? You may find it helpful to read this comparison.

China is close to adopting new RoHS regulation (China RoHS2)

18 May 2015, the Chinese Ministry of Industry and Information Technology (MIIT) published its final draft version of the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products for public consultations. The consultation ends on 17 June 2015.

This new China RoHS regulation is known as China RoHS 2. As China is close to adopting its upgraded China RoHS regulation (China RoHS 2), we feel it necessary to look into this new regulation and compare it with EU RoHS 2.

http://www.chemsafetypro.com/Topics/Restriction/China_RoHS_2_vs_EU_RoHS_2.html

Free Guide on International Chemical Conventions

There are many international chemical conventions restricting or even banning the production, use and trade of certain hazardous chemicals for the purpose of protecting human health and the environment.

We have prepared a guide on major international chemical conventions with a focus on their aims, controlled substance list, control measures and their impacts.

Note: You do not need to read all chemical conventions because some of them are not relevant to your business. The table below shows you how to identify which chemical conventions you shall read.

Table of Content

• Stockholm Convention on Persistent Organic Pollutants (POPs);
• Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade;
• Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal;
• Montreal Protocol on Substances that Deplete the Ozone Layer;
• Minamata Convention on Mercury;
• Chemical Weapons Convention (CWC);
• The United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances;
• ILO’s Chemicals Convention concerning Safety in the use of Chemicals at Work;
• Strategic Approach to International Chemicals Management (SAICM);

- See more at: http://www.chemsafetypro.com/Topics/Convention/international_chemical_conventions.html

Newsletter Vol 5 2015: 4 Changes and 5 Facts about the New Catalogue of Hazardous Chemicals in China

Source: http://www.chemsafetypro.com/

You may have already heard a lot of interpretations of the new Catalogue of Hazardous Chemicals in China recently. If you are still confused and would like to know more, you are encouraged to spend a few minutes reading our version. 

• 4 Changes and 5 Facts about the New Catalogue of Hazardous Chemicals in China

How Are Existing Chemicals Regulated by Types and Lists in China?
13 April 2015
If you think that having all your substances listed on IECSC means compliance with Chinese chemical regulations, then you are wrong. Lots of existing chemicals such as hazardous chemicals, chemical weapons precursors and drug precursor chemicals are also subject to registrations, reporting and production, import and export control. Read more...

Tips on Searching Japan ENCS
8 April 2015
If you find it difficult to search the Japan existing chemical substance inventory ENCS, you may get some tips here. 

Original Report: A Comparison of Global GHS Label Size Requirements 2015
24 March 2015
Many countries have set minimum GHS label size requirements for chemical packages with different packaging capacities. Some countries have even set additional requirements on GHS pictogram size and even font size. Read more...

GHS Quiz Result Summary & Some Clarifications
24 March 2015
Over 300 people have taken our GHS quiz in the past month. Less than 5% of people have scored more than 80%. Less than 20% of people have scored more than 60%. 

If you failed in this quiz, please do not get disappointed. Some questions are designed to be confusing to make this quiz difficult. You are the GHS experts as long as you can find some arguments to support your choices.

ChemSafetyPro Newsletter Vol. 3 - March 2015

On 19 Feb 2015, the Ministry of Industry in Thailand published its new regulation B.E. 2558 on the notification of the production and import of hazardous substances in Government gazette. The regulation comes into force immediately.

The regulation requires manufacturers and importers of hazardous chemicals supplied in quantities over 1 ton per year to notify their hazardous chemicals to the Department of Industrial Works (DIW) for the purpose of building a national chemical inventory in Thailand. We have taken a deep look at this new regulation and translated B.E.2558 and notification form into English to give you a quick understanding of its regulatory requirements. 

• New Chemical Regulations in Thailand: Chemical Inventory Notification Starts.

More News & Updates from CHEMSAFETYPRO

A GHS Quiz That 80% of People Fail.
24 Feb 2015
We have designed a quiz to determine whether you are a GHS expert or not. This anonymous and free quiz usually takes less than 5 mins (10 questions in total). Take the quiz here. Please note that this quiz is not suitable for beginners. If you could pass this test (80% score), please join us because there is nothing about GHS we can share now.

A Great TDG Guide That You Cannot Miss. 
17 Feb 2015
Are you looking for a TDG guide full of pictures and examples? This is the guide you need that could save your time on learning the UN Model Regulations on the Transport of Dangerous Goods.

How to Calculate German Water Hazard Class (WGK)?
13 Feb 2015
Lots of people have asked us about how to calculate German Water Hazard Class (WGK) for chemicals supplied to Germany because the WGK is usually required in the section 15 of SDSs. We have prepared an easy step-to-step guide to address this issue. 

