DRAFT
7/
7/
04
The
Globally
Harmonized
System
of
Classification
and
Labelling
of
Chemicals
(
GHS):

Implementation
Planning
Issues
for
the
Office
of
Pesticide
Programs
PURPOSE/
EXECUTIVE
SUMMARY
The
purpose
of
this
paper
is
to
describe
the
current
thinking
of
the
Office
of
Pesticide
Programs
(
OPP)
with
respect
to
the
application
of
the
Globally
Harmonized
System
of
Classification
and
Labeling
of
Chemicals
(
GHS)
to
pesticide
labels,
to
outline
possible
implementation
mechanisms
that
are
under
consideration,
and
to
solicit
initial
public
input
on
the
options
presented.

The
GHS
establishes
classification
criteria
for
physical,
health
and
environmental
hazards,
along
with
associated
hazard
communication
elements,
notably
pictograms,
signal
words,
and
hazard
statements
for
use
on
labels.
It
is
based
on
harmonizing
major
existing
systems
for
classifying
and
labeling
of
chemicals
in
transport
and
in
the
workplace,
in
pesticides,
and
in
consumer
products.
A
key
guiding
principle
of
the
GHS
harmonization
effort
was
that
harmonization
should
be
accomplished
without
lowering
the
level
of
protection
afforded
by
existing
systems.
It
was
also
acknowledged
that
changes
in
all
systems
would
be
required
to
achieve
a
single,
globally
harmonized
system.

To
implement
the
GHS
for
pesticides,
OPP
would
need
to
modify
certain
of
its
classification
and
labeling
requirements
to
be
consistent
with
the
GHS,
and
to
take
steps
to
ensure
that
pesticide
labels
are
revised
accordingly.
OPP
is
particularly
interested
in
comments
on
policies
and
mechanisms
that
will
achieve
implementation
within
a
reasonable
time
frame
in
an
equitable
and
efficient
manner,
minimizing
the
burden
on
agency
and
stakeholder
resources.
The
paper
presents
two
basic
options
for
implementation:
establishing
a
separate
approval
process
or
integrating
GHS
label
changes
into
ongoing
registration
and
re­
registration
actions.
We
are
also
seeking
comments
on
the
possible
benefits
of
instituting
a
pilot
project
before
final
changes
implementing
the
GHS
are
in
place,
how
such
a
pilot
might
be
structured,
and
what
educational
and
outreach
activities
would
be
most
effective.

In
light
of
the
comments
received
and
other
relevant
information
and
analysis,
OPP
will
evaluate
next
steps.
We
also
plan
to
continue
to
consult
within
the
North
American
Free
Trade
Agreement
Technical
Working
Group
on
Pesticides
(
NAFTA
TWG)
in
an
effort
to
coordinate
implementation
activities
in
all
three
NAFTA
countries:
Canada,
the
United
States,
and
Mexico.

The
paper
is
organized
into
four
major
sections:
(
1)
background
on
the
GHS,
its
contents
and
how
it
was
developed;
(
2)
comparison
of
the
GHS
with
current
OPP
classification
and
labeling
policies;
(
3)
initial
implementation
considerations;
and
(
4)
outreach
activities
and
plans.
DRAFT
7/
7/
04
2
I.
BACKGROUND
For
over
a
decade,
the
U.
S.
and
other
countries
and
stakeholders
worked
to
develop
the
Globally
Harmonized
System
of
Classification
and
Labelling
of
Chemicals
(
GHS),
a
major
activity
mandated
by
the
1992
UN
Conference
on
Environment
and
Development
and
endorsed
by
the
2002
World
Summit
on
Sustainable
Development
(
WSSD)
and
the
Intergovernmental
Forum
on
Chemical
Safety
(
IFCS).
The
GHS
is
designed
to
provide
a
common
and
coherent
approach
to
defining
and
classifying
hazards
and
communicating
hazard
information
on
labels
and
safety
data
sheets.
The
anticipated
benefits
of
harmonization
include:

 
Enhanced
protection
of
human
health
and
the
environment:
GHS
will
help
ensure
more
consistency
in
the
classification
and
labeling
of
all
chemicals,
thereby
enhancing
safer
transportation,
handling
and
use
of
chemicals
in
transport,
in
the
workplace,
and
in
consumer
use
settings.

 
Sound
management
of
chemicals
worldwide:
GHS
will
provide
a
harmonized
basis
for
the
first
step
in
sound
management
of
chemicals,
identifying/
classifying
hazards
and
communicating
them.
This
will
be
particularly
useful
for
countries
without
welldeveloped
regulatory
systems.

 
Trade
Facilitation:
GHS
will
reduce
costly
and
time­
consuming
activities
needed
to
comply
with
multiple
classification
and
labeling
systems,
promoting
more
consistency
in
regulation
and
reducing
non­
tariff
barriers
to
trade.

The
GHS
is
now
complete
and
was
formally
adopted
by
the
United
Nations
Economic
and
Social
Council
(
UN
ECOSOC)
in
July
2003.
For
a
fuller
discussion
of
the
history
and
organization
of
the
GHS
negotiations,
see
the
Federal
Register,
Volume
62,
Number
64
(
April
3,
1997)
pp.
15951­
15957.

Scope
of
the
GHS
The
GHS
is
based
on
harmonization
of
major
existing
systems
for
chemicals
in
transport
and
in
the
workplace,
pesticides,
and
consumer
products,
without
lowering
the
level
of
protection
afforded
by
those
existing
systems.
Its
scope
includes
all
chemicals;
however,
it
does
not
cover
pharmaceuticals,
food
additives
or
pesticide
residues
in
food,
or
cosmetics
in
the
A
consumer
use
setting.@
(
These
types
of
chemicals
are
covered
in
transport
and
in
the
workplace,
consistent
with
the
current
U.
S.
regulatory
framework.)
"
Articles,"
as
defined
by
the
Occupational
Safety
and
Health
Administration's
hazard
communication
standard
or
by
similar
definitions
are
also
outside
the
scope
of
the
system
(
GHS
1.3.2.1.2)

Elements
of
the
GHS
DRAFT
7/
7/
04
3
The
GHS
includes
classification
criteria
and
standardized
hazard
communication
elements
for
physical
hazards
(
flammability,
explosivity,
etc.),
health
hazards,
and
one
environmental
hazard
(
aquatic
toxicity).
The
health
hazards
covered
by
the
system
are
acute
toxicity,
skin
corrosion/
irritation,
serious
eye
damage/
eye
irritation,
sensitization,
germ
cell
mutagenicity,
carcinogenicity,
reproductive
toxicity,
and
target
organ/
systemic
toxicity
(
TOST).
(
Essentially,
TOST
includes
effects
not
covered
by
other
classes,
whether
caused
by
a
single
exposure
or
repeated
exposures.
Examples
include
neurotoxicity,
immunotoxicity,
liver
damage,
etc.)

