Implementation of GHS in Japan Hiroshi SANO Technical Consultant Japan Chemical Database Ltd. Lecturer Dep. of Occupational Health and Toxicology KITASATO University 1 UN GHS Recommendation The Globally Harmonized System of Classification and Labelling of Chemicals : GHS so called “Purple book” Recommendation by : United Nations Economic and Social Council (UN ECOSOC), Committee of Experts on the Transports of Dangerous Goods and on the Globally Harmonized system of Classification and Labelling of Chemicals, Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals. First Ed. Jul. 2003 First Revised Ed. Jul. 2005 Second Revised Ed. Mar. 2007 (Revised every other year) Implementation of GHS in Japan 1. Activities for GHS implementation in Japan 2. GHS Model Classification Project 3. Revision of Industrial Safety and Health Law 4. Supporting tools for GHS implementation 5. GHS implementation, development hereafter 1. Activities for GHS implementation in Japan 4 Activities for GHS Implementation in Japan Government Industry Inter-ministerial committee JCIA & Japanese Standards Association Translation of UN Recommendation on GHS (1st Ver. Mar. 2004) (1st Rev. Mar. 2006) (2nd Rev. Mar. 2008) Revision of MSDS JIS Z 7250-2005 Issue of Labelling JIS Z 7251-2006 Issue of Classification JIS (Z 7252 -2009) Classification Manual Technical guidance for Classification (April, 2005) Model Classification of Regulated Chemicals Ministry of Health, Labour & Welfare JCIA Guidelines for Classification, Labelling, and Preparation of MSDS (May, 2005 – June, 2006) Amendment of Industrial Safety & Health Law (Effective in December, 2006) Companies GHS Classification of Products (single substances & mixtures) Preparation & Announcement of Model MSDS (July, 2006) Change Labels Revise MSDS Seminars on Preparation of SDS for Mixtures (December, 2005 – June, 2006) Model Classification of Non Regulated Chemicals 5 (April, 2007 --) Inter-Ministerial Committee on GHS (2001 - ) <Member> Ministry of Foreign Affairs (MOFA), Ministry of Internal Affairs and Communication (MIC), Ministry of Health, Labour and Welfare (MHLW), Ministry of Agriculture, Forestry and Fisheries (MAFF), Ministry of Economy, Trade and Industry (METI), Ministry of Land, Infrastructure and Transport (MLIT), Ministry of Environment (MoE), <Observer> Experts Japan Chemical Industry association (JCIA) Technical experts group of Inter- Ministerial Committee on GHS < Member > Experts from Government offices, Academia, National/public laboratories and Industries. 6 Translation of “GHS Recommendation Text” into Japanese: Supervised by the Inter-Ministerial Committee on GHS Available from the web-site of : MHLW : http://www.mhlw.go.jp/bunya/roudoukijun/anzeneisei07/index.html METI : http://www.meti.go.jp/policy/chemical_management/int/ghs_text.html MoE : http://www.env.go.jp/chemi/ghs/kariyaku2.html * It is very important and takes long time to harmonize the technical terminology in the Japanese GHS text, because there were several inconsistent uses of the terms among the Japanese laws. 1st revised version (Original text) (Mar. 2006) 2nd Edition (Mar. 2008) 7 “GHS Classification Manual” Classification manual is prepared under the supervision of the Inter-Ministerial Committee on GHS. Part 1 : Principle of classification Part 2 : Physical and chemical hazards Part 3 : Health hazards Part 4 : Environmental hazards This manual is prepared for the GHS model classification project of the Inter-Ministerial Committee on GHS. Use only reliable data sources for the classification of hazards, such as those peer-reviewed by international authorities. 8 “Technical Guidance Documents for GHS Classification” Technical Guidance Documents are prepared by the members of Technical experts group of Inter-Ministerial Committee on GHS. This guidance is used as supporting document of expert judgment, and complement for classification manual. “GHS Classification Manual” and “Technical Guidance Documents for GHS Classification” is available from the web-site of National Institute of Technology and Evaluation (NITE) : http://www.safe.nite.go.jp/ghs/ghsi.html (Japanese version) 9 Issue of Japanese Industrial Standard (JIS) by Japanese Standards association Revision of JIS Z 7250 - 2005 “Safety data sheet for chemical products – Part 1 : Content and order of sections” ( Dec. 2005 ) JIS for preparation of SDS based on GHS. Transition period up to end of 2010 Revision of JIS Z 7250- 2000 (based on ISO 11014-1-1994) Issue of JIS Z 7251 - 2006 “Labelling of chemicals based on GHS” ( Mar. 2006 ) JIS for preparation of Labels based on GHS. 10 Japanese Industrial Standard JIS Z 