1 Globally Harmonized System of Classification and Labelling of Chemicals (GHS): U.S. Update

2 Key U.S. Agencies *Environmental Protection Agency * Office of Pesticide Programs (OPP) * Office of Pollution Prevention and Toxics (OPPT) *Occupational Safety and Health Administration (OSHA) *Department of Transportation (DOT) *Consumer Product Safety Commission (CPSC) Core interagency group coordinates GHS activities and positions for international meetings State, US Trade Rep, Commerce also play a role in international and interagency consultations

3 U.S. Implementation Planning Tasks Comprehensive comparison with existing practices Selection of “building blocks,” resolution of label format and placement issues Information systems support needed Internal and external outreach, input Decisions on implementation mechanism(s) Consideration of transitional issues Coordination within USG and internationally

4 What are the implications of GHS for pesticide programs? Implementation could affect all pesticide labels Pesticide users and handlers need to understand the new labels Regulations and policies related to classification categories need review International harmonization efforts may be affected (e.g., NAFTA label)

5 What should be harmonized (currently regulated by OPP) Classification criteria for physical hazards, health hazards, and aquatic toxicity, for substances and mixtures Certain standardized label elements: hazard pictograms, signal words, and hazard statements [Product and supplier identifiers, precautionary statements]

6 OPP Next Steps Work with stakeholders to address concerns, continued outreach and awareness-raising (public stakeholder meeting October 18-19) Interagency coordinating process Coordination with NAFTA and OECD pesticides groups Consideration of newer elements of the GHS (e.g., aspiration hazards) and work at the global level to avoid “moving target”

7 GHS Public Stakeholder Meeting: Meeting Goals Clarify scope and potential application of GHS to pesticide labels Examine key issues raised in public comments Gain better understanding of stakeholder concerns, explore ways to address them Assess potential paths forward to maximize benefits and minimize costs

8 OPPT Implementation of GHS -Currently examining whether to implement environmental labeling on existing chemicals. - OPPT does not currently require environmental labeling on existing chemicals so GHS implementation is optional GHS will need to be implemented for new chemicals, since labeling is already required

9 OSHA Update Completed comprehensive comparison of requirements with GHS and guide to GHS Added GHS to regulatory agenda (5/05) Advance Notice of Proposed Rulemaking, opportunity for public input on implementation issues, published September 12 (deadline for comments 13 November) U.S. delegation to GHS Sub-Committee NAFTA partner discussions, workshop, EU HPV pilot

10 DOT Update Long history of harmonization with work of UN TDG Sub-Committee, North American counterparts Existing transport system used in developing GHS Changes needed to align DOT rules with GHS Aquatic toxicity Acute toxicity Category 3 Flammable aerosols, liquids Revised pictogram for organic peroxides Aerosol changes complete, expect most other changes by 2007, allowing one year transition to meet 2008 goal (aquatic tox on separate track)

11 CPSC Update Staff has begun preparing for implementation; formal Commission decision required to implement Developing comparison of GHS with existing requirements Continuing participation in OECD work to refine GHS Coordinating within USG and internationally on implementation Will be considering use of GHS criteria to classify for health and physical hazards, risk option in GHS for labeling

12 For more information: * GHS text, UN papers and reports * EPA GHS information htm * OSHA GHS information html * DOT GHS information

13 For more EPA information: EPA/OPP White Paper, comparison document, Q’s & A’s: Public Comments: EPA Docket OPP at objectId=0b0007d4802cc6e6 (or, quick search “globally” in edocket) OPP Contacts: Mary Frances Lowe Deborah McCall