The
standardized
label
elements
include
symbols/
pictograms,
use
of
two
signal
words
(
danger
and
warning),
and
hazard
statements
for
each
hazard
class
and
category.
To
be
consistent
with
the
GHS,
labels
should
also
include
product
and
supplier
identifiers
and
precautionary
statements,
although
these
have
not
been
standardized.
In
addition,
it
is
consistent
with
the
GHS
to
include
supplemental
information
on
the
label,
to
give
more
detail
or
cover
additional
hazards,
provided
the
supplemental
information
does
not
undermine
the
GHS
label
information.
The
system
further
specifies
format
and
contents
for
hazard
communication
in
Safety
Data
Sheets,
used
primarily
in
the
workplace.

The
comprehensive
GHS
document
also
contains
guidance
on
how
some
related
issues
should
be
addressed
for
a
system
to
be
judged
consistent
with
the
harmonized
system,
e.
g.,
with
respect
to
ingredient
disclosure
and
protection
of
Confidential
Business
Information
(
CBI),
precedence
of
hazard,
and
use
of
only
one
signal
word
per
label.

Basis
of
Classification
and
Labeling
GHS
classification
criteria
are
based
on
intrinsic
hazard,
not
risk.
Classification
is
essentially
equivalent
to
the
hazard
identification
step
in
risk
assessment
paradigms.
Consistent
with
EPA/
OPP
policy,
a
weight
of
evidence
approach
is
used
in
making
classification
determinations
based
on
the
best
available
data.
The
GHS
is
not
intended
to
harmonize
risk
assessment
or
risk
management
measures.

The
GHS
is
testing­,
and
test
method­,
neutral
for
health
and
environmental
hazards.
Implementation
does
not
require
use
of
any
particular
test
protocols
or
imposition
of
any
new
data
requirements.
Classification
is
based
on
available
data,
but
the
GHS
acknowledges
that
agencies
with
authority
to
require
data
will
continue
to
do
so.
(
For
example,
pesticide
authorities,
including
OPP,
would
be
expected
to
continue
to
require
acute
toxicity
studies
for
pesticide
formulations
and
this
would
be
consistent
with
the
GHS.)
The
GHS
does
specify
test
methods
in
criteria
for
physical
hazards.

The
complete
current
text
of
the
GHS
is
posted
on
the
Internet
at
http://
www.
unece.
org/
trans/
danger/
publi/
ghs/
officialtext.
html.

The
GHS
Development
Process
and
Stakeholder
Involvement
DRAFT
7/
7/
04
4
The
GHS
was
developed
and
approved
based
on
a
tripartite
consensus
of
participating
government
representatives,
industry
representatives,
and
representatives
of
other
nongovernmental
organizations,
principally
labor
unions
and
professional
organizations
of
emergency
responders.
Overall
management
of
the
GHS
development
process
was
the
responsibility
of
the
Coordinating
Group
for
the
Harmonization
of
Chemical
Classification
Systems
(
CG/
HCCS),
under
the
auspices
of
the
Inter­
organization
Program
for
the
Sound
Management
of
Chemicals,
which
reported
to
the
Intergovernmental
Forum
on
Chemical
Safety
(
IFCS).

Under
the
direction
of
the
CG/
HCCS,
the
work
of
developing
the
elements
of
the
GHS
was
assigned
to
three
focal
points,
which
also
operated
on
a
tripartite,
consensus
basis.
A
task
force
of
the
Organization
for
Economic
Cooperation
and
Development
(
OECD)
developed
classification
criteria
for
health
and
environmental
hazards.
A
joint
working
group
of
the
UN
Committee
of
Experts
on
the
Transport
of
Dangerous
Goods
(
UNCETDG)
and
the
International
Labour
Organisation
(
ILO)
developed
the
classification
criteria
for
physical
hazards.
The
hazard
communication
elements
of
the
system
were
developed
by
an
ILO
Working
Group
on
Hazard
Communication.
The
Coordinating
Group
set
overall
policy
directions
for
development
of
the
system,
resolved
issues
referred
to
it
by
the
focal
points,
and
assembled
the
final
GHS
package
in
a
single
document.

U.
S.
government
agencies
and
stakeholders
participated
actively
in
the
work
of
the
focal
points
and
the
CG/
HCCS,
and
joined
in
the
consensus
on
the
final
GHS.
Overall
U.
S.
government
positions
were
coordinated
by
an
interagency
group
consisting
of
representatives
of
key
regulatory
and
trade
agencies
and
led
by
the
State
Department.
The
interagency
group
encouraged
public
participation
through
public
meetings
before
major
international
meetings,
Federal
Register
notices,
and
maintenance
of
an
electronic
mailing
list
of
interested
stakeholders.
Key
regulatory
agencies
took
the
lead
for
the
technical
work
of
GHS
development.
The
Department
of
Transportation
was
the
lead
agency
for
the
work
on
physical
hazards.
The
Environmental
Protection
Agency
Office
of
Pollution
Prevention,
Pesticides
and
Toxic
Substances
was
the
lead
for
health
and
environmental
hazard
classification
criteria.
The
Department
of
Labor
Occupational
Safety
and
Health
Administration
was
the
lead
for
GHS
hazard
communication
activities
and
chaired
the
CG/
HCCS.

The
permanent
home
of
the
GHS
is
the
UN
Sub­
Committee
of
Experts
on
the
Globally
Harmonized
System
of
Classification
and
Labelling
of
Chemicals
(
UN
SCEGHS),
which
reports
to
the
UN
ECOSOC
through
the
joint
Committee
of
Experts
on
the
Transport
of
Dangerous
Goods
and
the
Globally
Harmonized
System
of
Classification
and
Labelling
of
Chemicals.
The
U.
S.
is
a
member
of
the
Sub­
Committee
and
the
full
Committee.
U.
S.
stakeholder
organizations
participate
through
observer
organizations.
The
UN
SCEGHS
has
continued
the
roles
of
OECD
and
the
Sub­
Committee
of
Experts
on
the
Transport
of
Dangerous
Goods
as
focal
points
for
future
technical
work
on
health
and
environmental
hazards
and
physical
hazards,
respectively.
The
UN
Institute
for
Training
and
Research
(
UNITAR)
is
the
focal
point
for
international
capacity­
building
activities.
The
U.
S.
government
and
some
stakeholder
organizations
are
also
DRAFT
7/
7/
04
5
members
of
the
GHS
Partnership
created
under
the
auspices
of
the
WSSD
to
promote
GHS
implementation
worldwide.