7250 - 2005 “Safety data sheet for chemical products – Part 1 : Content and order of sections” ( Dec. 2005 ) (Japanese version and English version) JIS Z 7251 - 2006 “Labelling of chemicals based on GHS” ( Mar. 2006 ) (Japanese version only) 11 Issue of “GHS Implementation Guidelines” based on JIS Z 7250 and JIS Z 7251 by Japan Chemical Industry Association Part 1: General guidelines Part 2: Safety Data Sheet Part 3: Labelling 12 2. GHS Model Classification Project 13 GHS Model Classification Project (1) Target chemicals: 1,500 substances under regulation of; - Industrial Safety and Health Law (MHLW) - Poisonous and Deleterious Substances Control Law (MHLW) - Law Concerning Reporting, etc. of Releases to the Environment of Specific Chemical Substances and Promoting (PRTR Law) (METI / MoE) Model classification according to - “GHS Classification Manual” and - “Technical Guidance Documents for GHS Classification” Classification work was performed by experts selected from laboratories and industries. Classification results were checked by the member of Technical experts group of Inter-Ministerial Committee on GHS, so as to eliminate any different classification results among experts. Finished classification work in two years (2005~2006) 14 Model GHS Classification project (2) Results of GHS Model Classification Project is available from the web-site of NITE : http://www.safe.nite.go.jp/ghs/index.html Results of GHS Model Classification are used for the base data of GHS classification of mixed compounds, or preparation of label and MSDS in industries. The classification results are not authorized by the government. The results of the project are not compulsive and allow industries to use their own data, and classify chemicals on the basis of their own judgement. The classification results are translated into English by METI. 15 Example of GHS model classification (a) Xylene CAS 1330-20-7 Hazard class [Physical Hazards] Classification Rational for the classification 1 Explosives Not applicable Containing no atom groups with explosive properties 2 Flammable gases Not applicable Classified as "liquid" according to GHS definition 3 Flammable aerosols Not applicable Not aerosol products 4 Oxidizing gases Not applicable Classified as "liquid" according to GHS definition 5 Gases under pressure Not applicable Classified as "liquid" according to GHS definition 6 Flammable liquids Category 3 The flashing points are 32℃ for o-xylene and 27℃ for m-xylene and p-xylene (ICSC 2002) (closed cup flash test), each of which is classified into Category 3 or Class 3 and Container II-III (UN Recommendations on the Transport of Dangerous Goods, UN#1307). 7 Flammable solids Not applicable Classified as "liquid" according to GHS definition 8 Self-reactive substances and mixtures Not applicable No atom groups with explosive or self-reactive properties 9 Pyrophoric liquids Not classified Not pyrophoric when in contact with air at ordinary temperatures: the flashing points are 463℃ for oxylene and 527℃ for m-xylene and p-xylene (ICSC 2002). 10 Pyrophoric solids Not applicable Classified as "liquid" according to GHS definition 11 Self-heating substances and mixtures Classification not possible Test methods applicable to liquid substances are not available. 12 Substances and mixtures, which in contact with water, emit flammable gases Not applicable Containing no metals or metalloids (B, Si, P, Ge, As, Se, Sn, Sb, Te, Bi, Po, At) 13 Oxidizing liquids Not applicable Organic compounds containing no oxygen, fluorine and chlorine 14 Oxidizing solids Not applicable Classified as "liquid" according to GHS definition 15 Organic peroxides Not applicable Organic compounds containing no "-O-O-" structure 16 Corrosive to metals Not classified Classified into Class 3 (UN Recommendations on the Transport of Dangerous Goods, UN#1307) Example of GHS model classification (b) Xylene CAS 1330-20-7 [Health Hazards (1)] Hazard class Classification Rational for the classification 1 Acute toxicity (oral) Category 5 Based on the rat LD50 (oral route) value of 3,500 mg/kg representing the lower of the two testing data, 3,500mg/kg (CaPSAR, 1993) and 4,300mg/kg (MOE Risk Assessment Vol. 1, 2002). 1 Acute toxicity (dermal) Classification not possible No definitive value available, although the substance can be classified as Category 5 or not classified based on the rabbit LD 50 (dermal route) value of >4,350 mg/kg, (IUCLID 2000). 1 Acute toxicity (inhalation: gas) Not applicable Due to the fact that the substance is "liquid" according to the GHS definition and inhalation of its gas is not expected. 