Summary of status of the GHS regional implementation

Regional Project “Evaluating and Strengthening National and Sub-regional Capacities for Implementing the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) and

Supporting SAICM Implementation in Central and Eastern Europe (CEE)”

Regional Stocktaking Workshop on the GHS implementation in CEE Chisinau, Republic of Moldova

17-19 July 2012

Dr. Suzana AndonovaRegional GHS CEE Project Consultant

Introduction

This report presents the results of a survey conducted to assess the status of implementation of Globally Harmonized System of Classification and Labelling of Chemicals (GHS) in the CEE countries and the needs of each country in the Region for prompt introduction and better implementation of GHS.

The results of the assessment will serve as a basis for drafting the strategy for GHS implementation in the CEE Region.

Material and methods

• A questionnaire comprised of 28 questions was prepared.• All the questions were relevant to the issues related to GHS

implementation in the countries.• All the National Focal points were contacted and were

invited to respond to the questions.• A cross tabulation and data results dispersion methods

were used to analyse and summarise the responded questionnaires.

• Personal communication and desk research for other countries.

General FeedbackAmong 24 countries invited to fill in the questionnaires, in total 12 responses were received:

Invited countries Responding CountriesAlbania AlbaniaArmenia Azerbaijan Belarus BelarusBosnia and Herzegovina Bulgaria BulgariaCroatia CroatiaCzech Republic Estonia Georgia

Invited countries Responding countriesHungary HungaryKosovo KosovoLatvia Lithuania Republic of Macedonia Republic of MacedoniaMontenegro Republic of Moldova Republic of MoldovaPoland PolandRomania RomaniaRussia RussiaSerbia SerbiaSlovakia Slovenia Ukraine

List of the contact points in the respondent countries

Country

Contact PointName Title/ Responsible Institution

Kosovo Violeta Lajqi-Makolle Senior Officer for chemical management/ Ministry of Environment and Spatial Planning-MESP

Moldova Liudmila Marduhaeva Main Advisory Officer /Ministry of Environment

SerbiaAleksandra Zujic International Cooperation and Projects

Coordinator/ Serbian Chemicals AgencyCroatia Biserka Bastijančić-Kokić/ Nenad Lamer Ministry of Health, Directorate for Sanitary

Inspection

Albania Lindita Tafaj SAICM Focal Point/ Institute of Public Health

Macedonia Marin KocovSAICM National Focal Point/POPs&Ozone Unit/MoEPP

BelarusIrina Ilyukova Liliya Najaran Republican Scientific Practical Centre of Hygiene

Russia Makarova Anna SergeevnaInstitute of Chemistry and Sustainable development( РХТУ им.Д.И.Менделеева)

Bulgaria Hristina FilipovaChief Expert/Ministry of environment and water

Poland Mariusz GodalaSzymon Domagalski

Bureau for Chemical Substances

Hungary Gabriella Füle Ministry of Rural Development

Romania Liliana Luminita TirchilaSAICM National Focal Point/MINISTRY OF ENVIRONMENT and FORESTS

Survey findings

Country

Q1 Level of development of chemical industry

Q2 Source of chemical products

Leastdevelop

ed

Needs additiona

ldevelop

ment

Welldevelope

d

Highlyadvanced

level

Domestic production

Imported products

Manufacture /processing of imported

bulk/raw chemicals

Kosovo Moldova Serbia Croatia Albania Macedonia Belarus Russia Bulgaria Poland Hungary

Romania

Q1.Status of development of chemical industry in CEE countries

Q2.Source of chemical products

Q3. Current legal and policy frameworks assessment

Among 12 countries, 4 Countries assessed the current legal and policy frameworks 4 did not do so and the remaining 4 are in process of assessment of the legal policy framework.