General
Implementation
Expectations
at
the
International
Level
The
GHS
is
a
voluntary
international
system,
in
that
it
does
not
impose
binding
treaty
obligations
on
countries.
The
intent
is
that
countries
with
existing
systems
will
harmonize
them
with
the
GHS,
and
countries
that
do
not
have
systems
will
adopt
the
GHS
as
their
basic
system.
To
the
extent
that
regulatory
agencies
change
their
requirements
to
be
consistent
with
the
GHS,
however,
those
changes
will
be
binding
on
regulated
industry
in
the
same
way
as
current
regulatory
regimes
are
binding.

It
is
important
to
note
that
one
of
the
fundamental
premises
of
the
GHS
is
a
A
building
block@
approach.
Countries
are
not
obligated
to
cover
all
GHS
classes
and
categories
in
order
to
be
considered
consistent
with
the
GHS,
just
as
current
regulatory
systems
do
not
cover
all
GHS
hazards
(
e.
g.,
the
Department
of
Transportation
does
not
cover
chronic
effects,
OPP
does
not
generally
label
chronic
effects
based
on
hazard),
but
for
those
effects
that
are
covered,
it
is
expected
that
countries
will
consistently
apply
GHS
criteria
for
classification
and
require
GHS
hazard
communication
elements.
Countries
that
choose
the
risk­
based
labeling
approach
for
consumer
products
(
the
approach
currently
used
by
the
U.
S.
Consumer
Product
Safety
Commission)
would
also
be
expected
to
use
the
GHS
classification
criteria
and
label
elements.
Some
hazards
may
not
be
on
the
label,
based
on
a
risk
assessment
combining
exposure
with
the
GHS
classification
criteria,
but
those
effects
that
are
on
the
label
should
be
identified
in
accordance
with
the
GHS.

There
is
no
detailed,
internationally
agreed­
upon
GHS
implementation
schedule.
The
WSSD
confirmed
the
IFCS
goal
of
adoption
by
countries
in
each
region
by
2008,
and
the
Chemicals
Dialogue
of
the
Asia­
Pacific
Economic
Cooperation
Forum
(
APEC),
of
which
the
U.
S.
is
a
member,
set
a
goal
of
implementation
by
2006
to
the
extent
possible.
Different
systems
are
likely
to
require
different
implementation
schedules.
Not
all
regulatory
systems
require
preapproval
of
labels,
as
OPP
does.
It
has
also
been
noted
that
some
transitional
provisions
(
e.
g.,
accepting
both
new
and
old
labels
in
the
marketplace
at
the
same
time)
will
be
important
to
avoid
trade
disruptions.

GHS
implementation
for
pesticides
is
included
in
the
NAFTA
TWG
Five
Year
Strategy
(
available
on
the
Internet
at
http://
www.
epa.
gov/
oppfead1/
international/
naftatwg/
twgstrategy.
pdf).
The
NAFTA
TWG
Executive
Board
approved
a
project
to
promote
coordinated
approaches
to
implementation
at
its
meeting
in
Vancouver,
Canada,
in
December
2003.

II.
SUMMARY
COMPARISON
OF
GHS
WITH
CURRENT
OPP
CLASSIFICATION
AND
LABELING
POLICIES
DRAFT
7/
7/
04
6
This
section
provides
a
narrative
summary
comparison
of
the
GHS
with
current
OPP
policies,
drawing
on
EPA's
label
regulations
in
Title
40
of
Code
of
Federal
Regulations
Part
156
(
40
CFR
156)
and
the
OPP
Label
Review
Manual
(
http://
www.
epa.
gov/
oppfead1/
labeling/
lrm/).
A
separate
document
is
available
that
includes
a
side­
by­
side
comparison
of
the
GHS
and
corresponding
OPP
policies.
Neither
this
paper
nor
the
side­
by­
side
comparison
attempts
to
include
all
exceptions
or
special
circumstances
that
might
lead
to
divergent
classifications,
which
could
lead
to
different
label
requirements
and
would
still
be
considered
consistent
with
the
GHS.

General
Comparison
of
OPP
Policies
and
the
GHS
(
these
points
apply
across
hazard
classes)

1.
GHS
organizes
the
hazard
characteristics
of
chemicals
based
on
"
hazard
classes"
(
specific
physical,
health
or
environmental
effects,
such
as
flammability,
skin
corrosion/
irritation,
aquatic
toxicity)
which
are
subdivided
into
numerical
"
hazard
categories"
based
on
the
severity
of
the
hazard.
The
use
of
the
term
"
category"
is
thus
essentially
the
same
as
current
OPP
practice.
The
GHS
uses
Arabic
numerals
consistently,
while
OPP
uses
Roman
numerals.

2.
OPP
uses
the
skull
and
crossbones
symbol
for
severe
acute
toxicity
and
products
containing
methanol
at
concentrations
above
4%,
and
a
flame
symbol
for
highly
flammable
total
release
foggers
(
40
CFR
156.78(
d)(
3)).
The
GHS
uses
symbols
for
all
hazard
classes
(
but
not
all
categories).

3.
GHS
pictograms
are
composed
of
the
appropriate
symbol
surrounded
by
a
red
diamond­
shaped
border,
except
that
authorities
may
allow
a
black
diamond
border
if
the
chemical
is
for
domestic
use
only.
OPP
does
not
prescribe
borders
around
symbols.

4.
OPP
uses
three
signal
words
(
danger,
warning,
and
caution);
the
GHS
only
two
(
danger
and
warning).
OPP
prohibits
the
use
of
signal
words
for
environmental
or
physical
hazards;
the
GHS
mandates
their
use
for
some
categories
(
e.
g.,
extremely
flammable
liquids).

5.
GHS
"
hazard
statements"
are
simple
statements
of
hazard,
a
subset
of
what
OPP
calls
"
precautionary
statements."
GHS
does
not
specify
any
precautionary
statements
(
e.
g.,
first
aid,
personal
protective
equipment)
beyond
hazard
statements.
An
annex
to
the
GHS
document
gives
examples
of
precautionary
statements
currently
in
use
in
a
number
of
systems,
including
OPP's.
The
UN
SCEGHS
is
working
to
develop
proposals
for
greater
harmonization
of
precautionary
statements.

