Status of GHS Implementation In Malaysia Ministry of Interntional By Sri Ram Letchimanan Ministry of Interntional Trade & Industry

OUTLINE Why is GHS important GHS Implementation in Malaysia (Roadmap) UNITAR-GHS Project Impact of GHS in Malaysia Challenges of GHS Implementation

Why is GHS Important Before GHS After GHS Laws and regulations similar and yet differences are significant enough to cause confusion Different labels or SDS for the same product in different countries Different definitions of hazards, e.g. a chemical may be considered flammable in one country, but not in another. Laws to include GHS elements understood and practiced all over the world One labelling and SDS criteria practiced internationally One definition of hazards information, acceptable

Malaysia’s Chemicals Industry Sub-sectors Source: MITI Structure of Chemicals Industry Chemicals & Chemical Products Petroleum Products & Petrochemicals Agricultural chemicals, pesticides & fertilizers Soap, detergents, cosmetic & toiletry preparations Inorganic chemicals Industrial gases Paints, varnishes Oleo-chemicals Plastic Products Organic Chemicals Plastic resins

GHS “Setup” in Malaysia Industrial Workplace (DOSH) Pesticides (PB) Transport (MOT) Consumer Products (MDTCC) GHS National Coordinating Committee (NCCGHS) GHS Technical Working Group (TWGGHS)

GHS “Setup” in Malaysia (continued) Project Coordination Committee (PCC) Chaired by: MITI Facilitate and coordinate all activities under the project Preparation of PCC meetings Present overall progress of the project in PCC Prepare periodic status report National Coordinator Financial Official: MITI (Finance) Approve and sign all financial statements and budget requests associated with the project

GHS Implementation In Malaysia Malaysia is committed to GHS implementation; Currently reviewing and ensuring the existing laws and legislations pertaining to the control chemical substances, in the related sectors are in line with the GHS implementation as introduced in the “Purple Book”; Identified and addressing sectoral issues (situational and gap analysis) ; Organized training and capacity building programs for parties involved in control of chemical substances in each sector; and Increasing awareness on the benefits of regulatory harmonization

GHS Implementation Roadmap in Malaysia The GHS Implementation Roadmap for Malaysia (MyGHS) was established in 2010 A total number of 8 strategies and 19 action plans have been identified in the MyGHS Roadmap. Out of the 8 strategies, 1 of the strategies is cross sectoral strategy, whereas other strategies are focusing on industrial workplace (i.e. 3 strategies), agriculture (i.e. 1 strategy), transport (i.e. 2 strategies) and consumer (i.e. 1 strategy). The implementation of MyGHS Roadmap involved participation of all stakeholders, including government, private sector, NGOs, professional bodies, research institutes and academia.

GHS Implementation Roadmap ST1 (cross sectoral strategy): Enhance capacity of the National Coordinating Committee on the implementation of GHS (NCCGHS) No. Action Plans Lead agency Collaborating agencies Status AP1 To establish a Group of Resource Person on GHS (GRPGHS) MITI DOSH, IKM, LESTARI Have been established in Sept 2011 (completed) AP2 To establish a Technical Working Group on Establishing an Integrated Chemical Database (TWGCD) DOE, DOSH, IKM, LESTARI Have established an e-Technical Working Group in April 2012 however the latter is underway AP3 To enhance cooperation between the NCCGHS and the National Committee on the Management of Environmentally Hazardous Substances (NCMEHS) towards a sound chemicals management in Malaysia NRE In progress

GHS Implementation Roadmap ST2 (Industrial Workplace): Strengthen upstream chemical safety requirements at industrial workplace No. Action Plans Lead agency Collaborating agencies Status AP4 To establish common definitions related to GHS DOSH DOE Have merged some of CPL into CLASS 201X AP5 To incorporate GHS provisions into Occupational Safety and Health (Classification, Packaging and Labelling of Hazardous Chemicals) Regulations 1997 (CPL 1997) Proposal of CLASS 201x in final stages with Attorney General’s office AP6 To incorporate GHS provisions into the Occupational Safety and Health (Use and Standards of Exposure of Chemicals Hazardous to Health) Regulations 2000 (USECHH 2000) In progress

GHS Implementation Roadmap ST3 (Industrial Workplace): Facilitate data generation for chemicals No. Action Plans Lead agency Collaborating agencies Status AP7 To ensure data reliability (e.g. establish guidelines to obtain reliable data from various databases) DOSH DOE Held workshop completed in May 2012 AP8 To maintain the list of SAMM accredited laboratories and GLP Compliant Testing Facilities in the field of chemical and toxicity testing. Standards Malaysia IKM, SIRIM Berhad In progress

