“Understanding real cases can really help compliance with China’s GHS rules”
Cloris Pan
Manager of GHS Division of R&D Center
Hangzhou REACH Technology Group
At AsiaHub Summit Europe in September, we heard from Cloris Pan, GHS project manager for Hangzhou REACH Technology Group, who spoke about GHS implementation in Asia. We spoke to her before the event about China's GHS rules, and what companies can do to make sure they're compliant.
Q) What general approach should Chinese and overseas companies have to GHS implementation?
While the goal of GHS is global harmonisation, hence the name, this target has not yet been achieved and companies will inevitably have to author SDSs according to local standards.
Take chemicals imported to China as an example. Overseas suppliers should use the classifications and relevant data they hold and 'translate' the document according to China’s national standards. This means formatting the SDS and label to meet the standards. The Chinese standard GB 15258-2009 covers labelling and GB/T 17519-2013 covers SDSs.
Q) How would you advise companies who export to China to implement GHS when they are required to disclose information on substances with 'trade secret' ingredients?
China’s standard for SDSs (GB/T 17519-2013), allows the actual ingredient names and CAS numbers to be withheld from mixture products if they are trade secrets. However, the hazards must still be indicated the relevant sections of the SDS.
In our experience, the best way to indicate substances where there are trade secrets is to give a general name to the confidential ingredient and indicate its CAS number as 'trade secret' in section 3 of the SDS. If there is no general name, then a class name of the substance can be used. For example, we can indicate the ingredient is “inorganic acid”, “organic alcohols”, “ether” etc.
For GHS labelling our suggestion is similar. The ingredient information needs to be consistent with section 3 of the SDS. However, the CAS number is not required according to GB 15258-2009. We suggest listing a general name with a concentration range of the confidential ingredient on the label.
Q) Could you explain the compulsory classifications used in China’s Inventory of Hazardous Chemicals and how they should be used given the 2015 implementation guidance?
According to the article 8 of the guidance, the listed classifications of hazardous chemicals are an important basis for work safety authorities at all levels to determine the hazardous characteristics of hazardous chemicals and take effective precautionary measures.
In 2017, the national registration centre (NRCC) held seminars to promote the classification identification of hazardous chemicals. It clarified the following in its discussion of the guidance:
- the listed classifications are not exhaustive and may not include all hazards of the substance. So suppliers can and should add more hazards where necessary; and
- when classifications are marked with “*”, suppliers can give a higher-level hazard category to the substance.
Q) Why are you looking forward to AsiaHub Summit Europe?
I think it’s a great idea to bring the prospects for – and latest changes to – the many Asian regulations to a European audience. While a great deal of information can be found online, the summit gives people a chance to discuss regulations with experts face-to-face and have their questions answered.
I'm also looking forward to hearing about other topics and discussing compliance issues with all speakers and delegates.
My own presentation will cover a number of actual cases and the solutions that were employed. I believe that understanding real cases can really help when it comes to compliance with local requirements, such as China's GHS rules.