6.
The
GHS
calls
for
all
chemical
labels
to
include
a
product
identifier
(
a
name
or
number
that
provides
a
unique
means
by
which
users
can
identify
a
chemical
DRAFT
7/
7/
04
7
substance
or
mixture)
and
a
supplier
identifier,
but
does
not
provide
detailed
specifications.
It
also
calls
for
disclosure
on
the
label
of
ingredients
that
contribute
to
hazard
classification,
but
provides
that
national
rules
governing
disclosure
of
Confidential
Business
Information
(
CBI)
will
take
precedence
over
ingredient
disclosure
provisions.

7.
No
change
in
OPP
test
requirements
for
health
and
environmental
effects
is
necessary
to
achieve
consistency
with
the
GHS.
The
GHS
is
testing­,
and
testmethod
neutral
for
health
and
environmental
hazards
and
is
designed
to
permit
self­
classification
to
the
maximum
extent
possible,
while
recognizing
that
some
systems,
such
as
those
governing
pesticides,
do
require
testing,
independent
of
the
GHS.

8.
The
GHS
includes
conservative
"
bridging
principles"
for
classifying
untested
chemical
mixtures
based
on
the
availability
of
data
on
very
similar
mixtures,
or
on
the
ingredients
of
the
mixture,
that
permit
adequate
characterization
of
the
hazards
of
the
mixture
(
for
example,
for
acute
toxicity,
see
GHS
Section
3.1.3.5).
OPP
generally
requires
certain
data
based
upon
the
end­
use
product,
while
other
data
can
be
"
bridged"
in
certain
circumstances
when
scientifically
appropriate.

9.
The
GHS
specifies
test
methods
for
physical
hazards.
To
be
consistent
with
the
GHS,
OPP
would
need
to
ensure
that
its
guidelines
are
consistent
with
these
methods
and
that
its
regulations
specify
GHS
classification
criteria
and
label
elements
where
appropriate.

10.
Except
as
detailed
in
the
specific
hazard
class
comparisons
that
follow,
other
OPP
label
information
requirements
appear
consistent
with
the
GHS'
allowance
for
"
supplemental
information,"
beyond
the
specified
GHS
label
elements,
so
long
as
the
supplemental
information
does
not
undermine
the
GHS
label
information.
On
pesticide
labels,
supplemental
information
would
include,
among
other
things,
additional
precautionary
statements,
requirements
for
personal
protective
equipment,
re­
entry
intervals,
and
first
aid
statements.

Acute
Toxicity
1.
The
GHS
has
five
categories
for
acute
toxicity.
OPP
currently
uses
four
categories.
GHS
Categories
1­
2
correspond
to
OPP
Category
I.
GHS
Category
3
includes
chemicals
with
toxicities
up
to
300
mg/
kg
by
the
oral
route,
while
OPP
Category
II
extends
up
to
500
mg/
kg.
GHS
Category
4
covers
oral
LD
50
values
>
300
mg/
kg
<
2000
mg/
kg,
compared
to
OPP
Category
III's
range
of
>
500
mg/
kg
<
5000
mg/
kg.
GHS
Category
5
covers
chemicals
with
toxicities
expected
to
fall
in
the
range
of
oral
and
dermal
LD
50
of
2000
mg/
kg
­
5000
mg/
kg,
or
equivalent
doses
for
inhalation
toxicity.
OPP
Category
IV
has
no
upper
limit.
DRAFT
7/
7/
04
8
2.
The
basis
of
classification
in
both
systems
is
the
same:
LD
50
values
or
"
acute
toxicity
estimates"
of
the
LD
50
.

3.
OPP
uses
the
"
danger"
signal
word
and
skull
and
crossbones
symbol
for
chemicals
in
Categories
I
and
II
(
e.
g.,
oral
LD
50
of
up
to
50
mg/
kg).
GHS
uses
the
"
danger"
signal
word
and
skull
and
crossbones
symbol
for
chemicals
in
Categories
1­
3
(
e.
g.,
oral
LD
50
of
up
to
300
mg/
kg)
and
the
exclamation
point
symbol
for
Category
4
(
e.
g.,
oral
LD
50
>
300
<
2000
mg/
kg).
[
NOTE:
if
the
skull
and
crossbones
symbol
applies
under
the
GHS
based
on
any
route
of
exposure,
the
exclamation
point
should
not
also
appear
on
the
label.]

4.
The
GHS
specifies
different
classification
criteria
for
inhalation
toxicity
based
on
whether
the
chemical
is
(
1)
a
gas,
(
2)
a
vapor,
or
(
3)
a
dust
or
mist.
OPP
does
not
distinguish
among
different
types
of
inhalation
toxicants.
[
The
GHS
document
notes
that
additional
work
remains
to
be
done,
notably
in
defining
dusts,
mists
and
vapors;
and
in
addressing
technical
limitations
in
generating
and
maintaining
dusts
and
mists
in
respirable
form.]

Skin
Corrosion/
Irritation
1.
Both
OPP
and
GHS
have
a
single
category
for
skin
corrosion.
The
GHS
subdivides
this
category
based
on
duration
of
exposure,
but
the
label
elements
are
the
same.

2.
GHS
includes
eye
damage
in
the
hazard
statement
for
chemicals
that
are
corrosive
to
the
skin.
OPP
does
not,
although
in
practice
the
statements
are
often
combined
for
these
effects
based
on
data
or
other
information
(
e.
g.,
pH
values).

3.
OPP
defines
skin
irritation
qualitatively
(
severe,
moderate,
and
mild/
slight/
no
irritation)
based
on
72
hour
exposures.
The
GHS
classification
criteria
specify
scores
and
exposure
times
from
commonly­
used
test
protocols.
These
are
consistent
with
OPP
policy.

4.
OPP
has
three
irritant
categories:
severe,
moderate,
or
mild/
slight/
no
irritation.
GHS
has
two
irritant
categories:
irritant
and
mild
irritant.

5.
OPP
requires
no
symbols
for
skin
corrosion/
irritation.
GHS
uses
a
corrosion
symbol
for
Category
1
(
corrosives),
an
exclamation
point
for
Category
2
irritants,
and
no
symbol
for
Category
3
(
mild)
irritants.

6.
Both
OPP
and
GHS
use
the
signal
word
"
danger"
for
skin
corrosives.
OPP
requires
the
signal
word
"
warning"
for
severe
irritants
and
"
caution"
for
moderate
DRAFT
7/
7/
04
9
irritants.
GHS
specifies
the
signal
word
"
warning"
for
all
chemicals
that
cause
irritation
and
does
not
classify
or
prescribe
label
elements
for
chemicals
that
do
not
meet
the
criteria
for
irritation.