1 Acute toxicity (inhalation: vapour) Not classified Based on the rat LC50 (4 hour inhalation exposure) value of 29.08 mg/L (MOE Risk Assessment Vol.1, 2002) (equivalent to 6,700ppm) was lower than 90% of the saturated vapor concentration (8,000ppm) under a saturated vapour pressure of 0.8 kPa (20℃), the substance was considered as "vapour containing substantially no mist" and was classified based on standard values expressed in ppm. 1 Acute toxicity (inhalation: dust, mist) Classification not possible No data available 2 Skin corrosion / irritation Category 2 Based on the description in the report on the rabbit skin irritation test (CERI-NITE Hazard Assessment No.62, 2004): "moderate irritant". 3 Serious eye damage / eye irritation Category 2A Based on the description in the report on the rabbit eye irritation test (CERI-NITE Hazard Assessment No.62, 2004): "moderate irritant". 4 Respiratory/skin sensitizer Respiratory sensitizer: Classification not possible Skin sensitizer: Classification not possible Respiratory sensitizer: No data available Skin sensitizer: No data available 5 Germ cell mutagenicity Not classified Based on the negative data on human multi-generation epidemiological studies and somatic cell mutagenicity tests in vivo (micronucleus/chromosome tests) and the absence of data on heritable mutagenicity tests, germ cell mutagenicity tests in vivo and germ cell genotoxicity tests in vivo, described in CERI-NITE Hazard Assessment No.62 (2004), CaPSAR (1993), IARC (1999) and NTP DB (Access on December 2005). 6 Carcinogenicity Not classified Due to the fact that the substance is classified as Category A4 by ACGIH (2001) and Group 3 by IARC (1999). 17 Example of GHS model classification (c) Xylene CAS 1330-20-7 [Health Hazards (2)] Hazard class Classification Rational for the classification 6 Carcinogenicity Not classified Due to the fact that the substance is classified as Category A4 by ACGIH (2001) and Group 3 by IARC (1999). 7 Toxic to reproduction Category 1B Based on the evidence of weight reduction and hydrocephalus in foetuses at dosing levels not toxic to parent animals in mouse developmental toxicity tests, described in CERI-NITE Hazard Assessment (No 62, 2004), EHC 190 (1997) and IRIS (2003). 8 Specific target organs/systemic toxicity following single exposure Category 1 (respiratory organs, liver, central nervous system, kidneys) Category 3 (narcotic effects) Based on the human evidence including "throat irritation, severe pulmonary congestion, alveolar hemorrhage, pulmonary edema, congestion accompanying hepatomegaly, centrilobular vacuolation of hepatocytes, nerve cell damage associated with dot hemorrhage, swelling and disappearance of Nissl bodies, limb cyanosis, a transient increase in serum transaminase activity, an increase in the blood level of urea, a decrease in endogenous creatinine clearance in the urine, liver damage, severe kidney damage, amnesia, coma" (CERI-NITE Hazard Assessment No.62, 2004) and "pulmonary congestion, pulmonary edema, focal alveolar hemorrhage" (MOE Risk Assessment Vol.1, 2002) and the evidence from animal studies including "strong narcotic effect (EHC 190, 1997). The basis for the classification includes data on xylene with unknown composition or containing other substances (ethyl benzene, toluene, etc.). 9 Specific target organs/systemic toxicity following repeated exposure Category 1 (respiratory organs, nervous system) Based on the human evidence including "eye/nose irritation, thirst" (DFGOT Vol. 15, 2001) and "chronic headache, chest pain, abnormal electroencephalogram, dyspnea, cyanosis of the hands, fever, a decrease in WBC count, discomfort, impairment of pulmonary function, a decrease in working capacity, physical/mental disorders" (CERI-NITE Hazard Assessment No.62, 2004). The basis for the classification includes data on xylene with unknown composition or containing other substances (ethyl benzene, toluene, etc.). 10 Aspiration hazard Category 2 Based on the description in ICSC(J)(2002) regarding o-xylene, m-xylene and p-xylene: "May cause aspiration and chemical pneumonia if swallowed". Xylene CAS 1330-20-7 [Environmental Hazards ] Hazard class Classification Rational for the classification 1 Harzardous to the Aquatic Environment (Acute) Category 2 Fish (rainbow trout) 96hr LC50 = 3.3mg/L (CERIJ-NITE RAR, 2005); --> category 2 2 Harzardous to the Aquatic Environment (Chronic) Category 2 Low rapid biodegradability (39%, CERIJ Hazard Data Report, 2005), Estimated low bioaccumulation (log Kow = 3.16), and Acute category 2; --> category 2 18 3. Revision of Industrial Safety and Health Law Partial amendment of “Industrial Safety & Health Law” (Decided by the Cabinet on November 2, 2005) Improvements of Labels and Document Communications for Chemical Substances based on GHS classification criteria, label contents, SDS format. (Date of Enforcement) This law was put into force from December 1, 2006. (Penalty) The person who violate the provisions regarding labelling shall be punished with a penal servitude not exceeding six months or with a fine not exceeding 500,000 yen ( = RM17,000). 