What Changes to Expect from GHS Rev. 6?
13 Feb 2015
GHS Purple Book is updated every two years. This year is the year for GHS Rev.6. The Committee of Experts on TDG and GHS of the UNECE has published a report on the agreed amendments to the 5th revised edition of GHS. Read more.

How to Comply with Swiss Chemical Regulations
13 Feb 2015
Since Switzerland is not a member of the EU or the European Economic Area (EEA), EU REACH regulation does not apply here. Switzerland has its own chemical regulation Chemical Ordinance (ChemO) adopting REACH-like registration requirements (on new substances only). For those who supply chemicals (i.e, adhesives, solvents) and articles to Switzerland, it is also highly recommended that you read Swiss Chemical Risk Reduction Ordinance (ORRChem) which sets chemical restriction conditions for lots of chemicals and articles.

"Did you know that we are a mobile device friendly website? Please feel free to click all links above on your phone or tablets to take a look."  - Mr Little Pro.

New Chemical Regulation in Thailand: Notification of Hazardous Substances

Thailand has just published a new  chemical regulation B.E. 2558 on the notification of the production and import of hazardous substances in Government gazette. The regulation comes into force on 19 Feb 2015.

Manufacturers and importers of hazardous substances exceeding 1 ton per year are now required to notify their hazardous substances to the Department of Industrial Works (DIW) via DIW's online system. The notification shall be submitted within 60 days from the date of manufacture or importation (only once). 

K-REACH and EU REACH Comparison

2015 is a key implementation year for K-REACH. This is just another new important REACH-like chemical regulation which is not strange to many of us who have dealt with EU REACH regulation before. Despite many similarities, K-REACH and EU REACH are different in many aspects. In this article, we have compared the top 10 differences between K-REACH and EU REACH to help you understand K-REACH's regulatory requirements better.

K-REACH and EU REACH Comparison

http://www.chemsafetypro.com/Topics/Korea/Difference_between_K-REACH_and_EU_REACH.html

Changes in GHS Rev. 6

The 6th revised edition of GHS (GHS Rev. 6) is about to be published soon in 2015.  The UNECE has recently published a report on the agreed amendments to the 5th revised edition of GHS. The report summarizes what changes are going to be included in GHS Rev. 6.

Please click the following link for more info about GHS Rev. 6.
http://www.chemsafetypro.com/Topics/GHS/Changes_in_6th_revised_edition_GHS_rev_6.html

Related GHS Info & Resources

• GHS in EU/CLP
• GHS in Switzerland
• GHS in USA
• GHS in Canada
• GHS in Turkey
• GHS in Brazil
• GHS in China
• GHS in Korea
• GHS in Japan
• GHS in Taiwan
• GHS in Singapore
• GHS in Indonesia
• GHS in Malaysia
• GHS in Thailand
• GHS in Vietnam
• GHS in Philippines
• GHS in New Zealand
• GHS in Australia
• GHS in Other Countries

A Global Survey on GHS Pesticide Labels

It is generally expected that the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) will be adopted for pesticides. The biggest impact of GHS on pesticides will be pesticide classification and product labels due to the introduction of chemical classification criteria and GHS labelling elements. While GHS has been adopted for hazardous chemicals in workplace by a significant number of countries, many of them still follow the FAO Guidelines on Pesticide Registration and the FAO Guidelines on Good Labelling Practice for Pesticides (rather than GHS) to carry out pesticide hazard classification and prepare pesticide labels.

In this article, we have analyzed how GHS may impact pesticide labelling and classification and analyzed the current situation of GHS adoption in pesticides sector in 2015.

- See more at: http://www.chemsafetypro.com/Topics/GHS/GHS_for_pesticides.html

Canada Issues WHMIS 2015 Implementing GHS in Workplace

Canada modified its Workplace Hazardous Materials Information System (WHMIS) to incorporate the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) for workplace chemicals. 

Manufacturers or importers will be required to classify and label hazardous chemicals in accordance with the new GHS-based hazard communication system (called WHMIS 2015) from 1 June 2017. In this article, we have analyzed chemical classification, labelling and SDS requirements in WHIMS 2015 and compared it with OSHA's Hazard Communication Standards (HCS 2012) in the United States.

Transitional Periods of WHMIS 2015/Canada GHS

GHS will be implemented in Canada in three phases. Different deadlines apply to manufacturers/importers, distributors and employers. The picture below summarizes the transitional period for the implementation of WHMIS 2015.