Q4. Status of implementation of the MEAs

Stockholm Conventio

n

•Yes -Albania, Belarus, Bulgaria, Croatia, Hungary,, Republic of Macedonia, Republic of Moldova, Poland, Romania, Russia and Serbia /Armenia, Ukraine, Georgia, EU member states in CEE Region

•No – Kosovo,

•Montenegro and Bosnia and Herzegovina (at initial phase)

Basel Conventio

n

•Yes-Belarus, Bulgaria, Croatia, Hungary,, Republic of Macedonia, Republic of Moldova, Poland, Romania, Russia and Serbia/Armenia, Ukraine, Georgia, EU member states in CEE Region, Montenegro and Bosnia and Herzegovina (at initial phase)

•No- Kosovo, Albania (not implemented)

Rotterdam Conventio

n

•Yes-Albania, Belarus, Bulgaria, Croatia, Hungary,, Republic of Macedonia, Republic of Moldova, Poland, Romania, Russia and Serbia/Armenia, Ukraine, Georgia, EU member states in CEE Region

•No-Kosovo, Azerbaijan,

•Montenegro and Bosnia and Herzegovina (at initial phase)

SAICM

•Yes-Albania (initial phase), Belarus, Bulgaria, Croatia, Hungary,, Republic of Macedonia, Republic of Moldova, Poland, Romania, Russia and Serbia/Armenia, Ukraine, Georgia, EU member states in CEE Region

•No-Kosovo, Azerbaijan,Montenegro, Bosnia and Herzegovina

Q5. Integrated SAICM objectives in relevant programs, plans and/or strategies at various levels

• Out of total 12 countries, only Kosovo and Belarus have not integrated the SAICM objectives into a country relevant strategic program, plan or strategy.

• SAICM objectives are integrated into the EU Regulations REACH and CLP and are acting into all EU Countries.

Q6. Status of GHS implementation in CEE countries

50%33%

17%

GHS Implementation in CEE Region

Fully implementing/ Serbia,Croatia,Hungary,Poland, Romania,Bulgaria

Early stage ofImpl./Macedonia,Moldova,Belarus,Russia

No action /Kosovo,Albania

Q7a. Inter-ministerial or inter-institutional coordination arrangements to facilitatethe sound management of chemicals / GHS implementation in CEE Region

Country Inter-ministerial or inter-institutional coordination body

Albania Committee for pesticide registration, committee for biocides. ToR have been prepared for an Inter-sectorial Committee for Chemicals Management (Safety)

Belarus Yes

Bulgaria Yes

Croatia Yes

Hungary Yes

Kosovo No

Macedonia National Inter-ministerial Working Group for chemical management comprised by therepresentatives from the Ministry of Environment, Finance-Customs Administration, Health,Agriculture, Crisis management Centre, Poisoning Centre

Moldova National Inter-ministerial Working Group, mandated to implement theChemical MEAs, SAICM and National Programme on Sound Management ofChemicals

Poland Yes

Romania Yes

Russia Yes/CIS

Serbia Serbian Chemicals Agency, Ministry of infrastructure and energy and Ministry of Agriculture, Trade, Forestry and Water Management *

Q7b,c&d

• National Governmental authority/agency responsible for the GHS implementation

• Government agencies that should be involved for GHS implementation in the country

• Ministries/agencies in the country ready to implement and maintain the GHS

All listed in the Annex 1 of the report.

Q8.Level of awareness on GHS

Level of awareness on GHS in CEE Region

Country Very low Medium High

Kosovo

Moldova

Serbia

Croatia

Albania

Macedonia

Belarus

Russia

Bulgaria

Poland

Hungary

Romania

Q9. What are the obstacles to implement the GHS in countries?

1. No sufficient human resources/capacities and expertise.

2. Lack of financial resources to properly implement GHS.

3. Lack of system for integrated chemicals and hazardous substances information was very common for the twelve surveyed CEE countries.

Q10. GHS Implementation in the transportation sector

• All the CEE countries have relevant Law on transportation for dangerous goods that are in accordance with the based on the UN Recommendations for the Transport of Dangerous Goods(Model Regulations which is in accordance with GHS).

