1. Summary of status of the GHS regional implementation
Regional Project “Evaluating and Strengthening National and Sub-regional Capacities for Implementing the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) and Supporting SAICM Implementation in Central and Eastern Europe (CEE)”
Dr. Suzana Andonova
Regional GHS CEE Project Consultant

2. Introduction
This report presents the results of a survey conducted to assess the status of implementation of Globally Harmonized System of Classification and Labelling of Chemicals (GHS) in the CEE countries and the needs of each country in the Region for prompt introduction and better implementation of GHS. The results of the assessment will serve as a basis for drafting the strategy for GHS implementation in the CEE Region.

3. Material and methods
A questionnaire comprised of 28 questions was prepared.
All the questions were relevant to the issues related to GHS implementation in the countries.
All the National Focal points were contacted and were invited to respond to the questions.
A cross tabulation and data results dispersion methods were used to analyse and summarise the responded questionnaires.
Personal communication and desk research for other countries.

4. General Feedback
Among 24 countries invited to fill in the questionnaires, in total 12 responses were received:
Invited countries
Responding Countries
Albania
Armenia
Azerbaijan
Belarus
Bosnia and Herzegovina
Bulgaria
Croatia
Czech Republic
Estonia
Georgia
Invited countries
Responding countries
Hungary
Kosovo
Latvia
Lithuania
Republic of Macedonia
Montenegro
Republic of Moldova
Poland
Romania
Russia
Serbia
Slovakia
Slovenia
Ukraine

5. List of the contact points in the respondent countries
Country
Contact Point
Name
Title/ Responsible Institution
Kosovo
Violeta Lajqi-Makolle
Senior Officer for chemical management/ Ministry of Environment and Spatial Planning-MESP
Moldova
Liudmila Marduhaeva
Main Advisory Officer /Ministry of Environment
Serbia
Aleksandra Zujic
International Cooperation and Projects Coordinator/ Serbian Chemicals Agency
Croatia
Biserka Bastijančić-Kokić/ Nenad Lamer
Ministry of Health, Directorate for Sanitary Inspection
Albania
Lindita Tafaj
SAICM Focal Point/ Institute of Public Health
Macedonia
 Marin Kocov
SAICM National Focal Point/POPs&Ozone Unit/MoEPP
Belarus
Irina Ilyukova
Liliya Najaran
Republican Scientific Practical Centre of Hygiene
Russia
Makarova Anna Sergeevna
Institute of Chemistry and Sustainable development( РХТУ им.Д.И.Менделеева)
Bulgaria
Hristina Filipova
Chief Expert/Ministry of environment and water
Poland
Mariusz Godala
Szymon Domagalski
Bureau for Chemical Substances
Hungary
Gabriella Füle
Ministry of Rural Development
Romania
Liliana Luminita Tirchila
SAICM National Focal Point/MINISTRY OF ENVIRONMENT and FORESTS

6. Survey findings Q1 Level of development of chemical industry
Q1.Status of development of chemical industry in CEE countries
Q2.Source of chemical products
Country
Q1 Level of development of chemical industry
Q2 Source of chemical products
developed
Least
Needs additional
development
Well
Highly advanced level
Domestic production
Imported products
Manufacture /processing of imported bulk/raw chemicals
Kosovo
Moldova
Serbia
Croatia
Albania
Macedonia
Belarus
Russia
Bulgaria
Poland
Hungary
Romania

7. Q3. Current legal and policy frameworks assessment
Among 12 countries, 4 Countries assessed the current legal and policy frameworks 4 did not do so and the remaining 4 are in process of assessment of the legal policy framework.

8. Q4. Status of implementation of the MEAs
Stockholm Convention
Yes -Albania, Belarus, Bulgaria, Croatia, Hungary,, Republic of Macedonia, Republic of Moldova, Poland, Romania, Russia and Serbia /Armenia, Ukraine, Georgia, EU member states in CEE Region
No – Kosovo,
Montenegro and Bosnia and Herzegovina (at initial phase)
Basel Convention
Yes-Belarus, Bulgaria, Croatia, Hungary,, Republic of Macedonia, Republic of Moldova, Poland, Romania, Russia and Serbia/Armenia, Ukraine, Georgia, EU member states in CEE Region, Montenegro and Bosnia and Herzegovina (at initial phase)
No- Kosovo, Albania (not implemented)
Rotterdam Convention
Yes-Albania, Belarus, Bulgaria, Croatia, Hungary,, Republic of Macedonia, Republic of Moldova, Poland, Romania, Russia and Serbia/Armenia, Ukraine, Georgia, EU member states in CEE Region
No-Kosovo, Azerbaijan,
SAICM
Yes-Albania (initial phase), Belarus, Bulgaria, Croatia, Hungary,, Republic of Macedonia, Republic of Moldova, Poland, Romania, Russia and Serbia/Armenia, Ukraine, Georgia, EU member states in CEE Region
No-Kosovo, Azerbaijan,Montenegro, Bosnia and Herzegovina

9.   Q5. Integrated SAICM objectives in relevant programs, plans and/or strategies at various levels
Out of total 12 countries, only Kosovo and Belarus have not integrated the SAICM objectives into a country relevant strategic program, plan or strategy.
SAICM objectives are integrated into the EU Regulations REACH and CLP and are acting into all EU Countries.

