DOC《UN/SCETDG/28/INF.42》

UN/SCETDG/28/INF.

42 COMMITTEE OF EXPERTS ON THE TRANSPORT OF DANGEROUS GOODS AND ON THE GLOBALLY HARMONIZED SYSTEM OF CLASSIFICATION AND LABELLING OF CHEMICALS Sub-Committee of Experts on the Transport of Dangerous Goods Twenty-eighth session Geneva,

28 November C

7 December

2005 Item 11of the provisional agenda HARMONIZATION WITH GHS Submitted by the Expert from the United Kingdom In considering paper C4/2005/6 to be presented to the next session of the GHS Sub-Committee, members of the Transport Sub-Committee may find the United Kingdom transport sector guidance note below helpful in understanding how the GHS Building Block approach is intended to be applied. It may be appropriate to propose to the GHS Sub-Committee that, in addition to proposed amendments to Part

1 of the GHS book, this guidance might be included as an annex to the Building Block principles text. GHS - THE BUILDING BLOCK APPROACH THE UK UNDERSTANDING (Transport) CLASSIFICATION The Competent Authority for a sector may determine whether or not it needs to address a particular endpoint for which criteria are offered in the GHS. Example: the transport sector may decide that it does not need to address Reproductive Toxicity in its regulatory system If the Competent Authority for a sector does address an endpoint for which criteria are offered in the GHS, and the endpoint has only one category of hazard within it, that category must be applied without alteration of or deviation from the GHS criteria. Examples: the endpoints '

Corrosive to Metals'

, and '

Respiratory Sensitisation'

have only one category. If these endpoints are adopted they must be applied unchanged Where an endpoint is divided into more than one category, the competent authority for a sector may decide to use only those categories that are relevant to its purposes. However, it may not change the thresholds within any particular existing category addressed by GHS. Example 1: for liquids, the endpoint of flammability is divided into four categories. The Competent Authority for the transport sector has chosen to use Categories, 1,

2 and

3 but not Category 4. Thus flammable liquids with a flash point >

60°C and ≤ 93°C are not addressed in the UN Model Regulations. However, the competent authority for transport has also amended the upper threshold of ≤60.5°C for its Packing Group III (the equivalent of GHS Category 3) to ≤60°C to align with the GHS threshold. Example 2: for the end points of '

Acute toxicity: Oral, Skin and Inhalation'

the GHS provides for

5 categories. Category

5 extends the criteria beyond the limits (e.g. 2000mg/kg bodyweight) presently used in EU classification system. In drawing up legal requirements to adopt the GHS in Europe, Member States could choose to adopt categories 1, 2,

3 and

4 only. NOTE: In determining the categories they wish to adopt competent authorities should start with the most hazardous and, where more than one GHS category is adopted, categories should not be skipped. If the Competent Authority for a sector wishes to address an endpoint at thresholds outside the current GHS criteria i.e. above the maximum or below the minimum thresholds, it may do so and may set whatever categories it wishes to;

provided that these do not overlap or alter the GHS criteria. Example: for substances Hazardous to the Aquatic Environment a sector may wish to utilise a Category Acute

4 that extends beyond the current maxima for L(E)C50 of

100 mg/l. HAZARD COMMUNICATION GHS provides for hazard communication for the endpoints it addresses, but also recognises the continued use the existing transport labelling system and of other labelling and communication systems for information not included in GHS. Example 1: the competent authority for the transport sector requires labels for the primary hazard of a substance and for any subsidiary hazards e.g. methanol, a flammable liquid, will be assigned a flammable liquid label for its primary hazard but also a toxic label for its toxicity subsidiary hazard. Example 2: the competent authority for transport sector also sets labelling requirements for the transport of radioactive material, an endpoint not addressed in GHS. GHS labelling comprises three elements: a symbol;