Serious
Eye
Damage/
Eye
Irritation
1.
Both
OPP
and
the
GHS
have
one
category
for
corrosion/
serious
eye
damage/
irreversible
effects
on
the
eye
and
use
the
signal
word
"
danger"
for
this
category.
The
GHS
also
requires
the
corrosion
symbol.
OPP
requires
no
symbol.

2.
OPP
uses
three
categories
for
eye
irritants.
GHS
uses
one
category
that
is
further
divided
into
two
subcategories,
"
irritant"
and
"
mild
irritant."
Mild
irritant
effects
are
those
that
are
fully
reversible
within
seven
days.

3.
OPP
uses
the
"
warning"
signal
word
and
no
symbol
for
irritants
in
Category
II
and
"
caution"
and
no
symbol
for
Category
III.
GHS
uses
"
warning"
and
the
exclamation
mark
symbol
for
Category
2A
irritants
and
"
warning"
but
no
symbol
for
Category
2B
mild
irritants.

4.
Both
OPP
and
GHS
classification
criteria
are
based
on
severity
and
duration
of
effects.
OPP
classification
criteria
for
severity
are
described
more
qualitatively
in
the
Label
Review
Manual.
The
GHS
specifies
scores
from
commonly
used
tests;
these
are
consistent
with
OPP
practice.

5.
OPP
Category
IV
covers
minimal
effects
that
clear
in
less
than
24
hours.
No
signal
word,
symbol
or
hazard
statement
is
required
for
this
category.
Registrants
may
choose
to
use
the
Category
III
hazard
statement.
The
GHS
does
not
subdivide
irritant
effects
beyond
the
distinction
between
those
that
reverse
within
21
days
and
those
that
reverse
within
seven
days.

Skin/
Dermal
Sensitization
1.
Both
OPP
and
the
GHS
essentially
use
one
category,
though
OPP
does
not
use
the
term
"
category"
for
this
effect.
A
chemical
is
either
classified
as
a
skin
sensitizer
or
it
is
not.

2.
The
GHS
uses
the
signal
word
"
warning"
and
the
exclamation
mark
symbol
for
skin
sensitizers.
OPP
uses
no
symbol
and
no
signal
word.

Environmental
Hazards
1.
GHS
covers
only
one
environmental
hazard:
aquatic
toxicity.
Work
to
develop
terrestrial
toxicity
as
a
GHS
hazard
class
may
proceed
in
the
future.
In
the
DRAFT
7/
7/
04
10
meantime,
OPP
labeling
for
hazards
other
than
aquatic
toxicity
(
e.
g.,
bees,
mammals)
may
be
considered
"
supplemental
information,"
consistent
with
but
not
part
of
the
GHS.

2.
The
GHS
has
three
acute
and
four
chronic
categories
for
aquatic
toxicity.
Categories
1­
3
of
chronic
toxicity
are
based
on
combining
the
criteria
for
Categories
1­
3
acute
toxicity
with
criteria
for
persistence
in
the
aquatic
environment.
Category
4
chronic
toxicity
is
based
on
persistence
alone,
in
the
absence
of
toxicity
data.
OPP
only
covers
acute
aquatic
toxicity.

3.
OPP
requires
no
signal
word
or
symbol
for
aquatic
toxicity.
The
GHS
specifies
the
"
dead
fish
and
tree"
symbol
and
the
signal
word
"
warning"
for
Category
1
acute
toxicity
and
Category
1
chronic
toxicity.
For
Category
2
chronic
toxicity,
the
GHS
specifies
the
symbol
but
no
signal
word.

4.
OPP
requires
the
hazard
statement
"
this
pesticide
is
toxic
to
fish"
based
on
studies
showing
that
the
active
ingredient
has
a
fish
acute
toxicity
LC­
50
of
1
ppm
or
less,
if
the
pesticide
is
intended
for
outdoor
use.
OPP
requires
the
statement
"
this
pesticide
is
extremely
toxic
to
fish"
if
there
are
field
studies
or
incident
data
(
such
as
reports
received
under
Section
6(
a)(
2)
of
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act)
showing
fish
kills.
OPP
also
requires
specific
hazard/
precautionary
statements
for
some
individual
pesticides.
The
GHS
sets
out
toxicity
and
persistence
criteria
for
each
hazard
category,
and
accompanying
hazard
statements.

5.
GHS­
related
testing
protocols
for
aquatic
toxicity
are
still
in
the
process
of
validation
through
the
OECD
focal
point.
The
GHS
also
includes
lengthy
guidance
on
aquatic
toxicity
in
Annex
8
of
the
GHS
document.

Flammability
1.
Both
OPP
and
GHS
specify
test
methods
and
set
criteria
based
on
test
results.

2.
OPP
classification
criteria
are
based
on
flashpoint
(
all
pesticides)
and
flame
extension
tests
(
pressurized
containers).
There
are
three
categories
for
pressurized
containers,
and
four
for
nonpressurized
containers.

3.
GHS
specifies
criteria
and
label
elements
for
two
categories
of
flammable
gases,
two
categories
of
flammable
aerosols,
four
categories
of
flammable
liquids,
and
two
categories
of
flammable
solids.
OPP
does
not
distinguish
based
on
physical
state.
DRAFT
7/
7/
04
11
4.
OPP
uses
no
signal
words
and
no
symbol,
except
that
a
flame
symbol
is
required
for
highly
flammable
total
release
foggers
(
40
CFR
156.78(
d)(
3)).
GHS
uses
the
"
danger"
signal
word
for
Category
1
flammable
solids,
gases
and
aerosols
and
Categories
1
and
2
flammable
liquids;
and
the
signal
word
"
warning"
for
Category
2
flammable
solids,
gases
and
aerosols
and
Categories
3
and
4
flammable
liquids.
The
GHS
uses
the
flame
symbol
for
Category
1
flammable
gases,
Categories
1
and
2
flammable
aerosols,
Categories
1­
3
flammable
liquids,
and
Categories
1
and
2
flammable
solids.

Other
Physical
or
Chemical
Hazards
1.
OPP
does
not
specify
classification
criteria,
symbols,
signal
words
or
label
statements
for
physical
hazards
other
than
flammability
but
notes
that
when
data
demonstrate
such
hazards,
(
for
example,
explosivity),
appropriate
hazard
statements
must
appear
on
the
label.

2.
Part
2
of
the
GHS
document
specifies
classification
criteria
and
label
elements
for
explosives,
oxidizers,
compressed
gases,
self­
reactive
and
self­
heating
substances,
pyrophoric
liquids
and
solids,
substances
which
emit
flammable
gases
in
contact
with
water,
organic
peroxides,
and
metal
corrosives.