10. Q6. Status of GHS implementation in CEE countries

11. Inter-ministerial or inter-institutional coordination body
Q7a. Inter-ministerial or inter-institutional coordination arrangements to facilitate the sound management of chemicals / GHS implementation in CEE Region
Country
Inter-ministerial or inter-institutional coordination body
Albania
Committee for pesticide registration, committee for biocides. ToR have been prepared for an Inter-sectorial Committee for Chemicals Management (Safety)
Belarus
Yes
Bulgaria
Croatia
Hungary
Kosovo No
Macedonia
National Inter-ministerial Working Group for chemical management comprised by the
representatives from the Ministry of Environment, Finance-Customs Administration, Health,
Agriculture, Crisis management Centre, Poisoning Centre
Moldova
National Inter-ministerial Working Group, mandated to implement the
Chemical MEAs, SAICM and National Programme on Sound Management of
Chemicals
Poland
Romania
Russia
Yes/CIS
Serbia
Serbian Chemicals Agency, Ministry of infrastructure and energy and Ministry of Agriculture, Trade, Forestry and Water Management *

12. Q7b,c&d
National Governmental authority/agency responsible for the GHS implementation
Government agencies that should be involved for GHS implementation in the country
Ministries/agencies in the country ready to implement and maintain the GHS
All listed in the Annex 1 of the report.

13. Q8.Level of awareness on GHS
Level of awareness on GHS in CEE Region
Country
Very low
Medium
High
Kosovo
Moldova
Serbia
Croatia
Albania
Macedonia
Belarus
Russia
Bulgaria
Poland
Hungary
Romania

14. Q9. What are the obstacles to implement the GHS in countries?
No sufficient human resources/capacities and expertise.
Lack of financial resources to properly implement GHS.
Lack of system for integrated chemicals and hazardous substances information was very common for the twelve surveyed CEE countries.

15. Q10. GHS Implementation in the transportation sector
All the CEE countries have relevant Law on transportation for dangerous goods that are in accordance with the based on the UN Recommendations for the Transport of Dangerous Goods(Model Regulations which is in accordance with GHS).
Some of the countries stated some additional regulation concerning the transportation (Albania)

16. Q11. Has your country already conducted any basic/initial training course for GHS introduction/ implementation

17. Q12. How will stakeholder cooperation and support for implementing the GHS be managed
Many different views and approaches as well as understandings. …To be discussed during the workshop/working groups…

18. Q13A. Current status of GHS implementation- Sector transportation
Country
Current status of GHS implementation- Sector transport
No action taken
Situation analysis prepared or under preparation
Preparing for revising related legislation/ administrative procedures
Preparing for establishing new legislation/ administrative procedures
Already implementing GHS
Other
Kosovo
Moldova
Serbia
Croatia
Albania
Macedonia
Belarus
Russia
Bulgaria
Poland
Hungary
Romania

19. Q13B/C Current status of GHS implementation- Sector Industry & Consumer products
Country
Current status of GHS implementation- Sector Industry & Consumer products
No action taken
Situation analysis prepared or under preparation
Preparing for revising related legislation/ administrative procedures
Preparing for establishing new legislation/ administrative procedures
Already implementing GHS
Other
Kosovo
Moldova
Serbia
Croatia
Albania
Macedonia
Belarus
Russia
Bulgaria
Poland
Hungary
Romania

20. Q13D Current status of GHS implementation- Sector Agriculture/Pesticides
Country
Current status of GHS implementation- Sector Agriculture/Pesticides
No action taken
Situation analysis prepared or under preparation
Preparing for revising related legislation/ administrative procedures
Preparing for establishing new legislation/ administrative procedures
Already implementing GHS
Other
Kosovo
Moldova
Serbia
Croatia
Albania
Macedonia
Belarus
Russia
Bulgaria
Poland
Hungary
Romania

21. Q14. Is there a mandatory requirement to translate GHS into the national language(s)?

22. Q 15 a. Interesting topics to be discussed during the Regional workshop, according to the country needs
Country
Interesting topics to be discussed during the Regional workshop
Organizational structure needed for implementation of GHS/CLP
Needs for Capacity building to be prepared for GHS introduction
Full introduction of GHS or by sectors (Building Block Approach)
Introduction of GHS Versus CLP in some countries
Kosovo
Moldova
Serbia
Croatia
Albania
Macedonia
Belarus
Russia
Bulgaria
Poland
Hungary
Romania

23. Additional topics of interests:
Information on related activities under Agreements on Association with EU(Moldova);
Cooperation among countries in the Region for proper implementation of GHS/CLP (Macedonia);
Training of population and other relevant stakeholders (Russia);
Small and medium-sized enterprise involvement and difficulties by introducing GHS (Hungary).

