Written on: December 1, 2021 by Cassandra Taylor
The Globally Harmonized System of Classification & Labeling of Chemicals (GHS) was developed by the United Nations (UN) to address classification of chemicals by hazard type and propose harmonized hazard communication elements, including labels and safety data sheets (SDS). Despite its name, the GHS is neither completely “global” nor “harmonized” due to the varying implementation approaches enacted by governments around the world. However, GHS does provide a basis for harmonization of rules and regulations on chemicals at a national and international level, which is an important factor in trade facilitation.
This column discusses the latest edition of UN GHS, as well as recent implementation steps taken by some key jurisdictions around the world. While some countries move to implement their first iteration of GHS, others are adopting newer revisions of the system to provide increased worker health, safety benefits and protection.
UN releases 9th Revision of GHS
On Dec. 11, 2020, the Committee of Experts on the Transport of Dangerous Goods & on the Globally Harmonized System of Classification & Labeling of Chemicals adopted a set of amendments to the 8th revised edition of the GHS. The amendments include updates to Chapter 2.1 (Explosives) to better address explosion hazards when products are not in their transport configuration. Other changes include the revision of decision logics, changes to the classification and labeling summary tables in Annex 1, as well as the revision and further rationalization of precautionary statements. References to the Organization for Economic Cooperation & Development (OECD) test guidelines for the testing of chemicals in Annex 9 and Annex 10 were also updated.
The 9th revised edition of GHS, which incorporates these amendments, is currently available for consultation purposes in English and French on the UN Economic Commission for Europe (UNECE) website. The other four official UN languages (Arabic, Chinese, Russian and Spanish) are expected to be posted as they become available.
Chile implements GHS & chemical registration requirements
On Feb. 9, 2021, Chile’s Ministry of Health published Decree 57 of 2019, Regulation on Classification, Labeling & 
Notification of Hazardous Chemicals & Mixtures. This new decree marks the formal implementation of GHS in Chile as well as a new chemical reporting system, each with established implementation timelines. Although the decree references the UN Purple Book (a GHS guidance document), it is not based on a specific version of GHS. Product types that are excluded from GHS provisions include hazardous waste, medical devices, pharmaceutical products, food additives and animal feed. The Ministry of Health plans to publish an official list of chemical classifications for substances that will specify the hazard classes and categories. In the future, these official substance classifications will need to be taken into consideration when assessing the hazards of products sold in Chile.
Manufacturers and importers will be obligated to submit a notification to the Chilean government when quantities of a hazardous substance meet or exceed one ton per year.
The deadlines for implementation of GHS in Chile are as follows:
• Substances for industrial use: Feb. 9, 2022
• Substances for non-industrial use: Feb. 9, 2023
• Mixtures for industrial use: Feb. 9, 2025
• Mixtures for non-industrial use: Feb. 9, 2027
Deadlines for registration will come into effect two years after the GHS implementation dates specified above. For example, registration of substances for industrial use will be required by Feb. 9, 2024. Chemical registration is not required for active ingredients in pesticides for agriculture, health and home use.
Columbia moves forward with workplace GHS implementation
On April 7, 2021, Columbia’s Ministry 
of Labor published Resolution 0773/2021, defining the actions that employers must take to implement GHS in the workplace. Implementation of the GHS 6th revised edition was approved in 2018 by Decree 1496/2018 and will proceed based on the timelines established under Resolution 0773/2021.
The transition period for implementation depends on the type of product and the deadlines are as follows:
• Pure chemical substances and diluted solutions: April 7, 2023
• Mixtures: April 7, 2024
Labels and SDS must be in the Spanish language and classified in accordance with Revision 6 of GHS. Employers are required to review the data that SDS and label information is based on every five years, at minimum. The SDS must also include a local or toll-free 24/7 emergency phone number.
According to Resolution 0773/2021, label sizes for containers should align with EU Regulation (EC) No 1272/2008 and be proportional to the size of the container. Components contributing to acute toxicity, skin corrosion or severe eye damage, reproductive toxicity, mutagenicity, carcinogenicity, specific target organ toxicity or skin/respiratory sensitization must be identified on the label.
Australia moves to GHS Revision 7
On Jan. 1, 2021, the two-year transition period for updating from the 3rd edition to the 
7th edition of GHS in Australia began. By 2023, GHS Revision 7 must be used to prepare SDS and labels of hazardous chemicals in Australia.
The key changes involve product classification updates:
• “Flammable aerosols” hazard class becomes “Aerosols” and a new hazard category for non-flammable aerosols is added (Category 3)
• A new physical hazard is being introduced for Desensitized Explosives: Categories 1–4
• Flammable Gas 1 will be divided into Category 1A and 1B and three new flammable gas categories are added:
■ Pyrophoric gas
■ Chemically unstable gas A
■ Chemically unstable gas B
• All Category 2 Eye irritants, including the formerly exempt Category 2B, will now fall under the definition of “hazardous chemical” under the model Work Health & Safety (WHS) laws
There are no major changes to the format of the SDS itself.
New Zealand moves to GHS Revision 7
On April 30, 2021, New Zealand implemented the 7th revised edition of GHS as its official workplace hazard
classification system. SDS and labels for new hazardous materials must now be authored according to GHS Revision 7. There is a four-year transition period to update existing labels and SDS to comply with the new classification requirements; this ends on April 30, 2025.
As with the changes for Australia, the new requirements in New Zealand are primarily concerned with the hazard classifications. Revision 7 of the Purple Book applies for classification purposes, except for building blocks that are not adopted in New Zealand, such as the Acute Toxicity 5 and Skin Irritant 3 categories.
There are some differences in the classification cut-offs for New Zealand in comparison to the Purple Book—specifically, the deviations that affect the Skin & Respiratory Sensitizer, Specific Target Organ Toxicant, Carcinogen and Reproductive Toxicant classifications.
Previously, New Zealand managed hazardous substances under several different pieces of legislation. The key regulation was the Hazardous Substances & New Organisms (HSNO) Act, which set criteria that designate a substance as hazardous and assign it an HSNO hazard classification number. The HSNO number determines the nature and level of its conditions of use.
Companies were formerly required to use HSNO classifications on SDS and labels and could additionally choose to include the GHS format. Now, for the first time, the HNSO numbers have been converted to equivalent GHS classifications. All Pre-2021 HSNO classification codes have been revoked, except hazards to the terrestrial environment for agrichemicals, which do not have a GHS equivalent and comprise the following categories:
• Hazardous to soil organisms (9.2A, 9.2B, 9.2C, 9.2D)
• Hazardous to terrestrial vertebrates (9.3A, 9.3B, 9.3C)
• Hazardous to terrestrial invertebrates (9.4A, 9.4B, 9.4C)
• Designed for biocidal action (9.1D)
if you sell hazardous products in Chile, Columbia, Australia or New Zealand, we suggest taking note of the implementation deadlines for the new regulations in each country. This way, you can plan ahead to prepare for any new obligations and ensure that your documentation remains compliant. SPRAY
