In this edition of the Weekly Compliance Digest, we cover the publication of new and revised GHS classifications for 179 substances in Japan by the National Institute of Technology and Evaluation.
FY2016: GHS Classification Results by MHLW, METI and MOE
What is it?
On July 25, 2017, Japan’s National Institute of Technology and Evaluation (NITE) published new GHS classifications for 84 substances and revised GHS classifications for 95 substances. The classifications were conducted by relevant Japanese Ministries in accordance with GHS Classification Guidance for the Japanese Government, and are intended to provide a reference for preparing Safety Data Sheets (SDSs) and labels for chemical products placed on the Japanese market by domestic or foreign manufacturers, suppliers or distributors.
Why is GHS not harmonized?
The UN’s Globally Harmonized System for Classification and Labeling of Chemicals (GHS) is adopted and implemented by individual countries. There are different revisions of GHS published every 2 years (the 7th revision came out recently) and countries are not all on the same revision. Also, under the GHS “building block” concept, countries can decide which hazard classes and categories to use. As a result, each country has its own “adaptation” of GHS, even though classification rules, pictograms, and hazard and precautionary statements are the same. In addition to their own national adaptations of GHS, some jurisdictions, such as Japan, have also developed lists of GHS classifications for substances, to facilitate the creation of compliant SDSs and labels for substances and mixtures.
What is mandatory and voluntary in Japan?
In Japan, GHS-compliant SDSs and labels are mandatory for chemicals regulated by the Industrial Safety and Health Law (ISHL), the Pollutant Release and Transfer Register (PRTR) Law, and the Poisonous and Deleterious Substances Control Law (PDSCL). In addition to the mandatory regulations, Japan also published national standards (JISZ 7252 and 7253) for SDSs and labels. These standards are not mandatory, but companies have a obligation to “make a reasonable effort to comply”.
The GHS classifications of substances published by NITE are conducted by the Ministry of Health, Labour and Welfare (MHLW), the Ministry of Economy, Trade and Industry (METI) and Ministry of the Environment (MOE). The new and revised classifications are not mandatory, but many regulatory experts still recommend GHS SDSs and labels for these substances.
What steps should be taken?
These suggested steps should be taken as a result of the publication of the new and revised GHS classifications for the 179 substances:
1) Screen your product portfolio to verify whether you market any of the 179 substances, either on their own or as part of mixtures.
2) For all products identified in the previous step, verify whether they are placed on the Japanese market and whether they have Japanese SDSs and labels.
3) Update all Japanese SDSs and labels identified in the previous step.
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