• Some of the countries stated some additional regulation concerning the transportation (Albania)

Q11. Has your country already conducted any basic/initial training course for GHS introduction/

implementation

Q12. How will stakeholder cooperation and support for implementing the GHS be managed

Many different views and approaches as well as understandings.…To be discussed during the workshop/working groups…

Q13A. Current status of GHS implementation- Sector transportation

Country

Current status of GHS implementation- Sector transport

No action taken

Situation analysis

prepared or under

preparation

Preparing for revising

related legislation/ administrat

ive procedures

Preparing for

establishing new

legislation/ administrat

ive procedures

Already implement

ing GHSOther

Kosovo

Moldova

Serbia

Croatia

Albania

Macedonia

Belarus

Russia

Bulgaria

Poland

Hungary

Romania

Q13B/C Current status of GHS implementation- Sector Industry & Consumer products

Country

Current status of GHS implementation- Sector Industry & Consumer products

No action taken

Situation analysis

prepared or under

preparation

Preparing for revising

related legislation/ administrat

ive procedures

Preparing for establishing

new legislation/

administrative procedures

Already implemen

ting GHS

Other

Kosovo

Moldova

Serbia

Croatia

Albania

Macedonia

Belarus

Russia

Bulgaria

Poland

Hungary

Romania

Q13D Current status of GHS implementation- Sector Agriculture/Pesticides

Country

Current status of GHS implementation- Sector Agriculture/Pesticides

No action taken

Situation analysis

prepared or under

preparation

Preparing for revising related

legislation/ administrative

procedures

Preparing for establishing

new legislation/

administrative procedures

Already implement

ing GHS

Other

Kosovo

Moldova

Serbia

Croatia

Albania

Macedonia

Belarus

Russia

Bulgaria

Poland

Hungary

Romania

Q14. Is there a mandatory requirement to translate GHS into the national language(s)?

Q 15 a. Interesting topics to be discussed during the Regional workshop, according to the country needs

Country

Interesting topics to be discussed during the Regional workshop

Organizational structure

needed for implementation

of GHS/CLP

Needs for Capacity

building to be prepared for

GHS introduction

Full introduction of GHS or by

sectors (Building

Block Approach)

Introduction of GHS Versus CLP in some

countries

Kosovo Moldova Serbia Croatia Albania

Macedonia Belarus Russia Bulgaria Poland Hungary Romania

Additional topics of interests:

1. Information on related activities under Agreements on Association with EU(Moldova);

2. Cooperation among countries in the Region for proper implementation of GHS/CLP (Macedonia);

3. Training of population and other relevant stakeholders (Russia);

4. Small and medium-sized enterprise involvement and difficulties by introducing GHS (Hungary).

Q16. Availability of financial resources for national/regional capacity building activities towards

GHS implementation

Q17. Activities completed or planned for GHS implementation

Situation/ Gap

Analysis

Comprehensibility Testing

Impact Study

and/or Cost

Benefit Analysis

First Draft of

the Implementatio

n Instrum

ent

Consultation with

Stakeholders

Development of a

GHS National Implementation strategy

Final Adoption

of the Implementation

Instrument

Training courses for GHS implementation

Kosovo / / / / / / / /Moldova / / / / / / / /Serbia Yes Yes No No Yes No No YesCroatia / / / / / No Yes YesAlbania / / / / / / / /

MacedoniaYes No / Yes Yes No No No

Belarus No Yes/ 2008 No Yes/2011 Yes/2010-11

Yes No Yes/2008-11

Russia / / / / / / / /Bulgaria No No No / Yes No Yes YesPoland Yes Yes Yes Yes Yes Yes Yes YesHungary Yes Yes Yes Yes Yes Yes Yes YesRomania / / / / / / Yes Yes

Q18. Sectors covered by the National regulation regarding GHS, Edition used (Rev, 2, 3,4)

Transport Industrial /

WorkplaceConsumer products

Agriculture / pesticides Other

Kosovo / / / / /Moldova / / / / /Serbia Yes/Rev 3 Yes/Rev 3 Yes/Rev 3 /Croatia / / / / /Albania / / / / /