- See more at: http://www.chemsafetypro.com/Topics/Canada/Canada_GHS.html

GHS Update Report 2015

2015 is destined to be a busy year for GHS - the Globally Harmonized System of Classification and Labelling of Chemicals. In this article we have summarized key GHS implementation dates in 2015 and what to expect next.

Europe GHS 2015

• Key date: 1 June 2015;
• All mixtures have to be classified and labelled in accordance with EU CLP regulation/GHS since above date;
• GHS for substance: already implemented;

USA GHS 2015

• Key date: 1 June 2015;
• All mixtures have to be classified and labelled in accordance with OSHA's Hazard Communication Standard 2012 since above date;
• Distributors can sell hazardous mixtures with old labels until 1 Dec 2015;
• GHS for substance: already implemented;

Turkey GHS 2015

• Key dates: 1 June 2015 & 1 June 2016;
• 1 June 2015: All substances have to be classified and labelled in accordance Turkish CLP regulation after this date;
• 1 June 2016: GHS implementation deadline for mixture;

Malaysia GHS 2015

• Key dates: 17 April 2015 & 1 Jan 2016;
• 17 April 2015: GHS implemented for both substances and mixtures after this date;
• 1 Jan 2016: Notification of inventory of hazardous chemicals supplied in the quantity of 1t/y or above starts.

Philippine GHS 2015

• Key date: 14 March 2015;
• GHS implementation deadline for both substances and mixtures in workplace;

Taiwan GHS 2015

• Key dates: 26 Jan 2015 & 1 Jan 2016;
• 26 Jan 2015: GHS Rev. 4 chemical classification criteria implemented;
• 1 Jan 2016: Full GHS implementation for all hazardous chemicals with physical and health hazards.

What to Expect Next

• 2015: Adoption of GHS in Canada;
• 2015: New Zealand's Revision of HSNO Act;
• 30 March 2016: Vietnam's adoption of GHS for mixture;
• 13 March 2017: Thailand's adoption of GHS for mixture;

- See more at: http://www.chemsafetypro.com/A_Busy_Year_for_GHS_2015.html

Related GHS Info & Resources

• GHS in EU/CLP
• GHS in Switzerland
• GHS in USA
• GHS in Canada
• GHS in Turkey
• GHS in Brazil
• GHS in China
• GHS in Korea
• GHS in Japan
• GHS in Taiwan
• GHS in Singapore
• GHS in Indonesia
• GHS in Malaysia
• GHS in Thailand
• GHS in Vietnam
• GHS in Philippines
• GHS in New Zealand
• GHS in Australia
• GHS in Other Countries

GHS for Dummies

This is a post for beginners who wish to have a quick understanding of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). 

Original Source: http://www.chemsafetypro.com/UN_GHS_Chemicals_GHS_for_Dummies.html

GHS for Dummies by ChemSafetyPRO

The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is a system developed by the United Nations for standardizing and harmonizing the classification and labelling of chemicals globally. More specifically, the UN GHS Document (known as the UN GHS Purple Book):

• Defines physical, health and environmental hazards of chemicals and harmonizes classification criteria;
• Standardizes the content and format of chemical labels and Safety Data Sheets.

The UN GHS is updated frequently and the latest version was the 5th revised edition released in 2013.

As a voluntary international system, the GHS is not legally binding in any country. Therefore, countries adopting GHS have to issue their own regulations or standards to implement GHS criteria and provisions. Two examples are:

• The EU CLP REGULATION (EC) No 1272/2008 on Classification, Labelling and Packaging of Substances and Mixtures;
• OSHA's Hazard Communication Standard (HCS) 2012 in the United States;

Benefits of GHS Adoption

Compared to pre-GHS hazard communication, GHS offers better protection to workers and users and facilitates international chemical trade.

In pre-GHS era, users may see different label warnings or safety data sheet information for the same chemical, which can cause confusion. In addition to that, most of countries have their own hazard classification and labelling regulations in pre-GHS era. Those regulations vary significantly and compliance with them is very costly and time-consuming.

GHS Hazard Class, Hazard Category and Hazard Pictogram

GHS describes the nature and severity of a chemical hazard by hazard class and hazard category. GHS also assigns standard pictograms representing different types of hazards.

• Hazard class: the nature of a chemical hazard, i.e., flammable liquids, carcinogen.
• Hazard category: the division of criteria within each hazard class. For example, flammable liquids have 4 categories among which flammable liquids category 1 represents the most severe hazard.
• Hazard pictogram: 9 pictograms conveying different types of health, physical and environmental hazards;

The picture below shows the type of chemical hazards each GHS pictogram represents:

GHS Classification

GHS classification is a process to determine the hazard class and category of a chemical (substance or mixture) in accordance with GHS hazard classification criteria.