3.
To
be
consistent
with
the
GHS,
OPP
would
need
to
adopt
the
GHS
criteria
and
label
elements,
as
well
as
the
associated
test
methods,
for
each
physical/
chemical
hazard
class
and/
or
category
it
decides
to
cover.

III.
INITIAL
IMPLEMENTATION
CONSIDERATIONS
In
the
summer
of
2003,
soon
after
formal
international
adoption
of
the
GHS
by
UN
ECOSOC,
an
internal
EPA/
OPPTS
working
group
was
formed
and
began
meeting
to
analyze
and
compare
the
GHS
to
current
policies
and
to
develop
initial
implementation
recommendations.
The
working
group
includes
representatives
of
all
OPP
divisions,
other
key
EPA
offices,
and
state
regulators
and
educators.
This
section
of
the
paper
outlines
the
group's
initial
recommendations
and
reflects
current
OPP
thinking.
We
have
shared
these
recommendations
and
a
draft
of
this
paper
with
our
NAFTA
counterparts
and
plan
to
continue
to
consult
with
them
throughout
the
implementation
planning
process.
These
consultations,
as
well
as
discussions
at
the
broader
international
level,
may
lead
to
additional
refinements
or
modifications
in
the
approaches
under
consideration,
with
the
goal
of
further
advancing
the
objectives
of
international
harmonization.

How
the
GHS
will
affect
U.
S.
pesticide
labeling
General:
DRAFT
7/
7/
04
12
OPP's
general
approach
to
initial
GHS
implementation
is
to
limit
changes
in
the
current
system
of
pesticide
regulation
under
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
to
those
necessary
to
achieve
consistency
with
the
GHS.
EPA
will
need
to
revise
its
hazard
classification
and
label
requirements,
in
those
areas
that
EPA
currently
has
requirements,
but
does
not
intend
to
expand
the
scope
of
its
requirements
to
include
all
elements
that
are
part
of
the
GHS.
This
is
consistent
with
the
"
building
block
approach"
as
described
in
Sections
1.1.3.1.5.1­
3
of
the
GHS
document:

Consistent
with
the
building
block
approach,
countries
are
free
to
determine
which
of
the
building
blocks
will
be
applied
in
different
parts
of
their
systems
.
.
.
.
The
harmonized
elements
of
the
GHS
may
thus
be
seen
as
a
collection
of
building
blocks
from
which
to
form
a
regulatory
approach.
While
the
full
range
is
available
to
everyone,
and
should
be
used
if
a
country
or
organization
chooses
to
cover
a
certain
effect
when
it
adopts
the
GHS,
the
full
range
does
not
have
to
be
adopted.

OPP
plans
to
implement
the
GHS
for
all
types
of
pesticides,
as
defined
by
FIFRA
(
including
microbial
pesticides),
and
to
adopt
GHS
hazard
classification
criteria
and
label
elements
for
all
hazard
classes
for
which
OPP
currently
requires
hazard
labeling
for
pesticide
products,
i.
e.,
acute
toxicity,
skin
and
eye
irritation/
corrosion,
skin
sensitization,
acute
aquatic
toxicity,
flammability
and
other
physical
hazards.
Pesticides
which
do
not
meet
the
classification
criteria
for
any
of
the
hazard
categories
specified
in
the
GHS
would
be
unclassified
for
that
hazard
and
would
not
bear
any
of
the
GHS
hazard
label
elements.

GHS­
prescribed
label
elements
(
pictograms,
signal
words
and
hazard
statements)
should
appear
together
on
the
label.
The
pictograms
would
include
a
red
border,
as
specified
by
the
GHS.
Although
the
GHS
provides
discretion
for
regulatory
authorities
to
permit
products
not
intended
to
be
traded
internationally
to
use
a
black
border,
OPP
believes
that
using
a
red
border
in
all
cases
would
benefit
U.
S.
pesticide
users
by
drawing
greater
attention
to
the
label
information.
It
would
also
simplify
implementation,
in
that
it
would
not
be
necessary
to
make
this
distinction
when
reviewing
labels
for
compliance.
Only
one
signal
word
would
appear
on
each
label,
consistent
with
current
OPP
policy;
if
the
signal
word
"
danger"
applies,
the
signal
word
"
warning"
should
not
appear.
If
the
skull
and
crossbones
pictogram
applies,
the
exclamation
point
pictogram
should
not
appear
for
any
health
hazards.
If
the
corrosion
pictogram
applies,
the
exclamation
point
pictogram
should
not
appear
for
skin
or
eye
irritation.
(
For
example,
if
a
product
is
classified
as
Category
1
for
severe
eye
damage
and
Category
2
for
skin
irritation,
it
should
be
labeled
with
the
corrosion
pictogram
and
the
signal
word
"
danger"
only.
The
label
should
not
bear
the
exclamation
point
pictogram
or
the
signal
word
"
warning.")

Specific
considerations
by
hazard
class:

°
For
acute
toxicity,
OPP
plans
to
adopt
all
five
GHS
categories
and
corresponding
label
elements,
including
the
use
of
the
signal
word
"
danger"
and
skull
and
crossbones
pictogram
for
Categories
1­
3
and
the
signal
word
"
warning"
and
exclamation
point
DRAFT
7/
7/
04
13
pictogram
for
Category
4.
In
addition,
consistent
with
FIFRA
Section
2(
q)(
2)(
D),
OPP
would
continue
to
require
the
word
"
poison"
to
appear
prominently
in
red
on
a
background
of
distinctively
contrasting
color
for
pesticides
that
meet
criteria
for
classification
into
the
two
highest
categories
of
acute
toxicity,
Categories
1
and
2
(
e.
g.,
oral
LD
50
of
up
to
50
mg/
kg).

°
For
skin
corrosion/
irritation
and
serious
eye
damage/
irritation,
OPP
plans
to
adopt
the
GHS
hazard
categories
and
label
elements,
including
the
corrosion
pictogram
for
Category
1
and
the
expanded
hazard
statement
for
skin
corrosives
("
causes
severe
skin
burns
and
eye
damage")..
With
respect
to
current
OPP
Category
IV
eye
irritants
(
minimal
effects
clearing
within
24
hours),
OPP
plans
to
propose
that
these
products
either
be
considered
unclassified
or
that
registrants
be
permitted
the
option
of
labeling
them
with
the
signal
word
and
hazard
statement
prescribed
for
Category
2B
eye
irritants.

°
For
skin
sensitization,
OPP
plans
to
revise
its
hazard
statement
to
be
consistent
with
the
GHS
and
to
adopt
the
GHS
signal
word
"
warning"
and
the
exclamation
point
pictogram.

