Insights on Environmental Health & Safety (EHS), Operational Risk and Product Stewardship

A Walk Down Memory Lane with the Purple Book

February 18th, 2019
Carrie Decatur
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Benjamin Franklin once said, “In this world nothing can be said to be certain, except death and taxes.” I think that I would amend that to include regulatory changes. Ours is a world of change and while the rate of changes sometimes slows, it never really stops. I was reminded of this the other day when I was reviewing my list of country implementations and expected updates. Countries are remembering that while the UN continues to march ahead, they are being left behind.

In particular, the EU is looking at revising both the CLP and REACH Annex II, bringing in the updates made to revisions 6 and 7. OSHA has also announced that they are looking at updating Hazcom to meet the requirements of the latest edition (RIN: 1218-AC93). In keeping with North America, the Canadians announced plans to update to UN GHS revision 7. Travelling across the ocean we find ourselves in Japan and an update to the JIS standards to align it with UN GHS revision 6. To top it all off, we are expecting the UN to update the purple book this summer. We could go on, but the evidence is in….2019 is a year of change, or at least announced changes!  

To prepare for all this, I’ve been dusting off my notes and previous versions of the purple book to remind myself of where we are and what we need to do. Remember that some of these countries are still on revision 3, there are quite a few changes to remember between that and revision 7.

Let’s run through the revisions and see where you can expect to see changes in the country regulations.

UN GHS Revision 4:

UN GHS Revision 5:

UN GHS Revision 6

UN GHS Revision 7

All these updates contain changes to the H & P Phrases. Remember that while you need to know the changes within the purple book, you should also check the country implementations once they are published. We know that some regulations, such as OSHA Hazcom, have made changes to some of the phrases and it is important to recognize these differences on your SDS.

While waiting for the various countries to update their legislation, look at the changes and your product lines. It will be helpful to understand how these changes might impact you ahead of the country publications so that you can manage the changes that are coming. While 2019 is a year of change, we can be prepared for it and still hope that maybe there will be a bit more harmonization in our future!

Carrie Decatur

Carrie Decatur is an internationally recognized expert in GHS at the UN and individual country level. She has been with Sphera Solutions for over 10 years. In her role as Senior Regulatory Analyst she is responsible for the analysis and implementation of global chemical regulations into the Sphera Product Stewardship offerings and the web based IA (Intelligent Authoring) training program. She is the Chair the Global Regulatory Focus Group which is a monthly client-based forum where regulatory updates and issues and new system implementations are discussed. Carrie has worked in the Services group as a consultant where she utilized her experience in authoring SDSs and industry to assist clients in implementing IA in an efficient and cost-effective manner. She has also worked in the chemical manufacturing arena where she was responsible for HSE and quality programs. Carrie often speaks at international conferences and at industry trade association meetings.

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