Macedonia Yes No / Yes Yes

Belarus Yes/ SMGS Yes/ GOST 12.1.007-76

Yes/GOST 12.1.007-76 Yes /

Russia / / / / /Bulgaria Yes/Rev2 Yes/Rev 2 Yes /Poland ADR Yes/Rev 3 Yes/Rev 3 Yes/Rev 3 /Hungary Yes Yes Yes /Romania / / / / /

Q20. Transitional period in place for GHS implementation

Q21. Are all GHS hazard classes implemented for the sectors that are covered

Only Serbia, Bulgaria, Poland, Hungary and Romania answered to this question.“According to CLP only hazard categories that are not part of CLP are :

•“flammable liquids category 4”,•“acute toxicity category 5”,•“skin corrosion/irritation category 3”,•“aspiration hazard category 2” • “acute aquatic toxicity category 2 and 3”

Q22. Are GHS safety data sheets (SDS) accepted in your country today?

Country

Safety Data Sheets accepted

Yes No In process

Kosovo / / /

Moldova / / /Serbia Croatia Albania

Macedonia Belarus Russia Bulgaria Poland Hungary

Romania

Q23. Difficulties encountered in preparing the SDS due to lack of facilities and capabilities

Belarus: Lack of trained specialists, Absence of GLP laboratories, Legislation gaps.Russia: Lack of data. Different interpretation of existing data, Problems of reliability and Data inconsistencies.Serbia: One of the biggest problems is lack of data for classification of substances which are not in the List of classified substances or are not classified for all hazard classes. Very important problem for the downstream users (formulators) is the bad quality of SDS of imported substances. Also, there is a lack of capabilities for preparing SDS, especially in small and medium enterprises.

Q24. Support the cooperation and information exchange among the countries in the region for better

implementation of GHSAll countries support the cooperation and exchange of information in the frames of the CEE Region.Hungary: HelpNet Steering GroupBulgaria: The country is open to provide expertise and take part in CLP training seminars Poland: In 2011 Inspector for Chemical Substances implements three projects co-financed by the Polish aid program of the Ministry of Foreign Affairs (Armenia, Georgia and Moldova).Russia: Through TAIEX instruments

Q25. Existing accredited laboratories on GLP and cooperation with any relevant (Q26)

Accredited GLP laboratories Cooperation with GLP

Croatia Developing such practice

Macedonia1. Public health Institute-State owned2. Tehnolab-Private

/

Poland http://www.chemikalia.gov.pl/list_of_polish_labs_glp_certified.html

Hungary

National Institute of Chemical Safety, state owned http://www.okbi.hu/images/reach/laborlista_201002.pdf

Every GLP laboratory develops collaboration with other laboratories on their

own

Romania

Private institution It is not necessary, proposals for testing are controlled by ECHA and

tests methods are governed by Regulation 440/2008 under REACH, indirectly

OECD methods

Q27. Regional institution that coordinates the GHS implementation at regional level

•Slovenian Chemicals Bureau•Swedish Chemical Agency •GOST Standard•European Chemical Agency(ECHA)

Q28. Specific problems indicated in implementing the GHS

Country Indicated specific problemsBelarus Lack of political will, Legislation gaps,

No Register of chemicals, No Law on chemicalsCroatia Lack of staff and timeGeorgia: Inconsistent approach to classification of chemicals and distribution of the

information on hazards; Necessity of introduction of GHS (Ref. National Chemical profile, 2009)

Hungary Lack of human resource, quantitative and in expertise; Financial needs; Particularly small and medium-sized enterprises have the above mentioned difficulties

Poland In European Union GHS is implemented by CLP Regulation. According to the CLP Regulation each country has to establish: Competent Authority, Enforcement authority, National Helpdesk to provide advice to manufacturers, distributors, downstream users and other interested parties, Body responsible for receiving information relating to emergency health response. The main problem usually is concerning with division of responsibilities and preparing some changes in national law (very long process in Poland)

Serbia In certain cases where there is no other way to have access to data necessary for classification, and when it will be necessary to perform experimental testing in compliance with GLP principles, the problem for our industry will be where to perform those tests and the cost of these testing

Thank you for participating to this survey

Dr. Suzana AndonovaRegional GHS CEE Project Consultant