GHS Implementation Roadmap ST4 (Industrial Workplace): Enhance awareness and capacities of industrial workers No. Action Plans Lead agency Collaborating agencies Status AP9 To amend GHS training modules by incorporating elements of the CLASS regulation (that will replace CPL 1997) DOSH CICM, NIOSH, LESTARI In Progress AP10 Training of trainers NIOSH DOSH, CICM In progress AP11 Sustainability of the training course

GHS Implementation Roadmap ST5 (Agriculture): Enhance preparedness for GHS implementation in agriculture sector No. Action Plans Lead agency Collaborating agencies Status AP12 Identify possible amendments on the requirements for pesticide classification and labelling based on available WHO and FAO guidelines PB MCPA In planning with WHO. No indication on completion yet AP13 GHS capacity building for upstream personnel In the stage of identifying personnel and reporting by year end 2013

GHS Implementation Roadmap ST6 (Transport): Adopting the latest version of the UNRTDG in transport sector No. Action Plans Lead agency Collaborating agencies Status AP14 Enhance capacities and capabilities of port authorities and port operators MOT MDM, Port authorities and port operators Discussions have been planned and expected for reporting by year end 2013 AP15 Enhance transport safety of dangerous goods by road and rail Land Public Transport Commission (SPAD), RTD, DOR Discussions are still underway and expected to be reported by year end 2013

GHS Implementation Roadmap ST7 (Transport): Enhance GHS implementation at areas that relate to transport sector No. Action Plans Lead agency Collaborating agencies Status AP16 Reduce the risks of chemicals in transit that are stored at bonded warehouse Customs DOSH Ongoing enforcement at warehouse AP17 Enhance safety of customs officers, and other related officers at the custom ports. - Custom officers on duty are well briefed AP18 Enhance capability of emergency responders in addressing chemical accidents BOMBA Initiated for BOMBA to give seminars

GHS Implementation Roadmap ST8 (Consumer): Enhance preparedness for GHS implementation in consumer sector No. Action Plans Lead agency Collaborating agencies Status AP19 To carry out Comprehensibility Testing (CT) and Situation and Gap Analysis (SGA) for consumer sector MDTCC LESTARI Ongoing

Training and Capacity Building for the Implementation of GHS in Malaysia

GHS Training Sessions The GHS advanced training sessions were held on 26-27 September 2011 (Session 1) and 28-29 September 2011 (Session 2). A total number of 195 participants have completed the training sessions. It comprises about 90 agencies/companies.

GHS ImpleTraining Sessions After the training sessions were held in 2011, 10 GHS trainers have been identified (i.e. GHS trainers), i.e. 6 representatives from DOSH, 2 representatives from NIOSH, 1 representative from SIRIM and 1 representative from LESTARI. In 2012, 5 training sessions were held in different regions and each training session comprises GHS awareness seminar and GHS advanced training course.

GHS Training Sessions A total number of 543 participants have completed the GHS basic training whereas 396 participants have completed the GHS advanced training. It comprises about 174 agencies/companies.

GHS Awareness Materials GHS Awareness Seminar: Session 1: Introduction to GHS (by NIOSH) Session 2: GHS implementation in Malaysia (by MITI) Session 3: Importance of GHS to the industry (by CICM) Session 4: GHS toolkit (by SIRIM) Session 5: CPL vs GHS-Malaysia supplier perspectives (by DOSH) Session 6: Legislative GHS requirement in Malaysia-CLASS regulations (by DOSH) GHS Advanced Training Course: Session 1: Classification and communication of chemical hazards (UKM) Session 2: Environmental hazard classification criteria for substances and mixtures (SIRIM) Session 3: Practicing environmental hazards classification (SIRIM) Session 4: Physical hazard classification criteria for substances and mixtures (NIOSH) Session 5: Practicing physical hazards classification (NIOSH) Session 6: Health hazard classification criteria for substances and mixtures (DOSH) Session 7: Practicing health hazards classification (DOSH)

GHS Awareness Material

GHS Awareness Material

GHS Awareness Material

GHS Awareness Material

GHS Awareness Material

GHS Awareness Material

GHS Awareness Material

GHS Awareness Material

GHS Awareness Material

GHS Awareness Material

GHS Awareness Material

GHS Awareness Material

GHS Awareness Material The booklets have been distributed to some of the schools students :

