DR. MIKE MOFFATT, Ph.D. Director of Communications, Nexreg Compliance Inc. Regulatory International Influences The only constant with GHS is change......................................................................................... After months of waiting, Canada is moving again on implementing the Globally Harmonized System of Classification & Labeling of Chemicals (GHS). It is still months away from having a final version of the Controlled Products Regulations in place, but much closer than it was even two months ago. There were significant references to GHS in both the federal budget, which was released on February 11, and the budget Implementation Act, which was introduced for first reading in the House of Commons on March 28. The February 11 budget document is available for download at: http://www.budget.gc.ca/2014/home-accueileng. html. It contains a number of references to chemical regulations, including this section on regulatory cooperation between Canada and the U.S.: Broad progress has been made in implementing commitments from the Canada-U.S. 2011 Regulatory Cooperation Council Action Plan, with initiatives addressing four main regulated sectors: agriculture and food, transportation, health and personal care products, and the environment. Examples of progress include alignment of a number of vehicle safety standards, joint reviews of pesticides and veterinary drugs, use of the Globally Harmonized System of Classification and Labeling of Chemicals and the development of a common electronic submission gateway for pharmaceutical products. I recently asked a senior government official what the future may hold for GHS-based regulatory cooperation between Canada and the U.S. He indicated that there is room for “tighter” cooperation in the future, which may occur when both countries modify their respective GHS regulations as new revisions of the GHS guide, known as the Purple Book, are released. These may include, but are not limited to, joint comment periods (where a company could send one set of comments in, simultaneously, to both sets of regulators) and harmonized release dates for regulations. The government official stressed that this would not mean that the regulations would be wholly harmonized 26 SPRAY June 2014 as each country has unique issues that they would need to address in regulation. However, when there were differences in regulations, it would be a deliberate act because of circumstances unique to the country, not because regulators did not consult each other during the regulatory process. I am cautiously optimistic that this will mean tighter harmonization of regulations in the future and not just for safety data sheets (SDS) and workplace labels. In Canada, the first budget document contains information on the government’s priorities for the upcoming year. The actual What is the GHS? The GHS is an acronym for The Globally Harmonized System of Classification and Labeling of Chemicals. . The GHS is a system for standardizing and harmonizing the classification and labeling of chemicals. It is a logical and comprehensive approach to: • Defining health, physical and environmental hazards of chemicals • Creating classification processes that use available data on chemicals for comparison with the defined hazard criteria • Communicating hazard information, as well as protective measures, on labels and Safety Data Sheets (SDS) Many countries already have regulatory systems in place for these types of requirements. These systems may be similar in content and approach, but their differences are significant enough to require multiple classifications, labels and safety data sheets for the same product when marketed in different countries, or even in the same country when parts of the life cycle are covered by different regulatory authorities. This leads to inconsistent protection for those potentially exposed to the chemicals, as well as creating extensive regulatory burdens on companies producing chemicals. For example, in the United States (U.S.) there are requirements for classification and labelling of chemicals for the Consumer Product Safety Commission, the Department of Transportation, the Environmental Protection Agency, and the Occupational
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