On March 19, 2019, the 9th meeting of the United Nations TDG and GHS Expert Committee released the main technical revisions of the 8th revised edition of the United Nations GHS. The 8th revised version of GHS is expected to be officially released around July 2019. Since its introduction in 2003, the United Nations GHS system has gradually been adopted by multiple countries/regions such as the European Union, Japan, the United States, and China, and has been transformed into their respective chemical management systems or standards. Therefore, the revised content of the GHS system will gradually be incorporated into the existing system by various implementing countries.

In the previous compliance interpretation, we briefly summarized the main updates in chemical classification. In this interpretation, we focus on the updates regarding the use of GHS labels in this revision.

1、 Attachment 3 has been updated

In this revision, a graphic representation method for the prevention instruction P102 "Stay Away from Children" has been added to Section 5 of Attachment 3 of the GHS system, mainly adopting two graphics that have been promoted and used in daily consumer goods by AISE (International Soap, Detergent and Maintenance Products Association) and JSPA (Japan Soap and Detergent Association), as shown in Figures 1 and 2 respectively.

As shown in Figures 1 and 2, compared to the previous textual description P102, using graphical representation appears more direct and vivid.

2、 Attachment 7 has been updated

Attachment 7, as a guide for the actual use of GHS labels, has added pleated labels for small containers in the 7th revised edition. This revision has added GHS label usage example 10, with a focus on chemical kits containing multiple small bottles. This type of product is often encountered in the research and laboratory testing of pharmaceuticals and pesticides, where a single outer packaging contains multiple small packages of chemical reagents. The specific content is as follows:

When the surface area of each small package in the set is too small to attach all the information of GHS label and the content cannot be guaranteed to be clear and visible, the following two alternative solutions can be used:

Scenario A:

A chemical kit: It has an outer packaging containing 4 reagent bottles containing 1 # reagent and 2 larger packages containing 2 # reagent, as shown in Figure 3.

Figure 3 Schematic diagram of chemical kit

At this point, the solution for GHS labeling is as follows:

① The surface space of each inner container is limited, and only GHS labels can be attached as shown in Figure 4.

√ Product identification

√ Pictogram

√ Signal words

√ Prompt: "Please read the complete label"

Supplier identification (including name and phone number)

Figure 4 GHS label information of inner packaging products

② The GHS label information on the outer packaging is divided into four parts, as shown in Figure 5:

The supplier of the entire set of products;

The pictograms, signal words, product identification, and supplier identification of reagent 1 # and reagent 2 # respectively;

√ Precautions for 1 # reagent and 2 # reagent respectively;

Storage requirements and general prevention instructions for the entire product.

Figure 5 GHS label information on the outer packaging

2. Scenario B:

A chemical kit containing multiple small sample bottles, each containing a different chemical reagent. Each sample bottle is always stored in the outer packaging, and users usually select a single sample bottle from it to check its color, odor, and transparency before putting it into the kit. This type of outer packaging, as shown in Figure 6, cannot have GHS label information for all chemicals on its outer surface due to size and shape limitations.

Figure 6 Schematic diagram of the set for Scenario B

This time, the GHS system revision proposes a solution:

① Single inner packaging

Due to limited surface space on the inner packaging, the following GHS label elements can be optionally affixed, as shown in Figure 7.

√ Supplier identification

√ Product identification

√ Signal words

√ Pictogram

√ Prompt: "Please read the complete label included"

Figure 7 Schematic diagram of GHS label for inner packaging

② Inside the outer packaging

An additional complete label containing GHS information for each chemical should be attached inside the outer packaging, as shown in Figures 8 and 9.

Figure 8 Sample of GHS label inside the outer packaging

Figure 9: The method of attaching the complete GHS label to the outer packaging

For products without GHS hazards inside the outer packaging, it is also possible to indicate on the complete GHS label that the product belongs to "does not comply with GHS classification standards" or "not classified", to avoid misunderstandings caused by the lack of some product information when users view the label.

If there are multiple types of samples and hazards in the inner packaging, and there are many elements of GHS labeling, even if the above measures are taken, it may not meet the basic requirements of regulations for GHS labeling.

③ Outer surface of outer packaging

Due to limited space, the outer surface of the outer packaging only needs to display the following GHS label information:

√ Product identification for the set

√ Supplier identification

Storage and general prevention instructions for the set

√ GHS pictograms for each chemical inside (merged with similar items, non repetitive)

√ Signal word (choose the strictest one among all the chemicals inside)

√ Prompt: "Please read the complete label included"

3、 Summary

In this compliance interpretation, we continue to summarize the main technical changes of the 8th revised edition of the United Nations GHS system, with a focus on explaining a new solution for small packaging products that cannot be labeled with complete GHS information due to their small packaging surface area. From the recent revisions and changes, we have found that the United Nations GHS and TDG Expert Committees have paid more attention to the various problems encountered in the practical application of GHS labels and have been committed to providing more comprehensive solutions to the industry.