°
For
aquatic
toxicity,
OPP
plans
to
adopt
the
classification
criteria
and
label
elements
for
Categories
1­
3
of
acute
aquatic
toxicity,
including
the
use
of
the
signal
word
"
warning"
and
the
fish
and
tree
pictogram
for
Category
1.

°
For
flammability
and
other
physical
hazards,
OPP
plans
to
adopt
all
GHS
hazard
classes
and
categories
and
the
corresponding
label
elements,
including
the
use
of
pictograms
and
signal
words.

Other
label
elements
prescribed
but
not
standardized
by
the
GHS:
In
addition
to
pictograms,
signal
words
and
hazard
statements,
labels
should
contain
precautionary
statements
(
beyond
the
hazard
statement
itself,
for
example,
first
aid
statements,
storage
and
disposal
statements,
etc.),
product
identifiers,
and
supplier
identifiers
in
order
to
be
consistent
with
the
GHS.
The
GHS
does
not
prescribe
specific,
standardized
language
for
these
label
elements.
OPP
believes
that
its
current
label
requirements
generally
satisfy
GHS
provisions
in
this
regard.

Existing
EPA
requirements
for
product
and
chemical
names
and
registration
numbers
are
consistent
with
GHS
product
identifier
provisions.
While
OPP
ingredient
disclosure
policies
may
differ
somewhat
from
the
GHS
in
terms
of
inert
ingredients,
the
GHS
provides
that
national
CBI
disclosure
provisions
will
take
precedence,
as
noted
in
the
previous
section,
and
therefore
these
OPP
policies
are
also
consistent
with
the
GHS.
OPP's
requirements
for
supplier
names,
addresses
and
establishment
numbers
generally
satisfy
the
GHS
with
respect
to
supplier
identifiers.
In
addition,
however,
the
GHS
calls
for
labels
to
include
telephone
numbers
as
part
of
the
supplier
identifier.
OPP
strongly
encourages
this,
and
many
pesticide
labels
do
contain
telephone
numbers
to
assist
users
seeking
additional
information.
We
plan
to
seek
comments
on
whether
this
should
be
made
a
requirement
to
improve
the
usefulness
of
pesticide
labels
and
achieve
greater
consistency
with
the
GHS.
DRAFT
7/
7/
04
14
Options
for
possible
implementation
mechanisms
Clearly,
implementation
of
the
changes
described
above
to
make
all
pesticide
labels
consistent
with
the
GHS
will
require
substantial
commitment
and
resources
from
OPP
and
other
stakeholders.
In
considering
possible
implementation
mechanisms,
OPP
has
two
fundamental
guiding
principles:
the
mechanisms
used
should
be
fair
to
the
regulated
community
and
should
minimize
the
resource
burden
placed
on
OPP
and
on
stakeholders
to
the
extent
possible.

Rule­
making
EPA's
current
hazard
classification
criteria
and
labeling
requirements
are
contained
in
Title
40
of
the
Code
of
Federal
Regulations,
Part
156
(
40
CFR
156).
EPA
intends
to
initiate
rule­
making
to
change
current
label
requirements,
to
bring
them
into
conformity
with
the
GHS.
In
addition,
we
will
review
other
regulations
that
may
be
based
in
whole
or
in
part
on
current
classification
and
labeling
categories,
to
determine
if
changes
are
appropriate.
As
noted
in
earlier
sections
of
this
paper,
GHS
is
based
on
hazard,
not
risk,
and
is
not
intended
to
harmonize
risk
assessment
or
risk
management
approaches.
To
the
extent
that
current
risk
management
measures
may
be
linked
to
classification
and
labeling
categories,
it
will
be
important
to
evaluate
whether
such
links
should
be
maintained
or
modified,
or
whether
they
should
be
"
decoupled."
State
pesticide
authorities
may
also
need
to
review
regulations
that
link
regulatory
consequences
beyond
labeling
to
classification
categories
and
identify
any
appropriate
changes.

Options
for
implementing
the
GHS
OPP
is
considering
two
basic
approaches
to
the
actual
review
and
approval
of
label
changes,
in
light
of
the
goals
of
ensuring
equity
and
efficiency
in
the
implementation
process.

Option
1:
A
separate
review
and
approval
process.
Under
this
approach,
which
could
be
implemented
with
contractor
support,
EPA
would
request
label
changes
be
submitted
as
amendments
to
current
labels.
Submissions
would
be
limited
to
GHS
changes
only.
The
dates
for
submission
could
be
staggered,
so
that
changes
would
be
phased
in
by
chemical
or
class
of
chemicals.
All
labels
would
be
reviewed,
and
if
contractor
support
is
used
for
the
review
of
labels,
OPP
staff
would
do
a
secondary
review
of
some
percentage
of
submissions.
While
this
approach
has
the
attraction
of
providing
for
more
uniformity
in
the
timing
of
label
changes,
it
has
the
disadvantages
of
requiring
a
substantial
new
commitment
of
resources
and
creating
a
major
new
workload
for
OPP
and
for
pesticide
registrants.

Option
2:
Integrating
GHS
changes
into
ongoing
registration
and
re­
registration
actions
and
label
changes
that
come
in
for
OPP
review.
Under
this
approach,
registrants
who
are
making
changes
in
their
labels
would
incorporate
the
GHS
revisions
as
part
of
their
routine
business.
Consistent
with
the
international
GHS
implementation
goal
of
2008,
the
policy
could
be
that
all
label
amendments
submitted
for
review
during
the
period
2006­
2008
should
include
the
GHS
DRAFT
7/
7/
04
15
along
with
any
other
changes
that
are
being
proposed.
OPP
could
set
a
final
deadline
(
or
staggered
series
of
deadlines
if
necessary
for
workload
management)
by
which
all
registrants
who
have
not
already
revised
their
labels
would
be
required
to
submit
GHS
amendments.

The
major
advantage
of
this
approach
is
that
it
does
not
create
a
major
new
workload
for
OPP
or
registrants
but
allows
the
GHS
changes
to
be
made
in
the
course
of
other
routine
label
changes
and
reviews.
While
products
with
similar
characteristics
might
have
different
labels
for
some
period
of
time,
due
to
the
fact
that
the
registrants
did
not
choose
to
revise
their
labels
at
the
same
time,
this
would
not
persist
for
an
undue
length
of
time
and
is
not
materially
different
from
the
situation
that
exists
when
other
label
changes
are
made:
there
are
often
different
labels
in
the
marketplace
due
to
differences
in
the
time
it
takes
for
existing
label
stocks
to
be
exhausted.

