Nearly four years ago (30 April 2021) New Zealand adopted the GHS classification system for hazardous substances. This saw the HSNO classifications we have used since 2001 (and that were based on the first draft of GHS) being gradually replaced by the GHS 7 system.
Janet Connochie our Senior Hazardous Substances Consultant, Compliance Certifier and Director has written this piece to help point out some changes that may affect your business.
The implementation takes place over a period of time
- Updates to approvals, group standards and EPA databases such as the CCID were undertaken back in 2021. https://www.epa.govt.nz/database-search/chemical-classification-and-information-database-ccid/
- A transition period ending 30 April 2025 applies for the updated EPA Notices for Labelling, Packaging and Safety Data Sheets.
- The Health and Safety at Work (Hazardous Substances) Regulations still refer to the HSNO classifications – the EPA correlations are used.
Labelling, Packaging and Safety Data Sheets
The transition period for compliance with these updated EPA notices ends on 30 April 2025 – this applies both to the manufacturer/importer and the end supplier.
If your labels & SDS complied with the 2017 notice (based on the 5th edition of the GHS) then they are most likely to comply with the updated notice (based on the 7th edition GHS) – [side note – prior to that the ERMA Technical Guide from 2006 was based on the 1st edition of the GHS].
If you have desensitised explosives or flammable gases, there are changes to the classification framework that need to be reflected in the labels.
There are alternative provisions available for importers or exporters to follow the labelling and SDS requirements of Australia, USA, Canada or the EU provided that the required NZ-specific information is included – such as NZ contact details for manufacturer/importer and NZ emergency contact; restrictions on supply; HSNO approval.
Click below for more information – EPA Transitional period in Labelling, Safety Data Sheet and Packaging Notices ends on 30 April 2025
Signage
There is no requirement to change your hazardous substances signage to use the GHS pictograms – in fact this can be less helpful. The regulations require signs to
state the hazardous properties and describe the general type of hazard relating to each category of hazardous substance present through the use of-
(i) hazard pictograms consistent with the correct classification of the hazardous substances present; or
(ii) hazard statements consistent with the correct classification of the hazardous substances present; and
The pictogram can be either the GHS or the UN Model Regulations (transport / DG pictogram) and the GHS documentation includes both.
The GHS flammable pictogram covers multiple hazard classifications – flammable gases, liquids and solids which are illustrated by 5 distinct DG pictograms.
It is not non-compliant to use the GHS pictograms, but it is more informative to use the DG ones.
While we’re talking about signage – take a check
- Is all required wording on your sign clearly legible from 10m – including in rain or poor lighting conditions. Guidance on the size of the lettering is
- 50mm for capitals
- 40mm for lower case
- 30mm may be acceptable in good lighting conditions
- Is the sign durable, resistant to fading (requiring minimal maintenance)
Contact us for more information, our consultants are more than happy to discuss how we can help your business and workers or answer any questions.