Japan Soap and Detergent Association (JSDA)

June 2010


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No. 32 (June 2010)


Inside of this issue
1.Guidance for GHS Practice Successfully Developed
2.Revised Act on the Evaluation of Chemical Substances and Regulation of their Manufacture (AECS) will be soon enforced

1.Guidance for GHS Practice Successfully Developed

Japan Soap & Detergent Association
GHS Examination Working Group

●Aiming at providing safety information on chemicals at first sight

United Nations issued the GHS recommendation in 2003. In order to discuss how to deal with this issue, the GHS examination working group of Japan Soap & Detergent Association (JSDA) was formed in 2004.

Prior to publishing the guidance as an industry self-imposed standard, JSDA gave a speech regarding the guidance in the steering team meeting of Asia Oceania Soap and Detergent Association Conference (AOSDAC) held in Australia in October, 2009, followed by the press release in Japan on November 16.

GHS is an abbreviation of Globally Harmonized System of Classification and Labeling of Chemicals. While "chemicals" generally mean materials for industrial use, the GHS definition broadly includes consumer product containing chemicals as well.

The classification and labeling in GHS requires providing the safety information by 1) classifying hazard type and degree of the chemical or the mixture according to rules globally united, and 2) providing labeling, which shows the safety information at a glance, and its Material Safety Data Sheet (MSDS).

●Aiming at providing labeling globally unified

The primary purpose that GHS was enacted is to preserve people's health and environments. More specifically, it is to provide an international frame, which either removes the difference of measures in the classification and labeling of chemicals, or avoids repeating technical assessment for the same chemical in each country.

In net, it is expected that the GHS practice should result in easier handling of chemicals distributed all over the world and thus the smooth expansion of the international trade development, while unexpected accident is potentially prevented even in different country or language.

GHS has not yet been introduced into consumer products in any countries in the world, though the GHS introduction into industrial chemicals has already started in many countries. For instance, Industrial Safety and Health Law of Japan revised in 2006 requires the labeling and the MSDS defined in GHS to some materials, but general consumer products are excluded.

Similarly, consumer products are out of the scope of the GHS application in Asian countries, though South Korea, China, Taiwan, etc. are legislating GHS into law for industrial and commercial chemicals.

●Beginning from three product categories

Each industry association responsible for consumer products has been seeking the approach for GHS independently with the support of related government agencies in Japan. Especially, JSDA has promptly worked on the technical guidance development, while placing major efforts in the penetration activities within the industry such as conducting internal briefings, aiming at voluntary introduction of GHS into consumer products such as soap and detergents.

The first edition of the guidance was recently published as self-imposed standard, which contains 1) GHS Practice Guidance for Household Consumer Products and 2) GHS Labeling Guidance for Household Consumer Products. It should not be, however, considered that this is the end of the work, but rather should be considered that the guidance will be further revised by examining and consolidating opinions given to the first edition.

In the guidance, the labeling example is shown for typical consumer products along with the approach for classification determined by the risk assessment based on the chronic toxicity. Each manufacturer should develop the labeling of own products by classifying the products and examining whether and, if necessary, how to display it in the labeling according to the example shown in this guidance.

Current plan for the deployment is to introduce GHS-based labeling gradually on products in the product categories narrowed down by priority from January, 2011, in cooperation with Japan Soap and Detergent Co-operative Association and Japan Acid and Alkaline Household Cleaner Association. As the first step, three product categories are chosen, which are; 1) dish-washing detergent (excluding detergents for automatic dish washer), 2) chlorine bleach, and 3) chlorine and acid cleaner (limited to products with the cautionary statement - "Dangerous! Don't Mix" in the current labeling). The reason why dish-washing detergent has been chosen is that the penetration ratio and using frequency in general household are high and thus there are a lot of chances that consumers would see the labeling. Regarding the chlorine bleach and the chlorine and acid cleaner, the industry has been long rousing attention on their handling by the labeling with "Dangerous! Don't Mix".

●No changes in safety profile of the product

It needs to be importantly noted that the GHS labeling is not necessarily applied to every product. Moreover, it means neither that a product with the GHS labeling is dangerous, nor that the product should not be used.

To the product, which requires special handling, the usage instruction by writing or illustration voluntarily developed by the industry has been already applied in order to avoid the potential accident or the health hazard. GHS is just an addition to the usage instruction already available to the product.

A Guide to implement the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) in Consumer products

2. Revised Act on the Evaluation of Chemical Substances and Regulation of their Manufacture (AECS) will be soon enforced

-- Conversion of the regulatory focus from hazard to safety risk

Chemicals play a big role to support current society widely; however, quite a few chemicals have some hazardous properties. Therefore, there are various regulations on the use and manufacturing, etc. of chemicals besides the self-imposed restraint by the industry.

AECS was enacted in Japan in 1973 with fundamental difference from the former regulations.

Regulations to chemicals before AECS were to restrict poisonous and deleterious substances, to limit exhaust gas emission or industrial waste water, etc. AECS was the law which first aimed at direct control of industrial chemicals in Japan. The environmental pollution caused by PCB around 1965 actually led its establishment.

AECS was enacted to prevent person's health damage from environmental pollution by a chemical having similar chemical properties to PCB; i.e. 1) difficult to degrade in normal environment, 2) accumulated easily in the body of the living thing and 3) having a potential to damage person's health when continuously taken. Actually, the law first carried out an approval system before manufacturing or importing new chemicals. Chemicals which have low biodegradability, high accumulation in the body of the living thing, and prolonged toxicity are subject to official approval, and their use is restricted or prohibited.

In the current system, three hazard properties are used for the examination of new chemicals, i.e. 1) biodegradability, 2) biological accumulation and 3) toxicity to the person or animals.

For chemicals which had been allowed to use before the enactment, mainly the government has been conducting the investigation of their technical acceptability, while the manufacturer also has been doing it based on the OECD High Production Volume Chemical safety assessment, Japan Challenge Program, and so on. However, it requires huge time and cost to complete evaluation for all the chemicals, which are counted around 20,000.

Provided that the safety issue and the concern spread worldwide, the international safety assessment target was agreed in Earth Summit of United Nations in 2002, and the sustainability of regulatory system which meets the agreed standard became an issue in each country. REACH was enforced in EU in 2007. In Japan, the revised AECS was promulgated in May, 2009, and it will be enforced in two stages in April of 2010 and 2011.

The key point of the revision was to introduce a comprehensive management system even for chemicals currently available, and to include chemicals which can be easily degraded in the environment. Moreover, it should be especially noted that the main focus has been changed from the management system based on hazard property to the possibility of influencing humans, animals and/or plants, i.e. the management system based on "risk", taking discharge to the environment into account. Proper cooperation of the government and the manufacturer is then essential to promote effective and efficient chemical management in the future.

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