24. Q16. Availability of financial resources for national/regional capacity building activities towards GHS implementation

25. Q17. Activities completed or planned for GHS implementation
Situation/ Gap Analysis
Comprehensibility Testing
Impact Study and/or Cost Benefit Analysis
First Draft of the Implementation Instrument
Consultation with Stakeholders
Development of a GHS National Implementation strategy
Final Adoption of the Implementation Instrument
Training courses for GHS implementation
Kosovo /
Moldova
Serbia
Yes No
Croatia
Albania
Macedonia
Belarus
Yes/ 2008
Yes/2011
Yes/
Yes/
Russia
Bulgaria
Poland
Hungary
Romania

26. Industrial / Workplace Agriculture / pesticides
Q18. Sectors covered by the National regulation regarding GHS, Edition used (Rev, 2, 3,4)
Transport
Industrial / Workplace
Consumer products
Agriculture / pesticides
Other
Kosovo /
Moldova
Serbia
Yes/Rev 3
Croatia
Albania
Macedonia
Yes No
Belarus
Yes/ SMGS
Yes/ GOST
Yes/GOST
Russia
Bulgaria
Yes/Rev2
Yes/Rev 2
Poland
ADR
Hungary
Romania

27. Q20. Transitional period in place for GHS implementation

28. Q21. Are all GHS hazard classes implemented for the sectors that are covered
Only Serbia, Bulgaria, Poland, Hungary and Romania answered to this question.
“According to CLP only hazard categories that are not part of CLP are :
•“flammable liquids category 4”,
•“acute toxicity category 5”,
•“skin corrosion/irritation category 3”,
•“aspiration hazard category 2”
• “acute aquatic toxicity category 2 and 3”

29. Q22. Are GHS safety data sheets (SDS) accepted in your country today?
Safety Data Sheets accepted
Yes No
In process
Kosovo /
Moldova
Serbia
Croatia
Albania
Macedonia
Belarus
Russia
Bulgaria
Poland
Hungary
Romania

30. Q23. Difficulties encountered in preparing the SDS due to lack of facilities and capabilities
Belarus: Lack of trained specialists, Absence of GLP laboratories, Legislation gaps.
Russia: Lack of data. Different interpretation of existing data, Problems of reliability and Data inconsistencies.
Serbia: One of the biggest problems is lack of data for classification of substances which are not in the
List of classified substances or are not classified for all hazard classes.
Very important problem for the downstream users (formulators) is the bad quality of SDS of imported substances.
Also, there is a lack of capabilities for preparing SDS, especially in small and medium enterprises.

31. Q24. Support the cooperation and information exchange among the countries in the region for better implementation of GHS
All countries support the cooperation and exchange of information in the frames of the CEE Region. Hungary: HelpNet Steering Group Bulgaria: The country is open to provide expertise and take part in CLP training seminars Poland: In 2011 Inspector for Chemical Substances implements three projects co-financed by the Polish aid program of the Ministry of Foreign Affairs (Armenia, Georgia and Moldova). Russia: Through TAIEX instruments

32. Accredited GLP laboratories
Q25. Existing accredited laboratories on GLP and cooperation with any relevant (Q26)
Accredited GLP laboratories
Cooperation with GLP
Croatia
Developing such practice
Macedonia
1. Public health Institute-State owned
2. Tehnolab-Private /
Poland
Hungary
National Institute of Chemical Safety, state owned
Every GLP laboratory develops collaboration with other laboratories on their own
Romania
Private institution
It is not necessary, proposals for testing are controlled by ECHA and tests methods are governed by Regulation 440/2008 under REACH, indirectly OECD methods

33. Q27. Regional institution that coordinates the GHS implementation at regional level
Slovenian Chemicals Bureau
Swedish Chemical Agency
GOST Standard
European Chemical Agency(ECHA)

34. Q28. Specific problems indicated in implementing the GHS
Country
Indicated specific problems
Belarus
Lack of political will, Legislation gaps,
No Register of chemicals, No Law on chemicals
Croatia
Lack of staff and time
Georgia:
Inconsistent approach to classification of chemicals and distribution of the information on hazards; Necessity of introduction of GHS (Ref. National Chemical profile, 2009)
Hungary
Lack of human resource, quantitative and in expertise; Financial needs;
Particularly small and medium-sized enterprises have the above mentioned difficulties
Poland
In European Union GHS is implemented by CLP Regulation. According to the CLP Regulation each country has to establish: Competent Authority, Enforcement authority, National Helpdesk to provide advice to manufacturers, distributors, downstream users and other interested parties, Body responsible for receiving information relating to emergency health response.
The main problem usually is concerning with division of responsibilities and preparing some changes in national law (very long process in Poland)
Serbia
In certain cases where there is no other way to have access to data necessary for classification, and when it will be necessary to perform experimental testing in compliance with GLP principles, the problem for our industry will be where to perform those tests and the cost of these testing

35. Thank you for participating to this survey
Dr. Suzana Andonova
Regional GHS CEE Project Consultant