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)”

Dr. Suzana Andonova Regional GHS CEE Project Consultant

Regional Stocktaking Workshop on the GHS implementation in CEE

Chisinau, Republic of Moldova 17-19 July 2012

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.

Region.

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

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 Feedback

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

Invited countries

Albania Armenia Azerbaijan Belarus Bosnia and Herzegovina Bulgaria Croatia Czech Republic Estonia Georgia

Responding Countries Albania Belarus Bulgaria Croatia Invited countries

Hungary Kosovo Latvia Lithuania Republic of Macedonia Montenegro Republic of Moldova Poland Romania Russia Serbia Slovakia Slovenia Ukraine

Responding countries Hungary Kosovo Republic of Macedonia Republic of Moldova Poland Romania Russia Serbia

List of the contact points in the respondent countries

Country Kosovo Moldova

Name Violeta Lajqi-Makolle Liudmila Marduhaeva Aleksandra Zujic

Contact Point

Title/ Responsible Institution Senior Officer for chemical management/ Ministry of Environment and Spatial Planning-MESP Main Advisory Officer /Ministry of Environment

Serbia Croatia Albania Macedonia Belarus

Biserka Bastijančić-Kokić/ Nenad Lamer Lindita Tafaj Marin Kocov Irina Ilyukova Liliya Najaran International Cooperation and Projects Coordinator/ Serbian Chemicals Agency Ministry of Health, Directorate for Sanitary Inspection SAICM Focal Point/ Institute of Public Health SAICM National Focal Point/POPs&Ozone Unit/MoEPP

Russia Bulgaria Poland Hungary Romania

Makarova Anna Sergeevna Hristina Filipova Mariusz Godala Szymon Domagalski Gabriella Füle Liliana Luminita Tirchila Republican Scientific Practical Centre of Hygiene Institute of Chemistry and Sustainable development( РХТУ им.Д.И.Менделеева) Chief Expert/Ministry of environment and water Bureau for Chemical Substances Ministry of Rural Development SAICM National Focal Point/MINISTRY OF ENVIRONMENT and FORESTS

Survey findings

Q1.Status of development of chemical industry in CEE countries Q1 Level of development of chemical industry Q2.Source of chemical products Q2 Source of chemical products Country

Kosovo Moldova Serbia Croatia Albania Macedonia Belarus Russia Bulgaria Poland Hungary Romania

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 Convention • 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 Convention • 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 Convention • 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

17% 33%

GHS Implementation in CEE Region

50% Fully implementing/ Serbia,Croatia, Hungary,Poland, Romania,Bulgaria Early stage of Impl./Macedonia,Moldova,Belarus,Russia No action /Kosovo,Albania

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

Country Albania Belarus Bulgaria Croatia Hungary Kosovo Macedonia Moldova Poland Romania Russia Serbia Inter-ministerial or inter-institutional coordination body Committee for pesticide registration, committee for biocides. ToR have been prepared for an Inter sectorial Committee for Chemicals Management (Safety) Yes Yes Yes Yes No National Inter-ministerial Working Group for chemical management comprised by the representatives from the Ministry of Environment, Finance-Customs Administration, Health, Agriculture, Crisis management Centre, Poisoning Centre National Inter-ministerial Working Group, mandated to implement the Chemical MEAs, SAICM and National Programme on Sound Management of Chemicals Yes Yes Yes/CIS 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

Country

Kosovo Moldova Serbia Croatia Albania Macedonia Belarus Russia Bulgaria Poland Hungary Romania

Level of awareness on GHS in CEE Region Very low Medium High

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

No action taken Current status of GHS implementation- Sector transport Preparing Situation analysis Preparing for revising for establishing prepared or under related legislation/ new legislation/ Already implement ing GHS preparatio n administrat ive procedures administrat ive procedures Other Country Kosovo Moldova Serbia Croatia Albania Macedonia Belarus Russia Bulgaria Poland Hungary Romania

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

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/ administrativ e procedures Already implemen ting GHS Other Country Kosovo Moldova Serbia Croatia Albania Macedonia Belarus Russia Bulgaria Poland Hungary Romania

Q13D Current status of GHS implementation- Sector Agriculture/Pesticides

No action taken Current status of GHS implementation- Sector Agriculture/Pesticides 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 Country 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

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 Country 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

Kosovo Moldova Serbia Croatia Albania Macedonia Belarus Russia Bulgaria Poland Hungary Romania / / Yes / / Yes No Situati on/ Gap Analys is / No Yes Yes / Compreh ensibility Testing / / Yes / / No Yes/ 2008 / No Yes Yes / Impact Study and/or Cost Benefit Analysis First Draft of the Implem entation Instrum ent / / No / / / / / No / / Yes No / No Yes Yes / Consult ation with Stakeho lders / / Yes / / Yes Yes/2011 Yes/2010 11 / / / Yes Yes Yes / Yes Yes / Develop ment of a GHS National Impleme ntation strategy Final Adoption of the Impleme ntation Instrume nt Training courses for GHS implem entation / / No No / No / / No Yes / No / / Yes Yes / No Yes / No Yes Yes / No / Yes Yes Yes Yes Yes/2008 11 / Yes Yes Yes Yes

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

Kosovo Moldova Serbia Croatia Albania Macedonia Belarus Russia Bulgaria Poland Hungary Romania Transport / / / / Yes Yes/ SMGS / ADR / Industrial / Workplace / / Yes/Rev 3 / / No Yes/ GOST 12.1.007-76 / Yes/Rev2 Yes/Rev 3 Yes / Consumer products / / Yes/Rev 3 / / / Yes/GOST 12.1.007-76 / Yes/Rev 2 Yes/Rev 3 Yes / Agriculture / pesticides / / Yes/Rev 3 / / Yes Yes / Yes Yes/Rev 3 Yes / / / / / / / Other / / / / / Yes

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?

Safety Data Sheets accepted

Country 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 GHS All countries support the cooperation and exchange of information in the frames of the CEE Region.

Hungary: HelpNet Steering Group Bulgaria: 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)

Croatia Macedonia Poland Hungary Romania Accredited GLP laboratories Cooperation with GLP

1. Public health Institute-State owned 2. Tehnolab-Private http://www.chemikalia.gov.pl/list_of _polish_labs_glp_certified.html

National Institute of Chemical Safety, state owned http://www.okbi.hu/images/reach/l aborlista_201002.pdf

Private institution Developing such practice / Every GLP laboratory develops collaboration with other laboratories on their own 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

Country Belarus

GHS

Indicated specific problems

Lack of political will, Legislation gaps,

Croatia Georgia: Hungary Poland Serbia

No Register of chemicals, No Law on chemicals Lack of staff and time Inconsistent approach to classification of chemicals and distribution of the information on hazards; Necessity of introduction of GHS (Ref. National Chemical profile, 2009) Lack of human resource, quantitative and in expertise; Financial needs; Particularly small and medium-sized enterprises have the above mentioned difficulties 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)

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 Andonova

Regional GHS CEE Project Consultant