The picture below is an example of GHS classification criteria for flammable liquids. A liquid with a flash point between 23 and 60 Celsius degrees will be classified as flammable liquid category 3. A liquid with a flash point above 93 Celsius degrees does not meet GHS classification criteria and will not be regarded as a hazardous chemical.

Classification Determines Labelling Elements

Once a chemical has been classified according to GHS classification criteria, you can easily find assigned signal word, pictogram, hazard statements and precautionary statements that need to be included on labels and in SDSs. 

For example, a liquid with a flash point between 23 and 60 Celsius degrees will be classified as flammable liquid category 3. By checking the page 316 of above document, you can easily find out the core labelling elements for this liquid:

• Signal word: Warning;
• Pictogram: Flame;
• Hazard statement: H226 flammable liquid and vapour;
• Precautionary statement: P210, P233, P280, P303+P361+P353, P370+P378, P403+P235, P501;

How to Classify Substances and Mixtures under GHS

Classification is very important but not easy. For substances, you need to have test data to carry out classification. Luckily you do not need to test every substance. Many countries or regions have published compulsory or advisory GHS classification lists for pure substances. You can directly refer to those classifications for your substances without doing the tests.

The most well-known GHS classification list is the annex VI of EU CLP regulation. It includes compulsory GHS classifications for thousands of substances.

For mixtures, you may take advantages of abridging principles or calculation methods or concentration limits to classify them.

GHS Label

The core elements of a GHS label include:

• Product identifier: Chemical identities of a substance or hazardous ingredients in a mixture;
• Supplier identification: The name, address and telephone number of a supplier;
• Signal word: Danger or Warning;
• Hazard pictogram: conveying different types of chemical hazards;
• Hazard statements: standardized and assigned phrases that describe the hazard(s) as determined by hazard classification;
• Precautionary statements: standardized phrases that describe measures to minimize or prevent adverse effects;

An example of a GHS label for a chemical can be found below:

- See more at: http://www.chemsafetypro.com/UN_GHS_Chemicals_GHS_for_Dummies.html

Chemsafetypro Newsletter Vol 2 Feb 2015

ChemsafetyPRO Newsletter - Feb 2015

Taiwan Implements GHS Rev. 4 This Week

8 Feb 2015
You could know more than that. Read more about Taiwan GHS and the revised CNS 15030 Classification and Labelling of Chemicals.

Taiwan's Existing Chemical Substance Inventory Now Has An Official Name TCSI.

5 Feb 2015
The Ministry of Labor has officially called Taiwan's existing chemical substance inventory TCSI. Do you like this name?

Are You Looking for Good GHS Tutorials?

3 Feb 2015
Please give this GHS Guide a try if you do not wish to read thousands of pages in UN GHS Purple Book.

Do You Know Thailand's Hazardous Substances Act?

28 Jan 2015
We have prepared a short summary to help you understand how chemicals are regulated in Thailand. Read more...

Japan New Substance Notification: CSCL vs ISHL

28 Jan 2015
Double registration makes Japan's new substance notification difficult to understand. We would like to say no to this by comparing the differences between CSCL and ISHL. Read more...

Canada DSL and NDSL

Canada Domestic Substances List (DSL) is an inventory of approximately 23 000 substances manufactured in, imported into or used in Canada. Substances on DSL do not require new substance notification unless they are subject to a "significant new activity" regulation.

Non-domestic Substance List (NDSL) contains substances that are not on the DSL but are listed on TSCA inventory in the United States. There are more than 58 000 entries in NDSL. Substances that are not on the DSL but are listed on the NDSL are subject to new substance notification with reduced requirements.

Like TSCA inventory, both DSL and NDSL have two parts: public and confidential portion. The public portion of DSL and NDSL can be searched via the link below. Please be noted that this engine does not work well with substance names.

• Search Canada DSL/NDSL

To search the confidential section of DSL/NDSL, you may submit a Notice of Bona Fide Intent to Manufacture or Import to Environment Canada.

How to Comply with DSL/NDSL Requirements?

Before you export any substance (on its own or in a mixture) to Canada, it is crucial that you determine whether the substance to be exported to Canada is listed on the DSL or on the Non-domestic Substances List (NDSL). Substances that are not listed on DSL will be regarded as new substances and need to be notified. Please be noted that small volume of new substances are exempt from new substance notification in Canada unless their quantities have reached volume trigger.

