Key Concepts

Why is Chemical Hazard Communication important?

Chemical hazard communication is crucial for safeguarding human health and the environment by ensuring that everyone handling chemicals is aware of their hazards and knows how to manage them safely. Proper communication helps prevent accidents, reduces workplace injuries, and supports regulatory compliance, which is essential for maintaining safety and operational efficiency.

How does Chemical Hazard Communication vary across different countries?

Chemical hazard communication regulations can vary significantly from country to country, reflecting differences in regulatory frameworks and safety priorities. However, many countries have based their own hazard communication systems on the Globally Harmonized System (GHS) to standardize chemical hazard communication internationally, which provides a common approach to classifying and labeling chemicals. Despite this common framework, there are notable differences:

 

• United States: In the U.S., the Occupational Safety and Health Administration (OSHA) enforces the Hazard Communication Standard (HCS), which aligns with GHS principles revision 7. The HCS mandates that chemical manufacturers and importers provide labels with specific hazard symbols, signal words, and precautionary statements, as well as detailed safety data sheets (SDS). Employers are also required to provide training to employees on the hazards they may encounter.

• European Union: The European Union enforces chemical safety through the REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals) and CLP (Classification, Labeling and Packaging) Regulations. CLP requires detailed hazard labels, while REACH focuses on the registration and assessment of chemical substances and Safety Data Sheet (SDS). The EU's approach emphasizes comprehensive safety assessments and the provision of extensive information to both consumers and workers.

• Canada: Canada's regulatory framework follows the Hazardous Products Act and aligns with GHS through the Workplace Hazardous Materials Information System (WHMIS 2015). WHMIS requires labels to include hazard symbols and statements, as well as SDS that provide information on chemical hazards and safety measures. The integration of GHS has streamlined hazard communication but also includes specific Canadian adaptations.

• Oceania: In Australia, the Hazardous Substances Information System (HSIS) has been replaced by GHS-aligned regulations under Safe Work Australia. Australian regulations require that labels include hazard pictograms, signal words, and precautionary statements, and that SDS provide detailed information on chemical risks and safety practices. New Zealand has adopted a localized version of the GHS under the Hazardous Substances and New Organisms (HSNO) Act, administered by the Environmental Protection Authority (EPA New Zealand). The GHS is used to classify hazardous substances and standardize labeling and safety data sheets, ensuring consistent communication of chemical hazards across workplaces and industries.

• Asia & Pacific: Many Asian countries have adopted GHS standards, but the level of implementation, enforcement, and alignment with the UN’s GHS revisions varies significantly across the region.

  For example, Japan follows GHS principles under several frameworks, including the Chemical Substances Control Law (CSCL) and the Industrial Safety and Health Law (ISHL). These laws require classification, labeling, and the provision of safety data sheets (SDS), but with country-specific hazard categories and disclosure thresholds.

  China has implemented its version of GHS through the Administrative Measures for the Registration of Hazardous Chemicals and standards such as GB 30000 for classification and labeling. While largely aligned with GHS Rev. 4, China imposes additional requirements for registration, local data use, and SDS language and formatting, making local compliance more complex.

  Other countries in the region, such as South Korea, Thailand, and Indonesia, have also adopted GHS with varying degrees of completeness and enforcement. For instance, South Korea enforces GHS under its Occupational Safety and Health Act (OSHA) and maintains a regularly updated list of classified substances.

  Due to these regional differences, companies must carefully consider local adaptations of GHS to ensure compliance with each country’s specific regulatory framework.

• Latam: Several Latin American countries are in different stages of adopting and implementing the Globally Harmonized System (GHS) for classification and labeling of chemicals. While most countries in the region have formally adopted GHS principles, the scope, enforcement, and version alignment vary.

  - Brazil has fully adopted GHS through Norma Regulamentadora NR-26, which requires standardized labeling and SDS for hazardous chemicals in the workplace. It aligns closely with GHS Revision 7, and updates continue to be made through national technical standards such as ABNT NBR 14725.

  - Mexico enforces GHS via the standard NOM-018-STPS-2015, which mandates hazard classification, labeling, and SDS requirements in line with GHS Rev. 5. This standard is mandatory for all workplaces handling hazardous chemicals.

   - Argentina adopted GHS through Resolution SRT 801/15, requiring GHS-based classification and labeling for workplace chemicals. The country follows elements of GHS Revision 5.

   - Chile implemented GHS via Decree 57/2019, which became mandatory in 2022 for industrial use and establishes requirements for classification, labeling, and SDS aligned with GHS Revision 7.

  - Costa Rica adopted GHS through Executive Decree No. 40457-S-MTSS, with gradual implementation depending on the sector and product type. The country is working to harmonize with the latest GHS revisions.

  - Colombia regulates GHS implementation under Decree 1496 of 2018 and Resolución 773 de 2021, which establishes the technical guidelines for classification, labeling, and SDS preparation, following GHS Revision 7. 

  - Uruguay has advanced GHS adoption through Resolution 45/2019 by the Ministry of Labor, which sets criteria for hazard classification, labeling, and SDS aligned with GHS Revision 7. The country is actively working toward full enforcement across industries.

  Other countries such as Peru and Paraguay are also making progress through draft legislation or voluntary guidelines. Due to this regulatory diversity, businesses operating in LATAM must stay informed of national updates to ensure compliance with country-specific GHS adaptations.

 

Understanding these variations is crucial for multinational companies to ensure compliance with local regulations while maintaining a consistent approach to chemical hazard communication globally. Adapting to these requirements helps in managing chemical safety effectively and meeting regulatory obligations across different jurisdictions.