DGAG. DG and the GHS in Australia. Richard Greenwood. Consultant and Trainer, RG Chemical Safety. Dangerous Goods Advisory Group, Victoria

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1 DG and the GHS in Australia Richard Greenwood Insert Company logo Consultant and Trainer, RG Chemical Safety Dangerous Goods Advisory Group, Victoria DGAG

2 Outstanding Issues Non-harmonisation in states: Status in Victoria, WA and ACT Workplace awareness of system Adoption of labelling by industry Continued use of Poisons Schedule label for workplace products Regulator Support information Environmental Classification Labelling, SDS information

3 Effect of varied adoption Victoria has patched the OHS and DG Regs to recognise GHS, but not in the way done in WHS. The covered classification categories are included in Vic OHS legislation as hazardous substances, but are excluded from WHS as Hazardous Chemicals WA: back to public consultation

4 Workplace Awareness Most of my training requests are framed around Dangerous Goods The only employers regularly asking for hazardous substances are Local Government The only organisations asking for GHS are national and technical. No one has asked for hazardous chemicals training (yet). I always add in GHS, response is generally we don t have that on our products, They always do, on a minority (so far). Once familiar with pictograms, they are easily recognised.

5 Some DG and GHS labelling examples

6 Adoption by Industry Labels must be updated by 2017 in WHS States: Obligation of Supplier, Manufacturer and Importer. To do so, these material must be through the supply chain and out of the direct control of these by this date. But, also Obligation of PCBU (employer) That includes the company providing 3rd party warehousing services in those states (possibly not for transit storage, but the Coroner and courts may find otherwise). Possibly OK if it is in the retail stream distributors, dual purpose retailers. BUT will it be acceptable to all customers in 2017 with old labels? Will some customers have sufficient clout to reject product?

7 Poisons Schedule Labels for Workplaces Does Poisons Schedule Label (2-3 warning and first aid statements) provide safety information equivalent to workplace requirements? Hazardous substances legislation (4 risk and 4 safety phrases), WHS (all hazard and 6-10 precautionary statements). The lack of engagement of the SUSMP committee for domestic labelling: IMAP decisions adopted from NICNAS. SUSMP does not recognise or permit the use of hazard and precautionary statements. The use of these labels on commercial products is largely ingrained habit. WHS Regs: SUSMP on original container of chemical, where incidental to nature of work Labelling CoP: WHS if use and handling are predominantly related to a work activity

8 Regulator Support The clear winner is Safework NSW basic information resources developed Queensland has fewer resources, and most other states provide just a link to the Safe Work Australia website, where support materials are mainly technical. WA and Victoria link to the UN GHS website, although arguably these workers need extra practical support on label and SDS changes. A Regulators committee has been set up to provide consistent, shared resources in this area. I applaud this, but encourage them to not delay release further.

9 Environmental Hazards Environmental hazards are GHS and DG everywhere else in the world. A National Standard for Environmental Risk Management of Industrial Chemicals Discussion Paper has been developed, but has no provision for labelling or SDS information. It also has no guidance for application to mixtures. The responsibility of the user would be to check ingredients against those listed on regulatory schedules. At present, every chemical would have to be assessed by NICNAS, despite the existence of accepted international hazard classification systems. Initial comment closes 5 May, before release for public comment.

10 DG and the GHS in Australia So where does DG fit into all this? The Australian chemical regulatory framework has been made so complex that either shortcuts are taken, or competitiveness is compromised for compliance. If you re paying someone to check all this stuff for every product, your competition who isn t can be cheaper than you. It is the cheaper alternatives who are taking the risks, and that is as likely to be in the Dangerous Goods space as anywhere else. We aren t going to get a simpler legislative framework quickly, but we could get much better consistency in the framework we have.

11 DG and the GHS in Australia