• Canada New Substance Notification Exemption and Requirements

Significant New Activity

Significant new activities can apply to existing substances on the Domestic Substances List or to new substances. A significant new activity is an alternative use of a substance or other activity that results or may result in:

• a significantly greater quantity or concentration of the substance in the environment; or
• a significantly different manner or circumstances of exposure to the substance.

If there is a suspicion that a significant new activity may result in the substance becoming toxic, the substance can be subject to a Significant New Activity Notice. The Notice communicates the criteria under which the government must be re-notified. The government assesses the new information on the substance to determine if it is toxic in relation to the significant new activity.

View the List of Substances Subject to Significant New Activity Notice

Source http://www.chemsafetypro.com/Topics/Canada/Canada_DSL_Domestic_Substance_List_NDSL.html

Canadian Environmental Protection Act (CEPA) and New Substance Notification in Canada

The Canadian Environmental Protection Act 1999 (CEPA 1999) is the most important chemical control law in Canada. It is a broad act covering a number of subjects, i.e., chemicals, living organisms, marine environment, vehicles, and hazardous wastes. In this article, we will only talk about how it manages new chemical substances and existing chemicals in Canada.

New Substances Management

Substances that are not on the Domestic Substances List (DSL) are considered to be new chemical substances in Canada. Any company or individual who plans to import or manufacture a new substance must provide Environment Canada with a New Substances Notification (NSN) dossier to import or manufacture. Substances that are not on the DSL but are listed on the Non-Domestic Substance List (NDSL) are subject to new substance notification with reduced requirements.

The type of information required and the timing of the notification will depend on such factors as the type of substance (chemical substance, polymer or bio-chemical), the quantity of the substance, the intended use of the substance and the circumstances associated with its introduction.

The risks of substances determined to be or suspected of being toxic or capable of becoming toxic may be managed, as necessary, through conditions or prohibitions imposed on their import or manufacture.

New Substance Notification Exemptions and Requirements

Articles, impurities, by-products, naturally occurring substances and chemical substances regulated by other Canadian laws are exempt from the new substance notification requirements. For a mixture, the notification requirement only applies to individual substances in it.

New substances in small volumes do not require notification unless they reach the volume triggers specified by the CEPA. Compared to regular new substances, new substances on the DSL and polymers are subject to reduced information requirements. The review time needed is also shorter.

The picture below shows the volume trigger for different types of new substances and required information:

Detailed information required for each notification schedule can be found here.

Existing Substances Management

CEPA 1999 includes specific requirements for the assessment and management of substances currently existing in commerce or being released to the environment in Canada. The Minister of the Environment and the Minister of Health jointly assess existing substances. The picture bellow shows how it works (source: Environment Canada).

The risks of priority existing substances are controlled by various regulatory lists:

• Significant New Activity;
• Priority Substances List;
• Toxic Substances List;
• Virtual Elimination List;
• Export Control List;

- See more at: http://www.chemsafetypro.com/Topics/Canada/Canada_Environmental_Protection_Act_New_Chemical_Notification.html

EC Inventory: EINECS, ELINCS and NLP

European Inventory of Existing Commercial Chemical Substances (EINECS), European List of Notified Chemical Substances (ELINCS) and No-longer Polymers (NLP) List are 3 very important chemical inventories in Europe. Substances listed in EINECS/ELINCS/NLP are deemed as phase-in or existing substances in Europe and they can enjoy extened registration deadlines until 2018 if they were pre-registered under the EU REACH regulation. Substances that are not listed on the three lists shall be registered immediately before they can be be manufactured or imported into EU.

The ECB's system ESIS http://esis.jrc.ec.europa.eu/ has stopped working. To access EINECS, ELINCS and NLP and find an EC number for your substance, you may click the link below provided by ECHA.

• http://echa.europa.eu/information-on-chemicals/ec-inventory

More info about the 3 inventories can be found below:

European Inventory of Existing Commercial Chemical Substances (EINECS)

This inventory includes chemical substances deemed to be on the European Community market between January 1, 1971 and September 18, 1981.

European List of Notified Chemical Substances (ELINCS)

This inventory consists of all chemical substances notified within the European Community after 18 September 1981. The finalized ELINCS was issued in 2009 and includes 5,292 notified substances in total.

No-longer Polymers (NLP) List

This is a list of substances which were previously considered to be polymers and later did not meet polymer criteria due to the change of definition of polymer in 1992. Thus the No-longer Polymers (NLP) list was drawn up, consisting of such substances that were commercially available between 18 September 1981 and 31 October 1993.

- See more at: http://www.chemsafetypro.com/Topics/EU/EU_Chemical_Inventory_EINECS_ELINCS_NLP.html