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Analysis

International Harmonization Method's Impact on Oil Industry

Wed, 01/22/2014 - 16:36

- The Globally Harmonized System of Classification and Labeling of Chemicals, or GHS, developed by a United Nations committee of experts, seeks to facilitate international trade through the standardized classification and labeling of chemicals and to improve the overall clarity of available hazard information. GHS itself is not a regulation. Instead, it is an internationally recognized harmonization method to classify hazards and communicate them throughout the supply chain. Regulatory authorities adopt the UN standard through their national regulatory processes. For this reason, variations still remain among countries, but the much desired “harmonization” is closer than ever before.

Mexico’s adoption of GHS was initially aimed to assist the country’s chemical industry, which was previously burdened with dual labeling and safety data sheets (SDS) requirements, including both GHS and Mexican standard NOM-018-STPS-2000. The latter is a domestic system for identification and communication of hazards and risks of hazardous chemicals in the workplace. In an effort to harmonize the requirements, ANIQ, the National Association for the Chemical Industry in Mexico, requested authorization to use the non-binding NMX-R019-SCFI-2011, Mexico’s GHS, as an alternate to complying with NOM-018-STPS-2000. On June 29, 2011, the Ministry of Labor authorized ANIQ to use the GHS standard, particularly because NMX-R-019-SCFI-2011 complied with the provisions of Chapters 7 and 8 of NOM-018-STPS-2000. Chapter 7 is an identification system of hazards and risks of dangerous chemicals, while Chapter 8 addresses hazard communication and training for dangerous chemicals.

Mexico’s GHS provides the elements of a uniform hazard communication for chemical products, labeling requirements, and safety data sheets. The standard contains five annexes:

• Annex 1: Labeling symbols, pictograms, and warning phrases

• Annex 2: Summary Tables of Classification and Labeling

• Annex 3: Hazard and Precautionary Statement Codes

• Annex 4: Guide for the elaboration of Safety Data Sheets with a 16-Section format. The terminology must comply with that of the Hazard and Precautionary Statement to facilitate translation into user language.

• Annex 5: Labeling of consumer products according to the potential health damage they can cause.

When evaluating the impact of GHS on Mexico’s oil and gas industry, it is important to remember that petroleum substances are not mixtures. They are chemical substances, derived from crude oil and later distilled and modified. As such, these substances can be classified into various groups. The resulting data lessens the need for animal testing. As with companies that follow OSHA regulation in the US, impacted companies will have to shift from risk-based classification to hazard-based classification. Mexican GHS also introduces symbols for labels, and does not maintain the previously used colorbased system. Moreover, GHS provides a more consistent and reliable classification of petroleum substances that provide good hazard communication, reducing risks in storage and handling. All in all, consistent classification results in reduced costs for both the chemical industry and the countries implementing the GHS system. 

The efforts on behalf of ANIQ have paid off in that the chemical industry has been granted relief from the unnecessary burden of having to prepare NOM-018-STPS-2000, which remains in force, and the requirement of preparing GHS Safety Data Sheets when importing into GHS regulated countries. Today, the chemical industry in Mexico has the option of using the older standard or the voluntary GHS to classify, label, and prepare SDSs. Notwithstanding, the use of GHS not only harmonizes classification, labeling, and SDSs, but also makes companies more competitive in GHS markets. As companies increasingly begin to turn to GHS as opposed to NOM-018- STPS-200, there is a possibility that the GHS standard (NMXR-019-SCFI-2011) will be made mandatory, with the current standard (NOM-018) being repealed outright.