In
light
of
the
relative
advantages
of
the
two
approaches,
OPP's
current
thinking
is
that
the
second
option
is
preferable,
since
it
allows
for
the
GHS
changes
to
be
accomplished
without
creating
new
procedures
or
significantly
disrupting
ongoing
work
and
business.
In
either
approach,
an
upgraded
acute
toxicity
database
would
facilitate
efficient
review
of
GHS
label
changes
and
the
progress
of
implementation
could
be
tracked
through
use
of
special
codes
for
label
amendments
containing
GHS
revisions.

Other
measures
to
promote
more
efficient,
effective
implementation
In
preparation
for
GHS
implementation
and
in
the
interest
of
improving
the
efficiency
of
OPP
label
review
procedures
generally,
we
are
investigating
the
possibility
of
upgrading
our
database
of
acute
toxicity
data
to
reflect
the
GHS
categories
and
therefore
ease
the
burden
of
reviewing
new
labels
when
changes
begin
to
be
made.
This
will
be
a
significant
improvement
regardless
of
the
implementation
mechanism(
s)
selected.

OPP
is
also
considering
the
possibility
of
pilot
project
before
final
rule
changes
implementing
the
GHS
are
in
place.
A
pilot
project
could
allow
for
voluntary
submissions
of
label
amendments
with
GHS
changes
by
registrants
who
wish
to
make
the
revisions
at
an
earlier
date.
Experience
gained
in
such
a
pilot
could
help
OPP
refine
procedures
for
label
review.
Criteria
for
participation
in
the
pilot
project
should
be
drawn
to
keep
the
workload
manageable.

Another
way
in
which
the
approach
to
label
review
could
be
piloted
on
a
relatively
small
scale
would
be
to
call
for
voluntary
GHS
changes
to
be
made
in
connection
with
label
revisions
required
by
Re­
registration
Eligibility
Decisions.

Finally,
as
implementation
planning
proceeds,
OPP
wants
to
explore
opportunities
for
work
sharing
with
states
and/
or
through
the
NAFTA
TWG.
This
could
reduce
the
workload
for
all
parties
and
enhance
efficiency.

Timing
DRAFT
7/
7/
04
16
At
the
international
level,
as
noted
above,
the
Intergovernmental
Forum
on
Chemical
Safety
and
the
World
Summit
on
Sustainable
Development
have
called
for
implementation
of
the
GHS
to
the
extent
possible
by
2008.
This
is
a
very
ambitious
goal
in
terms
of
pesticide
labels.
In
addition,
OPP
will
need
to
coordinate
with
other
agencies
working
toward
GHS
implementation
in
their
programs,
including
the
Department
of
Labor
Occupational
Safety
and
Health
Administration,
the
Department
of
Transportation,
and
the
Consumer
Product
Safety
Commission.
We
also
plan
to
work
toward
coordinated
implementation
under
the
NAFTA
TWG.

It
is
difficult
to
predict
time
frames
at
this
early
stage
of
implementation
planning.
Ideally,
rulemaking
could
be
initiated
in
2004
and
completed
in
2005.
After
a
proposal
is
published,
a
pilot
project
could
be
undertaken.
Once
regulations
have
been
promulgated,
OPP
would
expect
to
see
label
amendments
incorporating
the
GHS
changes.

It
is
likely
that
implementation
activities
at
the
State
level
will
be
needed
after
EPA
approval
is
obtained.
EPA
intends
to
work
with
States
to
ensure
a
smooth
follow­
on
process
and
reasonable
time
to
obtain
State
approvals.

IV.
OUTREACH
ACTIVITIES
AND
PLANS,
REQUEST
FOR
COMMENT
As
described
in
Part
I
of
this
paper,
U.
S.
and
international
negotiators
made
considerable
efforts
to
involve
stakeholders
throughout
the
GHS
development
process.
Representatives
of
regulated
industry
and
groups
who
use
or
are
otherwise
exposed
to
chemicals
participated
in
the
negotiation
and
joined
in
the
consensus
approval
of
the
GHS
document.
Despite
these
efforts,
OPP
recognizes
that
many
concerned
stakeholders
are
likely
not
to
be
aware
of
the
GHS
or
its
implications
for
pesticide
labels,
and
that
substantial
outreach
and
education
should
be
undertaken
in
connection
with
GHS
implementation.

In
recent
months,
we
have
participated
in
number
of
awareness­
raising
activities
with
OPP
stakeholders,
including
presentations
at
meetings
and
workshops
and
briefings
for
outside
groups
and
the
Pesticide
Program
Dialogue
Committee,
OPP's
principal,
broadly­
based
advisory
committee.
We
have
consulted
with
pesticide
educators
who
will
be
involved
in
updating
manuals
and
training
users
in
how
to
interpret
revised
labels
and
have
encouraged
stakeholder
organizations
to
educate
their
members
about
the
GHS.
We
will
be
continuing
these
activities
and
invite
suggestions
for
how
to
expand
and
improve
them
to
promote
more
effective
stakeholder
participation
in
implementation
planning.
We
are
also
upgrading
our
website
information
on
the
GHS
and
will
be
developing
educational
materials
for
pesticide
users
in
cooperation
with
interested
stakeholders.

With
this
paper,
OPP
is
opening
a
new
phase
of
outreach,
beyond
GHS
awareness­
raising,
to
share
our
current
thinking
and
solicit
comment
on
the
implementation
issues
under
consideration.
In
particular,
we
are
inviting
comments
on
the
following
questions:
DRAFT
7/
7/
04
17
°
What
are
your
views
on
the
options
presented
for
GHS
implementation
mechanisms?
Are
there
additional
considerations
you
believe
OPP
should
take
into
account?

°
Do
you
have
recommendations
on
additional
regulations,
in
addition
to
40
CFR
156,
which
you
believe
may
warrant
review
and
possible
revision
in
connection
with
GHS
implementation?

°
Would
you
favor
a
voluntary
pilot
project
to
permit
GHS
label
revisions
before
final
rules
are
in
place?
If
so,
what
criteria
would
you
propose
for
participation
in
the
pilot?

°
What
time
frames
would
be
reasonable
for
the
various
steps
involved
in
implementation,
consistent
with
international
implementation
goals?

°
Do
you
have
suggestions
for
work
sharing
with
NAFTA
TWG
partners
and/
or
states,
or
for
other
efficiencies
that
could
be
introduced
to
improve
the
process?

°
What
are
the
most
effective
steps
that
OPP
can
take
in
terms
of
outreach
and
education?
