evatech
Safety Management Services
Nelson, New Zealand
HSNO Issue 75. May/June 2009. Bruce Evans, Evatech, Nelson
HSNO Labeling delays cause confusion. Does big brother know best?
Last issue I made some observations prompted from my summer experiences across the Tasman on the link between good signage and effective hazard management.
One comment was that HAZCHEM signage was more widely used in Australia and less so here.
This latest article is also prompted by inter country differences over label warnings, signage and the uptake of regulatory guidance on this vexed question.
As should be well known now New Zealand is one of the only countries if not the only one to have adopted the United Nations driven Globally Harmonised Chemical Classification and labeling system known as the GHS.
We call our version of the GHS HSNO and we watch with interest as the Aussies have yet another look at whether the United Nations recommended scheme is for them as well. Don’t hold your breath.
Who cares anyway; what difference would it make if we were singing from the same labeling guidebook?
Have you had a look at how many of your consumer, hygiene and specialty products come from across the Tasman, let alone the significant proportion of agrichemicals that are labeled across the Tasman to NZ HSNO specifications then shipped over here for consumption?
Many chemical handlers express confusion and frustration about labeling differences when they try and find HSNO label requirements on their Australian sourced stock and Safety Data Sheets that are supposed to be HSNO’ised by now.
I have encountered this labeling frustration when conducting Approved Handler training.
I normally ask customers to bring to the training typical examples of the products that cause them compliance headaches. There is no shortage of products with Australian labels or labels from NZ companies without HSNO requirements.
It needs to be said at this point that I am not talking in 2009 about what used to be called Registered Pesticides - these were transferred into the HSNO system many years ago.
The majority of their labels used to be heavily regulated by label prescriptions driven by MAF, and most NZ proprietors are now using the industry driven HSNO guidelines and Codes of Practice.
The confusion and lack of uniform labeling standards comes primarily from the large number of previously non-regulated products that were transferred into the HSNO system about three years ago.
All industries have large numbers of these products that are supposed to be regulated by the Group Standards process which will continue to accept labels from other countries, including Australia, Canada, the EU and the USA until December 2010.
This Group Standard approach is leading to a very slow uptake of labels that are HSNO’ised and so the lack of understanding in things compliance continues.
I would have thought that the end of 2010 would have been late enough to expect labels being read in NZ to have some reference to our legislative requirements.
Imagine my consternation when I read in the media that the Australian National Industry Association [ACCORD] wants even more time to get around to meeting our labeling standard.
The Aussies want another 10 years to take the labeling deadline out to December 2020!
What do we care? Is it okay to allow another decade of delay and feet dragging, when our own agricultural industry completed the HSNO labeling process in just a few years?
Would the Australian proposal mean that NZ companies who do not import from those four countries and label Kiwi products have another ten years as well to change their labels? How would you feel if your company has already met the labeling change deadline and you see competitors dragging out the changes for a decade longer than you?
Want to comment?
If you want to comment on this latest proposal to delay labelling change, ERMA will take a submission from you, but act fast; the closing date is 5 June. submissions@ermanz.govt.nz
To see the consultation document on this proposal for yet more labeling delay visit ermanz.govt.nz
Other label related inter-country differences come to light when you look at some of the background information on the proposal for Australia to adopt the GHS labeling system.
Their Productivity Commission’s Review of Chemicals and Plastics Regulation sees the benefits offered by the GHS, but also notes that Australia’s implementation of the GHS should be delayed until it can be demonstrated that the system would deliver a net benefit.
In response to the recommendations of the Productivity Commission, the Council of Australian Governments (COAG) has subsequently agreed that implementation of the GHS in the workplace chemicals sector should not occur unless there is a demonstrated net benefit to the community and not in advance of Australia's major trading partners!
One of those key trading partners the EU has set a transition timeframe of 2010 for the adoption of the GHS for chemical substances and 2015 for mixtures.
Mind you their had been a previously recommended 2008 target for the wider adoption of the GHS. Talk about sliding timeframes.
What chance have we got of ever seeing Aussie generated GHS/HSNO labels?