20 Revision of Industrial Safety and Health Law (Labelling) Article 57. A person who is to transfer or provide substances explosive, combustible, and flammable and other substances which are liable to cause dangers to workers which are liable to inflict health impairment upon workers, shall, as provided for by Ministry of Health, Labour and Welfare Ordinance, label the container or the package. (Material Safety Data Sheet) Article 57-2. A person who is to transfer or provide substances which are liable to cause dangers to workers or inflict health impairment upon workers shall notify the party to whom the notifiable substances are to be transferred or provided, of the following matters by means of delivering a document or other manner prescribed by Ministry of Health, Labour and Welfare Ordinance. [ Number of chemicals targeted under ISH Law ] Labelling MSDS 99 640 21 4. Supporting tools for GHS implementation 22 “GHS Classification Working Sheet” Prepared for classification work of the Technical experts group of Inter-Ministerial Committee on GHS. Workshops by Japan Industrial Safety and Health Association (JISHA) How to classify chemicals especially mixed compounds, according to GHS criteria and to make labels and SDSs under GHS requirements. (Nov. 2005 – Jun. 2006) The module of Workshop by JISHA - Introduction of GHS and principle of revised Industrial Safety and Health Law (2 hrs) - Physical hazard classification (1.5 hrs) - Health hazard and Environmental hazard classification (2 hrs) Workshops at 26 places in the whole country, and more than 3,000 participants totally. 24 Pamphlet and Web-site (1) Ministry of Environment http://www.env.go.jp/chemi/ghs/ [MoE GHS Pamphlet ] [MoE GHS Web-site] 25 Pamphlet and Web-site (2) Ministry of Health, Labour and Welfare http://www.mhlw.go.jp/topics/bukyoku/roudou /ghs/index.html [Poisonous & Deleterious Substances Control Law Pamphlet ] [Industrial Safety & Health Law Pamphlet ] [MHLW GHS Web-site] 26 Pamphlet and Web-site (3) Ministry of Economy, Trade and Industry http://www.meti.go.jp/policy/chemical_management/int/ghs.html [MWTI GHS Web-site] [PRTR Law Pamphlet ] 27 Model Labels and MSDSs by Japan Industrial Safety and Health Association (JISHA) Model Labels and MSDS according to the results of GHS model classification project. • Model Labels for 100 substances under ISH Law: http://www.jaish.gr.jp/anzen/gmsds_label/label_index.htm (in Japanese) • Model MSDSs for 700 substances under ISH Law: http://www.jaish.gr.jp/anzen_pg/GHS_MSD_FND.aspx (in Japanese) 28 [JISHA GHS Web-site] http://www.jaish.gr.jp/user/anzen/kag/kag_main01.html [JISHA Model Label] [JISHA Model MSDS] Classification software for Mixtures Development of computer software for GHS classification of mixture, installed with the classification results of 1500 chemicals. Only 3 steps ; 1. Input GHS classification results of substances, 2. Input the percentage of substance in mixture, 3. Get the classification of the mixture. Software is available from the site below (in Japanese) http://www.meti.go.jp/policy/chemical_management/GHS/land%20of%20thousand %20of%20GHS%20classification.htm 30 Educational publication (Books & CD-ROM) “Challenge of GHS” Supervision: Dr. Jonai Coauthor : Jonai, Sano, Noguchi The Chemical Daily (2006) “Guidebook on Preparation of Labels and MSDS, complying with GHS system ” Author: Sano The Chemical Daily (2007) “GHS-Education CD-ROM” with narration for an employer to educate workers. Supervision: Dr. Jonai (Based on GHS 1st rev. available both in Japanese and English) (2006) “GHS Q&A” Coauthor: Jonai Miyagawa Morita The Chemical Daily (2008) 31 5. GHS implementation, development hereafter 32 a) Classification of Non Regulated Chemicals Japan Industrial Safety and Health Association (JISHA) started GHS model classification of Non-regulated chemicals under the financial support of MHLW. 1,500 chemicals in two years (2008 – 2009) Japan Chemical Industry Ecology-Toxicology & Information Center (JETOC) started GHS model classification of the chemicals listed in SIDS Report (OECD Screening Information Data Set) using the data in SIDS Report . 200 chemicals (2004 – 2008) . classification work will continue ! 