Influence on international activities?

1. REACH aims to assist the EU in achieving the SAICM objectives.
At its first meeting in February 2006 the international conference on the management of chemicals approved the Dubai Declaration on the international management of chemical products and its general policy strategy. The Conference also recommended a global action plan as a work, documentation, and orientation tool. These three documents made up the “Strategic Approach to International Chemicals Management, (SAICM). This initiative was already described during the UN summit for sustainable development in Johannesburg in 2002, and had the purpose of risk reduction and knowledge collection concerning chemical substances at world level. A worldwide approach to the substances strategy was chosen to protect the competitive position of companies. With the link to the Johannesburg summit the SAICM strategy clearly fitted in with the concept of sustainable development, where besides the environment account is taken of social and economic aspects. Institutions including the FBE do, however, also point out here that scientifically and technically founded arguments should prevail over emotional ones. “The compulsory substitution of substances of high concern may not be generalised. Account must be taken of the real risks and the social advantages of these substances,” so judges the FBE. At European level REACH can give companies an innovation advantage by strengthening the substitution obligation, and by developing a system of temporary licences for socially indispensable products. Companies must be stimulated to set up co-operative ties to avoid the same substances having to be tested a number of times. Investing now means preventing high social costs in the future!

More information about this can be found at http://www.chem.unep.ch/saicm/.

2. The Rotterdam convention on the trade in dangerous chemicals.
To reduce the risks of the trade in toxic pesticides and other dangerous chemicals to the population and the environment, the so-called ‘prior informed consent’ procedure has existed since the start of the eighties in the last century. On the basis of this procedure trading takes place with the permission of the importer. In 1998 the ‘Rotterdam Convention’ was adopted, on the basis of which the ‘prior informed consent’ procedure became compulsory by law. This entails that the export of prohibited substances or substances subject to strict limitations such as DDT and PCBs may only take place if the importing country has given its permission based on information provided beforehand. The purpose of these Regulations is to give the importing country the opportunity to consider the risks and benefits of a substance. The Rotterdam Convention forms the first phase of a worldwide approach to “chemical management”. The convention came into force on 24 February 2004.

More information about this can be found at http://www.pic.int.

3. GHS will replace the existing provisions for classification and labelling.
The United Nations has been working on the GHS system since 1992. The GHS (Globally Harmonized System of Classification and Labelling of Chemicals) establishes criteria for the classification of chemicals based on the intrinsic hazardous properties (“health, the environment and physical dangers”) and determines the elements required for harmonised communication via labelling and safety data sheets.

At present the European Commission only has a proposal for a Regulation. It is also having a study take place of the (business) economic aspects of GHS. At present the proposal is not yet available in all 27 languages of the European Union. Between 21 August 2006 and 21 October 2006 Internet consultation took place from the EU. The ultimate proposal will, as expected, be published in the second half of this year, after which consideration by the Council and the European Parliament follows. The plan is that after the introduction of GHS the transitional period for the reclassification and relabelling of pure substances will run until 1 December 2010. Because the classification of the mixtures depends on the classification of the individual substances, the criteria will first have to be applied to substances, and then mixtures (GHS jargon for preparations). Hence, after the transitional period for pure substances, for mixtures there will be a following additional period until 1 June 2015. After these dates the SDS must have been adapted to the new classification method.

The most important objectives of GHS are:

• The increasing of the protection of people and the environment by means of an internationally understandable system of danger communication;
• To offer a framework for countries not having a system relating to danger classification and communication;
• The reduction of tests and assessments of chemical substances;
• The stimulation of international trade in chemical substances of which the dangers are explored and evaluated in an appropriate manner on an international basis.

When GHS comes into force in Europe, the REACH Regulation will be updated to be able to make the link with each other. GHS and REACH are closely intertwined. The European implementation of GHS forms a substantive development of the classification and labelling aspect.

The existing classification system and GHS for Europe are conceptually similar and include the same elements. For certain danger categories the same criteria apply to the European system and GHS for Europe, for others this is not the case. There are also differences in the cut-off values among these criteria. GHS for Europe (GHS-EU) has defined additional danger categories. The European system has 15 danger categories, while GHS has 27. The most important differences with the current system are the new danger symbols and the signs consisting of the danger symbol and other graphic elements. R and S phrases are to disappear and be replaced by a signal word and H and P statements (Hazard and Precautionary statements). GHS introduces the signal word “danger” for the most dangerous category inside a class and “warning” for the less dangerous category inside the class.

The classes in the GHS are, just as those for the transporting of hazardous goods (ADR), essentially based on the UN Recommendations. Besides the symbols known from the ADR another two are added. The reason for this is that substances that are ‘harmful’ (slightly toxic) and substances that in the longer term are harmful to health are not normative for transport. So for neither of them was there a symbol for the danger classes.

There are two conspicuous signs:

	: This new sign is used with the higher classes of different health dangers.
	: This new sign replaces the current St Andrew's cross. The sign is used with the lower danger class for different health dangers.

The GHS will have consequences on the classification and labelling of both substances and preparations (“mixtures” in GHS jargon). The business practices of manufacturers and importers of substances and mixtures and their users will be affected by the consequences. According to the expectations the far-reaching harmonisation will simplify international trade. Internationally operating companies will particularly benefit from this. On the other hand, the GHS will in the short term require much effort from manufacturers, importers and users of chemical products.

More information about this can be found at: http://www.unece.org/trans/danger/publi/ghs/
ghs_welcome_e.html.