Government Notice No . R 280 on 29 March 2021 . Prior to this , she noted , there had generally been a relatively long time gap between amendments to existing legislation , GHS compliance was voluntary and national standards were aligned with UN standards . This latest amendment integrates the UN GHS with a transition period until September 2022 . It covers :
• Prohibited hazardous chemical agents , i . e . GHS-aligned chemical agents as defined in Annexure 1
• Classification of hazardous chemical agents
• SDSs
• Occupational exposure limits ( OELs ) with maximum and restricted limits
• Biological exposure indices The regulation prohibits the manufacturing , procurement , use , handling and storing within workplaces of :
• Substances listed in Table 1 of Annexure 2
• Ozone-depleting substances , as defined in Appendix A in Regulations Regarding the Phasing-Out & Management of Ozone Depleting Substances
• Substances listed in the Prohibition on the Import , Export , Possession , Acquisition , Sale , Use & Disposal of Agricultural Remedies under Section 7 of the Fertilisers , Farm Feeds , Seeds & Remedies Act 36 of 1947 Before a possible HCA is supplied to a workplace , the user must carry out a hazard assessment referencing the cut-off values provided in Tables
4 and 5 of Annexure 1 . If it is proved to be an HCA , a GHS classification must be carried out and this must be reviewed whenever a change is made to the composition .
Review required
SDSs must be UN GHS-compliant , reviewed at least once every five years and amended on a regular basis , said Kasim . In addition , manufacturers , importers , suppliers , retailers and employers must ensure correct labelling in accordance with the UN GHS . Mandatory information includes : the product identifier ; the chemical identity ; the name , address and telephone number of manufacturer or importer ; an emergency telephone number ; and a signal word , hazard statement , precautionary statement and hazard pictogram . The quantity of HCA and each HCA ingredient , further safety information , first-aid measures and the expiry date may also be included . Manufacturers and importers must ensure the correct packaging for HCAs as laid down by the UN Transport of Dangerous Goods , the IMO International Maritime Dangerous Goods Code and the IATA Dangerous Goods Regulations , as well as South Africa ’ s National Road Traffic Act No . 93 of 1996 The chemical identity of an ingredient in an HCA must be disclosed , Kasim said . However , it may be disclosed by a generic name if : the identity of the ingredient is commercially confidential ; it does not cause the correct classification
of the hazardous chemical to include any other hazard class and hazard category in Table 4 ; and an OEL for it has not been established . All this is similar to the criteria referred to in Article 24 of Regulation ( EC ) No . 1272 / 2008 Annex I , Part 1 . Finally , there are requirements in place to recycle all HCA waste and ensure that it is classified and disposed of as waste based on the Waste Classification & Management Regulations ( Government Notice No . R 634 ) and the National Norms & Standards for the Assessment of Waste for Landfill Disposal ( R 635 ). “ The key takeaways are that careful consideration of multiple regulations across various departments may be needed when seeking compliance in South Africa ,” Kasim concluded . “ Complying with UN GHS has become mandatory for industrial chemicals in the workplace and conformity with the latest revision of the GHS is still expected .”
Kenya leads the way
Other African countries are also moving forward with chemical management regulations , said Nhat Nguyen of
70 SPECIALITY CHEMICALS MAGAZINE ESTABLISHED 1981