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The Globally Harmonized System for the Classification and Labelling of Chemicals (The GHS) - Implementation of the GHS in Canada

Workshop, October 15, 2003

Breakout Session - Transportation of Dangerous Goods

The following is a verbatim transcript of the flip charts produced during the workshop.

Issue Identification

Using a brainstorming process, participants were asked to suggest issues they're related to the implementation of GHS in Canada.

  • Harmonization with the U.S. and impact on Canadian exports/imports;
  • Clear identification of differences;
  • Don't lose focus on transportation issues;
  • Impact of the new classification scheme;
  • Timing of implementation of the changes;
  • Harmonizing with the U.S.;
  • Transition in attacks on packaging that might be pre-labeled, pre-marked;
  • Marking and labelling of package is in regards to mode of transportation;
  • Sizing of labels;
  • Harmonize station with U.S. and other countries like Europe;
  • Labelling and placarding are they the same?
  • Classification of multiple hazard products: how are you going to classify them?
  • Merging of different classification criteria;
  • Integration of all components;
  • Pre-classification of Schedule I materials;
  • Cost/benefit to industry, impact on competitiveness;
  • Entered TDG, will there be an implementation period?
  • Integration as well as harmonization between the sectors;
  • Harmonization between sectors in labelling portion;
  • Current exemptions, will they be maintained?
  • The issue of adding chronic exposure;
  • Implications of other countries nonparticipating;
  • Interpretation of requirements;
  • Will there be a GHS requirement added to the TDG training program?
  • Degree of involvement by provincial government in the GHS program;
  • TDG classification of non TDG products;
  • Scope of training TDG vs G H S;
  • Classification resources for small business;
  • Will MSDSs be required on Transport shipments? If yes, will 24 (sic) number go out?
  • Will for the identification process be changed on documentation?
  • Will the government subsidize us for reclassification?
  • Capacity/resources to complete work;
  • Consolidate with other up-dates to TDG regulations;
  • Inconsistencies between TDG classification verses non-GHS;
  • Reciprocity;
  • Will TDG Regulations be updated when GHS comes in;

Themes

Participants were asked to suggest themes that could include many of the different issues addressed in the above noted brainstorming session.

  1. Classification;
  2. Implementation/Transition;
  3. Reciprocity/harmonization;
  4. Safety marks;
  5. Training/capability/resources
  6. Cost management;
  7. Documentation/C

Regrouped Issues

The group then regrouped the information from the brainstorming into one of the seven themes they had identified.

Classification

  • Impact
  • Identification of differences;
  • Multiple hazard;
  • Merging of different classification criteria;
  • Prescribed classifications;
  • Chronic exposure;
  • " new " TDG products;
  • Non-GHS;

Implementation/Transition

  • Don't lose focus on transportation;
  • Timing of implementation;
  • In attacks on packaging that might be pre-labeled/pre-marked;
  • Implementation period;
  • Current exemptions, will they be maintained?
  • Clear interpretation of requirements;
  • Capacity/resources to develop implementation;
  • Consolidate with other up-dates;

Reciprocity/Harmonization

  • Harmonization with U.S. imports/exports;
  • Multi-modal harmonization;
  • International harmonization;
  • Harmonization between sectors;
  • Nonparticipating countries;
  • Involvement provincial/territorial;
  • Integration of all components

Safety Marks

  • A marking and labelling of packagings;
  • Sizing of labels/placards;
  • GHS label/non TDG;
  • Harmonization of labelling in sectors

Training/Capability/Resources

  • GHS component of TDG training;
  • Overlaps/authority TDG verses GHS;
  • Classification resources

Cost Management

  • Cost/benefit to industry;
  • Impact on competitiveness;
  • Government subsidy for reclassification;
  • Timing of implementation;

Documentation/Communications

  • Will MSDS be required?
  • Will it Transport description be changed;
  • Clear interpretation of requirements;
  • GHS FAQs on TDG web site;

Options and Solutions

Based on the discussion of the above themes, the group then identified possible options and solutions. These options and solutions were grouped by the seven themes previously identified.

Classification

  • I wish for common classification criteria across the sectors;
  • Retained current TDG exemptions;
  • Identify GHS classification for all prescribed DGs;
  • Wish that "chronic issues " excluded;
  • Classification support from Transport Canada;
  • Three years lead in time

Implementation/Transition

  • 18 to 24 month phased compliance overlap of regulations;
  • Grandfathering of existing inventory (containment);
  • Program coordinator across all agencies;
  • Interpretation link on Transport Canada website;
  • I wish that they would use clear language;
  • More public meetings across Canada in English and French;
  • Uniform interpretation of the rules

Reciprocity/Harmonization

  • Wish that all countries implement the same way as Canada and at the same time;
  • Standardize the language that is used;
  • I wish that there is harmonization between sectors;
  • Program coordination between sectors;
  • Other countries status re GHS;
  • Federal/provincial/territorial harmonize wrt (sic) content and timing;
  • Multi-modal harmonization;
  • Get it right the first time

Safety Marks

  • Minimize the change;
  • Establish a format/guidelines

Training/Capability/Resources

  • Minimal impact on TDG training requirements;
  • Phase in a GHS training;
  • No redesign/reissue of certificates

Cost Management

  • Minimize " pocketbook " impact;
  • Transparency on cost/benefit analysis that government completes

Documentation/Communications

  • Complete, timely, thorough Communications to all parties;
  • No "MSDSs" required for shipments;
  • Wish that Canutec (sic) had " a generic MSDSs on file;
  • Issue an official GHS newsletter similar to the TDG newsletter;
  • Establish a GHS Canada website;
  • Ordinate and integrate documentation requirements between the four sectors and other bodies.
Date Modified: 2007-11-09 Top