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National activities to support the implementation of the GHS
Dr Paul Taylor
Director, Occupational Hygiene Policy
Safe Work Australia
Overview• Background • Training and awareness raising• HWSA GHS reference group • Publications and web content • Implementation Issues • Future activities 2016/17 • International activity• Other hazardous chemicals work
National activities to support the implementation of the GHS
Background • The GHS was first slated for adoption in Australia by Mark Vaile MP- the then Minister for Trade in
2002
• Adoption was to occur across APEC economies by 2006(!)• The model WHS legislation implements the GHS Rev. 3 in Australia. • All states and territories except WA and Victoria have adopted the model WHS legislation.
• WA and Victoria recognise the GHS under their existing legislation• The ACT considering how it will incorporate the hazardous chemicals chapter of the model WHS regulations
National activities to support the implementation of the GHS
Training and awareness raising• 40 training sessions were run across Australia in 2013/2014
• Approximately 1700 people attended the training
• SWA and WHS regulators have conducted targeted awareness sessions industry groups and associations: • Master Builders Association National Conference • Better Work Tasmania• Animal Medicines Australia
National activities to support the implementation of the GHS
Heads of Workplace Safety Authorities GHS reference group • Chaired by SafeWork South Australia• Remit: To assist regulators in promoting awareness and supporting industry to
transition to the GHS • Approach: Consult and engage with industry groups and stakeholders to assess
readiness• Technical subgroup: to resolve implementation issues raised by regulators and
stakeholders
National activities to support the implementation of the GHS
New Hazardous Chemicals Database• Hazardous Chemicals Information System (HCIS)• Replaces the Hazardous Substances Information System(HSIS)• Uses NICNAS and CLP Annex VI classifications• Retains Workplace Exposure Standards database• Has improved functionality – shows pictograms hazard codes and statements
– cut off concentrations will return• Launch Date : 1 July 2016 • HSIS will be taken down from 1 January 2017. The consolidated list (.xls) will remain online
National activities to support the implementation of the GHS
Safe Work Australia Web content • New Frequently Asked Questions package
• 120 questions based on questions commonly received by SWA and regulators• Covers hazardous chemicals management, classification, GHS, SDS, labelling • Publication is imminent
• General awareness fact sheet• SWA staff respond to approximately 1000 GHS/hazardous chemicals enquires
annually
National activities to support the implementation of the GHS
Implementation Issues Poisons standard
• Requires labelled of exempt industrial, dispensary, etc chemicals in accordance with the NOHSC Code• Amendment has been requested and is in train• Poison standard exemption applies only to chemicals solely supplied to workplaces. Under the Poison
standard, dual use requires Poisons standard labels alongside WHS label elements. ARPANSA licensing
• Licensed facilities are required to label radioactive sources for non-radiation hazards in accordance with the NOHSC code (via AS2243 series)
• Approach has been made to have this resolvedTGA
• Requires hospital grade disinfectants to be labelled in accordance with NOHSC as well as TGArequirements
National activities to support the implementation of the GHS
Implementation Issues Bulk containers and tanks• Previous legislation exempted bulk containers, including fixed tanks from workplace labelling if
placarded• WHS legislation does not provide for this exemption • It is therefore required that bulk containers include both EIP and a GHS label
• The GHS label should be placed near where the contents of the tank will be accessed at an appropriate size for someone a ‘use’ distance rather than emergency response
National activities to support the implementation of the GHS
Implementation IssuesExplosives labelling• Explosives are labelled under the AEC • The WHS regulations recognise this but require other hazards to be communicated
via the GHS• The industry is seeking national clarification on a number of sector specific issues
National activities to support the implementation of the GHS
Labelling Transitional Issue- across the supply chain • What do end users have to do come 1 January 2017?• What do suppliers (retail, wholesalers) have to do come 1 January?
National activities to support the implementation of the GHS
End users (PCBUs who use hazardous chemicals at their workplace, and are not manufacturers/importers, or suppliers)
Pre-1 January 2017 • Stocktake• Identify chemicals no longer required, and arrange disposal (if required) • Identify chemicals which are not correctly labelled under GHS, AC, or other existing
labelling scheme as appropriate• Obtain SDS (if available) • Label in accordance with guidance in CoP (noting reduced requirements for research, decanted
chemicals and small containers etc)
• Update SDS libraries, registers, manifests, and storage placarding as necessary
National activities to support the implementation of the GHS
End users (PCBUs who use hazardous chemicals at their workplace, and are not manufacturers/importers, or suppliers)
Post 1 January 2017 • Only accept supply of workplace hazardous chemicals labelled in accordance with
the GHS• Label research, decanted, and samples for analysis in accordance with the GHS • Update registers, manifests, and storage placarding as necessary
National activities to support the implementation of the GHS
Suppliers (PCBUs who supply hazardous chemicals, including manufacturers/importers
Pre-1 January 2017 • Stocktake• Identify chemicals no longer required(expired, not saleable) and arrange disposal (if
required) • Run down stocks of non-GHS labelled chemicals• For remaining stocks arrange for relabelling in accordance with guidance in CoP• Ensure GHS SDS are going to be available prior to 1 January 2017
National activities to support the implementation of the GHS
Suppliers (PCBUs who supply hazardous chemicals, including manufacturers/importers)
Post 1 January 2017 • Only supply GHS labelled chemicals • Supply updated SDS to match
National activities to support the implementation of the GHS
International • GHS Rev. 6 published July 2016• Combustible Dusts- to be progressed as an Annex (guidance) rather than a
chapter
National activities to support the implementation of the GHS
International • GHS Rev. 6 published July 2016• Combustible Dusts- to be progressed as an Annex (guidance) rather than a
chapter• Ongoing discussion re: GHS labels on portable tanks, and MEGCs alongside
transport elements
• Stakeholder engagement • November 2015 – stakeholder teleconference to inform Australian position to UNSCEGHS
National activities to support the implementation of the GHS
What’s next? • GHS revision 6- adopted from 1 January 2017 on a 2 year transition, subject to
regulatory impact analysis • Development of storage guide• More detailed guidance on classification of mixtures
National activities to support the implementation of the GHS
Update on other Hazardous Chemicals related activities
• Inorganic Lead- Consultation Regulation Impact Statement completed• Cost benefit analysis to support Decision RIS underway • Anticipated publication September 2016
• Workplace Exposure Standards• Discussion Paper released late 2015 • Work underway to support Consultation RIS publication• Anticipated CRIS publication – end of 1st Quarter 2017
National activities to support the implementation of the GHS