jaco wessels product regulatory steward march 19 2009 n.
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Jaco Wessels, Product Regulatory Steward March 19, 2009. GHS in practice. Organization. Coatings Chemicals Car Refinishes Surface Chemistry Marine & Protective Coatings Polymer Chemicals Powder Coatings Functional Chemicals Industrial Finishes Industrial Chemicals

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organization
Organization
  • CoatingsChemicals
  • Car Refinishes Surface Chemistry
  • Marine & Protective Coatings Polymer Chemicals
  • Powder Coatings Functional Chemicals
  • Industrial Finishes Industrial Chemicals
  • Packaging Coatings Pulp & Paper Chemicals

Polymer Chemicals | GHS

polymer chemicals
Polymer Chemicals
  • Organic peroxides, Metal alkyls
  • Suspending Agents Anti-fouling
  • Organometallic Specialties
  • About 1000 commercial products

Polymer Chemicals | GHS

content presentation
Content presentation
  • Advantages GHS
  • Where are we as Akzo Nobel?
  • Practical issues implementing GHS
  • Classification
  • GHS is not (yet) Global
  • Implementation of developing system
  • Label issues
  • Downstream legislation

Polymer Chemicals | GHS

advantages of ghs
Advantages of GHS
  • Moral duty.
  • No possibilities to “misuse” legislation differences.
  • Getting development countries aboard.
  • Globally operating companies.
  • We are on the road to; Uniform language
  • One label / One MSDS
  • Possibility to stand out
  • Regional operating companies
  • No real advantage. Only Costs

Polymer Chemicals | GHS

advantages of ghs1
Advantages of GHS
  • GHS is opportunity to change small issues;
  • Peroxides; Oxidizing symbol replaced by flammable symbol
  • Severity of decomposition is in GHS (Type A-G)
  • Other

Polymer Chemicals | GHS

where are we
Where are we?
  • Awareness training
  • Adjusting MSDS software system
  • Preparing GHS labels
  • Reclassification substances/mixtures
  • .

Polymer Chemicals | GHS

practical issues classification
Practical issues : Classification
  • Lack of information. (will be solved by REACH)
  • Due to lack of information  over classification.
  • LD50 calculation of mixture
  • (100/ATEmix)=Σi (Ci/ATE)
  • (100/ATEmix)=Σi (100-Cunknown)/ATE)
  • Example 2% of R22 substance in not classified solvent without known underlying data.
  • Opportunity : Stimulates discussions internally and externally.
  • Product file with classification decisions
  • Translation rules applicable for substances.
  • Disadvantage to use them for mixtures

Polymer Chemicals | GHS

practical issues classification1
Practical issues : Classification
  • Classification changes (from EU perspective)
  • About as many substances that are now (not) dangerous will remain (not) dangerous.
  • Some dangerous substances (10%?) will be classified slightly more “severe”.
  • Many mixtures will be classified more “severe”
  • New items for EU : Target Organs
  • New items for US : Environmental issues

Polymer Chemicals | GHS

global differences
Global differences
  • Building block approach
  • Different building blocks  Different label elements.
  • So still differences in label content in different regions.
  • Regional Lists with mandatory(?) classifications
  • Differences in classifications even within one building block.
  • Different implementation dates and ways
  • Generally : Asia  Europe  America’s
  • Since Asia usually followed EU and now GHS, we are facing now de-harmonization.
  • Ways of implementing (list, substances-preparations, all)

Polymer Chemicals | GHS

implementation of developing system
Implementation of developing system
  • Asia.
  • Unclear which building blocks
  • Changing implementation dates
  • Precautionary statements
  • Correspondence group (United Kingdom) is working on a proposal
  • Sequence and amount of precautionary statements.

Polymer Chemicals | GHS

eu label issues
EU – Label issues
  • Trigonox K-80
  • May cause fire.
  • Harmful in contact with skin and if swallowed.
  • Toxic by inhalation.
  • Causes burns.
  • Harmful: danger of serious damage to health by prolonged exposure through inhalation and if swallowed.
  • Toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment.
  • Keep container tightly closed in a cool place.
  • Keep away from reducing agents (e.g. amines), acids, alkalies and heavy metal compounds (e.g. accelerators, driers, metal soaps).
  • In case of accident or if you feel unwell, seek medical advice immediately (show the label where possible).
  • Do not mix with peroxide-accelerators or reducing agents.
  • Avoid release to the environment. Refer to special instructions/Safety data sheets.

Polymer Chemicals | GHS

eu label issues1
Trigonox K80

DANGER

Combustible liquid.

Heating may cause a fire.

Harmful if swallowed.

May be fatal if swallowed and enters airways.

Harmful in contact with skin.

Causes severe skin burns and eye damage.

Fatal if inhaled.

Toxic to aquatic life with long lasting effects.

Keep/Store away from dirt, rust, chemicals in particular.

Keep only in original container.

Do not breathe vapors.

Wash hands and contaminated skin thoroughly after handling.

Do not eat, drink or smoke when using this product.

Use only outdoors or in a well-ventilated area.

Avoid release to the environment.

Wear protective gloves, eye/face protection and protective clothing.

Wear respiratory protection.

Immediately call a POISON CENTER or doctor/physician.

Rinse mouth.

In case of fire: Use water spray, alcohol resistant foam, sand, dry chemical powder or CO2 for extinction.

IF SWALLOWED: Rinse mouth. Do NOT induce vomiting.

IF ON SKIN: Wash with plenty of soap and water.

IF ON SKIN (or hair): Take off immediately all contaminated clothing. Rinse skin with water.

IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing.

IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing.

Store locked up.

Protect from sunlight.

Store at temperatures not exceeding 40°C.

Store away from other materials.

Store in a well-ventilated place. Keep container tightly closed.

Dispose of contents and container according to local regulation.

EU – Label issues

Polymer Chemicals | GHS

eu label issues2
EU – Label issues

Polymer Chemicals | GHS

eu label issues3
EU – Label issues
  • Logistic problem due to the increased amount of label text
  • Poland
  • Germany
  • Greece
  • Poland
  • Germany
  • Greece

Polymer Chemicals | GHS

downstream legislation
Downstream legislation
  • Legislation is often based on classification of products. So, if classification changes….
      • Restrictions on Marketing and Use
      • Export / import
      • Reporting
      • Waste treatment
      • Other…
  • Translation of GHS into current legislation isn’t done yet in Europe.
  • Possible consequences.
      • More toxic material on your site might lead to more issues with storage on your site.
      • Corrosive products sold to general public requires child resistant closures.
      • Changes in packaging

Polymer Chemicals | GHS

conclusions
Conclusions
  • GHS is a good thing!
  • On the road to global hazard communication.
  • GHS is not yet fully developed
  • Complex legislation like this needs time to grow
  • GHS has many consequences
  • Not just a different label on your product

Polymer Chemicals | GHS