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HawesM2
Matthew Hawes

GHS and emergency response

12/07/2013

The implementation of the Globally Harmonised System (GHS) around the world has meant that there is now a greater similarity in the structure of safety data sheets (SDS). This is because their format is one of the areas where GHS has provided guidance (Annex 4). The GHS guidance states that part of the information included in section 1 of a SDS is a requirement for an emergency number to be listed. The GHS guidance only states that an emergency number and its hours of operation be listed.

If you supply your products to overseas markets this raises the question of how would you respond to a call from a non-English speaker with an emergency involving your product. It is conceivable that you employ a German or Spanish speaker but what if the caller was Korean or Russian?

An additional complication is that where GHS has been implemented it has been used as a basis for each legislature’s regulations, for example as CLP in the EU. In a number of cases the emergency number requirement is more prescriptive than that outlined in GHS. The most common requirements are that the telephone be manned 24 hours a day and answered in the language of the country. Where a country has more than one official language often the emergency number may be required to be answered in one, some or all of them. In India under the Hazardous Substances (Classification, Packaging and Labelling) Rules 2011 Section 8.3.d all labels must contain a 24 hour emergency number which must be answered in English or Hindi. Another common requirement is that the number be local to the relevant country, e.g.: in China the listed emergency number must be a Chinese number.

Though these requirements are can simply be met by companies with 24 hour operations in the country they can represent a challenge for those who don’t (and even for those with local operations but no guarantee of a specialist being available 24/7 and with constant access to product data). For example it would be difficult for a small or medium sized company to ensure that they have country located number for all of the markets in which they trade or are able to answer a call 24 hours a day in the required language. Where the regulations are more prescriptive the penalties for non-compliance are often harsher, such as fines, seizure of goods, or prohibition from trading if the requirements are not met.

For companies that trade in overseas markets there are questions that they need to ask themselves to help ensure that they remain compliant. These include;

-    Where do we trade?
-    What are the regulations in these countries?
-    Can we fulfil our obligations?

Even where the requirements are the same as GHS, being unable to satisfactorily answer an emergency call can result in a decline in customer relations and negative media reports which can both result in a decrease in orders.
Remember though that supply legislation is only part of the story, the goods need to be transported to the customer so you need to check that there are no additional requirements in the country’s transport legislation. Examples include;

-    Mexico, The Mexican Official Standard NOM-005-SCT/2008 Emergency for the Transport of Hazardous Substances, Materials and Wastes lists, Section 4.1.1 2
-    Australia, The Australian Dangerous Goods Code ADG7 14.2.1
-    Mercado Común del Sur, which incorporates Argentina, Brazil, Paraguay and Uruguay, MERCOSUR\CMC\DEC No. 2/94 Chapter IV Article 23

A number of companies are able to assist by providing a 24 hour telephone emergency response service. A smaller number are capable of multilingual response, with fewer still able to offer country located numbers. When choosing a company to provide your emergency response you need to ask of them the same questions you asked yourself about fulfilment of your obligations. Can they really provide a guaranteed 24 hour response, can they provide the response in the languages required and can they offer country located numbers where compulsory?

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