Contributor: Dan Hagerty, MS, CHMM

Business Title: Sr. Hazard Communication & Training Coordinator

Contact Information:
ChemADVISOR, Inc.
750 William Pitt Way
Phone: 412 826 3750
Fax: 412 826-3753
Email: dhagerty@chemadvisor.com
Web Site: www.chemadvisor.com
Title of Poster Presentation: Implementation Considerations for Internationally Harmonized Hazard Communication

Authors:
Dan Hagerty

Paul F. Moyer MS
Hazard Communication Manager
ChemADVISORÒ, Inc.
750 William Pitt Way
Pittsburgh, PA 15238
Pittsburgh, PA 15238
Fax: (412) 826-3753
Email: pmoyer@chemadvisor.com
Web Site: www.chemadvisor.com

Key Words: Hazard Communications, chemical, regulation, regulatory agency, international, global, standards, harmonize, Material Safety Data Sheets, MSDS, product labels,transportation classifications

Abstract:
For the past few years, the focus of numerous international regulatory agencies has been on the examination of the different systems of chemical safety regulations in an effort to define criteria that would unify various global standards. At the current time, this work in developing a globally harmonized system continues to progress and make strides towards reaching this goal. As the conclusion of these efforts nears, the attention must shift from what the criteria and regulations of the system will be to how those rules and conventions will be implemented by the various governmental agencies, and by the companies that manufacture, import or distribute chemical products.

The very nature of harmonizing different chemical regulations implies that changes will need to be made to the existing procedures in order to comply with these unified rules. As beneficial as these regulatory changes promise to be, the fact remains that much effort will be required in order for the affected governmental agencies and private companies to make these necessary adjustments. From a chemical safety perspective, these changes will include, but are not limited to, updating material safety data sheets, product labels, transportation classifications, and software packages. Before such documents can be updated, regulatory changes may prompt the need for products to be tested for additional physical and toxicological properties. All of these considerations will result in an expense of both time and resources in order to fulfill the demands of harmonization. This paper will provide some examples of what this effort may entail.

The creation and application of a globally harmonized hazard communication system also brings about other considerations. These items include jurisdiction, enforcement, legal and civil liability, and the necessary interaction of government agencies.

Although the principles and criteria for the harmonization of international chemical safety regulations are still being formulated, there can be little debate that implementing such a system, though substantially beneficial, will inevitably require many changes to the way in which hazard communication is currently being conducted. This paper will address some of the needs for the expenditure of such time and resources. By discussing these issues, the preparation for, and the realization of, harmonization may proceed in a more efficient