Impact of GHS In Malaysia Industrial Workplace GHS in Work place A safer work environment through consistent and comprehensible system of chemical hazards communications and practices for safe handling and use; Improved relations with employees; One standard hence avoids duplication of testing and evaluating chemicals and chemical mixtures A new regulation based on GHS principles Occupational Safety and Health (Chemicals Classification, Labeling and Safety Data Sheet) Regulations 201X (CLASS) is going to be implement by end of 2013. Malaysian Standard on GHS-Specification for Classification, Labelling and Formulation of Safety Data Sheet for Chemical Products in 2008 (MS1804:2008) DOSH has translated the GHS Purple Book into Bahasa Malaysia (3rd revised edition)

Impact of GHS In Malaysia (contd.) Transport Sector GHS in Transport Safer transport of chemicals, with common signals and precautionary statement Avoids duplication of testing and evaluating chemicals and chemical mixtures Facilitates international trade at ports of entry GHS pictograms are similar to UNRTDG pictograms Civil Aviation Act 1969 [Act 3] Civil Aviation Regulations 1996 Road Transport Act 1987 [Act 333] Merchant Shipping Ordinance 1952 Railway Act 1991 [Act 463] Carriage of Goods By Sea Act 1950 [Act 527] UN Recommendations on the Transport of Dangerous Goods, (UNRTDG)

Impact of GHS In Malaysia (contd.) Agricultural sector GHS in Agriculture By incorporation into international agreements, e.g. FAO Pesticide Labelling Guideline (not yet in line with GHS) Updated WHO classification that already in line with GHS Pesticide labels remain the primary communication tool with the farmer on safe and effective handling provide clear and transparent messages on health and safety Information transfer via label and SDS Align with other guidelines such as FAO International Code of Conduct on the Distribution and Use of Pesticides Pesticides (Labelling) Regulations 1984 Label wording must be consistent, clear and applicable to local use

Impact of GHS In Malaysia (contd.) Consumer sector GHS for consumer Consumer Protection Act 1999 Different and inadequate labelling of consumer products Label provides important source of information for consumers on the chemical hazards involved. GHS- harmonised hazard communication elements (pictograms, signal words and hazard statements)

Challenges of GHS Implementation Legal Challenges Recommendations Review/Amendment of regulations and law takes time More resources needed/ expertise (for legal review) Dependent on international regulatory development and guidelines( e.g. FAO Guidelines on Labelling of Pesticides) Adopt and adapt GHS to local needs ( do not reinvent the wheel) To leverage on the existing infrastructures and systems, and the strengths to synergize GHS with other initiatives relating to chemicals management (Environmental Hazardous Substance Scheme, Multilateral Environmental Agreements, MEAs)

Challenges of GHS Implementation Technical Challenges Recommendations More experts needed to classify chemicals and competent and translator More trainers to train the industry players and regulators Too many precautionary statements Capacity-building Lack of technical experts within the region Acceptable database on chemicals – like OECD to come up with a web Portal on chemicals To step up training and capacity building under the UNITAR project funding Engage the assistance of ASEAN partners Information sharing– through a help desk from industry, print materials and electronic media. Require supplier to provide reports on chemicals. List of chemicals – for monitoring. Continuing support from UNITAR. Need for multinationals to be on-board –added value. Cooperation with industry organization and association.

Challenges of GHS Implementation Implementation Challenge Recommendations Engaging stakeholder – different stakeholders Develop a national policy Road Map – promoting GHS Provide incentives or matching grants MNCs to spearhead the implementation of GHS( mentor/mentee) Process of classification – different sets of data Additional resources needed (financial and manpower) Different building blocks – by different countries Need for guidelines to consider it as mixtures or as a separate classification Commitment from all the stakeholder

Challenges of GHS Implementation Dissemination Challenge Recommendations Need to reach out to Small & Medium Companies. Website – regular updates on GHS Knowledge and awareness, generally lacking & need further enhancement within government, - especially for policy makers. MITI continue to engage with other government agencies, civil society and industry to promote GHS in Malaysia through the print and electronic media. To coordinate training: > GHS Awareness Seminars, > GHS advanced trainings

CONCLUSION GHS can lead to Harmonization; allow recognition of GHS prior to formal commencement; more reach-out programme to be organized; Efforts have been made to introduce A Malaysian Standard by SIRIM and new regulation based on GHS is in the pipeline by DOSH; GHS has been planned to be implemented for industrical chemicals and will be extended to other sectors; Goods get faster clearance at ports especially for movements of shipment and transshipments goods;

MINISTRY OF INTERNATIONAL TRADE THANK YOU MINISTRY OF INTERNATIONAL TRADE AND INDUSTRY MALAYSIA

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