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Last month, 3E hosted a well-attended webinar on “GHS in New Zealand - Exploring the Proposed Adoption for Workplace and Consumer Product Safety.” During the webinar, Nhat Nguyen, Regulatory Analyst - Asia Pacific, provided an insightful overview of this comprehensive regulation, outlining its impact on industry and offering guidance on how to best conform.
There were several questions at the end of the webinar that were unable to be answered due to time constraints. Following Mr. Nguyen shares his expertise and answers attendees unresolved questions.
Attendee Question: How does NZL regulator see the downstream process? For example, in the case of Acute Toxicity Cat 5, the manufacturer may sell substances for industrial use to their customers excluding cat 5 classification. Finally at the end of the supply chain, a manufacturer of mixtures has to classify acute tox cat 5. How will the communication gap be closed?
NN: The consultation papers on the current EPA notices on classification, labeling, SDS and packaging have not addressed this concern. However, New Zealand laws and regulations require manufacturers and suppliers to classify and label mixtures. In other words, the burden of compliance would be on the manufacturers. It is important that the mixture manufacturers have clear communication with their suppliers and develop procedures to address communication gaps within their supply chain.
Attendee Question: Do consumer products have to be accompanied by a Safety Data Sheet (SDS)?
NN: Generally, all hazardous products must be accompanied by a SDS. Guidance on how to determine whether a substance is hazardous can be found in the Hazardous Substances (Identification) Regulations 2001 and the Hazardous Substances (Minimum Degrees of Hazard) Regulations 2001. The group standards also prescribe SDS requirements for different products.
Attendee Question: What is the difference between the 4th and 5th Edition of GHS?
NN: The short answer is that there is not that much of a difference (e.g. no changes to or addition of new categories etc.). However, some of the information has been reorganized. If you need assistance on determining how the new 5th edition will impact your products, please contact the 3E team.
Attendee Question: Is there a different deadline for substances and mixtures?
NN: The deadline as proposed is the same for both substances and mixtures.
Attendee Question: Can a hazardous substance be listed as a proprietary ingredient?
NN: The substance name must be listed. A generic chemical name may be used in some cases.
Attendee Question: Why is New Zealand trying to align itself with Australia and other jurisdictions?
NN: The New Zealand Environmental Protection Authority (EPA) is interested in promulgating and enforcing rules and regulations that inform and protect the public while limiting unnecessary impediments to trade. New Zealand’s proximity, trading relationships and shared history with Australia may factor into why New Zealand wants to align some of its regulations with Australia. It is important to note that New Zealand is also seeking to align itself with the international community as well. In proposing the changes, the EPA has taken into consideration what has been adopted in the European Union, the United States, as well as China and Japan.
Have another question for Nhat? Please feel free to email us at firstname.lastname@example.org.