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Summary of status of the GHS regional implementation Regional Project “Evaluating and...
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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