33 b) Issue of New Industrial Standard Standardization of GHS classification method is considered to be suitable to clarify the ambiguity of the “Purple Book”, with decision of Japanese policy on “Building block approach” and “Cut-off limit value”. New “GHS Classification JIS” will be issued as “JIS Z 7252 – 2009” in early next year. 34 c) Classification Manual for Mixture Classification manual for mixture will be issued under the supervision of the METI Sub-committee on GHS Classification Manual. This manual will be prepared based on new “GHS Classification JIS”, and will be issued in early next year. 35 d) The electronic bulletin board for GHS (J-Chemipedia) Trial establishment of the electronic bulletin boards for GHS classification with the data source of comments to the GHS classification results. http://www.ghs-net.jp/ METI Technical comment for initial data Experts 2016/3/23 Offer for board and initial data Reference for data and comment Companies 36 1. Select the substance to modify in the list 4. Vote on trust in the comment, and display the result of vote 2. Select the classification to modify and insert the comment 3. Display the classification and the comment 37 e) Risk-based labelling for consumer products (1) The decision to adopt risk-based labelling for consumer products. GHS Inter-Ministerial Committee (Jan. 2007) http://www.meti.go.jp/policy/chemical_management/GHS/Consumer_product _labelling.htm “Outlook on Risk Assessment for Consumer Products Based on Exposure for GHS Labeling” GHS Inter-Ministerial Committee (Jan. 2007) (in English) http://www.meti.go.jp/policy/chemical_management/03kanri/risk_based_lab el_interministrial080218set.doc 38 e) Risk-based labelling for consumer products (2) The guidance documents of risk-based labelling for consumer products. National Institute of Technology and Evaluation (NITE) http://www.safe.nite.go.jp/ghs/risk_consumer.html “Guidance for implementation the GHS of consumer products” (Draft) Guidance documents for the implementation of the GHS in collaboration with Asian countries. Japan Soap & Detergent Association (JSDA) 39 f) Application of GHS to chemical risk management (1) Use GHS system as the tools of hazard communication in chemical risk management. GHS will lead to: - Logical classification of hazards of chemicals, - Domestic harmonization of diverse regulations. Raising awareness on chemical hazards. Sharing a responsibility of chemical control with the people to use it. 40 f) Application of GHS to chemical risk management (2) Use GHS classification results as the means of hazard rating in risk assessment of hazardous chemicals. UK HSE: COSHH ESSENTIALS - Easy steps to control health risks from chemicals. (use EU R-phrase for hazard rating) http://www.coshh-essentials.org.uk/ UN ILO: Control Banding - Practical Tools for Controlling Exposure to Chemicals. (use EU R-phrase and GHS classification for hazard rating) http://www.ilo.org/public/english/protection/safework/ctrl_banding /index.htm US NIOSH: Control Banding - Qualitative Risk Characterization and Management of Occupational Hazards. (use OEL and R-phrase for hazard rating) http://www.cdc.gov/niosh/topics/ctrlbanding/ 41 f) Application of GHS to chemical risk management (3) Use GHS classification results as the means of hazard rating in risk assessment of hazardous chemicals. Japan Industrial Safety and Health Association (JISHA) JISHA Method Chemical Health Risk Assessment (use EU R-phrase and GHS classification for hazard rating) Hazard Group EU R-Phrases A R36, R38, R65, R66 All dusts and vapours not allocated to another band Acute toxicity, any route, category 5. Skin irritation category 2 or 3. Eye irritation category 2. All dusts and vapours not allocated to another band. B R20/21/22, R40/20/21/22, R33, R67 Acute toxicity, any route, category 4 STOT (single exposure), any route, category 2. C R23/24/25, R34, R35, R37, R39/23/24/25, R41, R43, R48/20/21/22 Acute toxicity, any route, category 3. STOT (single exposure), any route, category 1. Skin corrosion class 1A, 1B or 1C. Eye damage category 1. Respiratory tact irritation. Skin sensitization. STOT (repeated exposure), any route, category 2. D R48/23/24/25, R26/27/28, R39/26/27/28, R40 Carc. Cat. 3, R60, R61, R62,R63, R64 Acute toxicity, any route, category 1 or 2. Carcinogenicity category 2. STOT (repeated exposure), any route, category 1. Reproductive toxicity category 1 or 2. E R42, R45, R46, R49, R68 Germ cell mutagenicity category 1 or 2. Respiratory sensitization . GHS Classification (Hazard class / Hazard category) Carcinogenicity category 1. 42 Terima Kasih ! Arigato-gozaimashita! 43