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Taiwan GHS

  •   13 Apr 2018
  •    Nadine He

    Improper uses of chemicals without fundamental understanding of their hazards may damage the environment and cause human injuries. To secure safe use of hazardous chemicals, Taiwan began phased implementation of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) in 2008 and has fully adopted GHS since 1 Jan 2016.

    Contents

    1. Competent Authority

    With the interagency coordination efforts, Taiwan began phased implementation of GHS. The key authorities involved in GHS impelementation in Taiwan are as below:

    • Workplace: MoL (Miniatry of Labor, previously known as CLA, the Council of Labor Affairs under Executive Yuan)
    • Toxic Chemical Substance: EPA (Environmental Protection Administration)
    • Transport: MOTC (Ministry of Transportation and Communication)
    • Emergency Response: EPA (Environmental Protection Administration) & NFA (National Fire Agency)
    • Consumer Product: MOEA (Ministry of Economic Affairs)
    • Environmental Agents/Pesticide: EPA (Environmental Protection Administration) & COA (Council of Agriculture, Executive Yuan)

    2. History 

    Phased implementation of Taiwan GHS:

    • Feb 2006: Taiwan Interagency GHS Implementation Plan was passed by Executive Yuan
    • Oct 2006: Taiwan Bureau of Standards, Metrology and Inspection (BSMI) completed the CNS 15030 series standards and revision of CNS 6864
    • 19 Oct 2007: Taiwan issued Regulation of Labeling and Hazard Communication of Dangerous and Harmful Materials, which came into effect on 31 Dec 2008, marking the beginning of the phased implementation of Taiwan GHS
    • First/Second/Third stage of GHS took effect respectively
      • 1st stage: implemented on 31 Dec 2008 with one year transitional period ending on 31 Dec 2009
      • 2nd stage: implemented on 7 Jan 2011 with transitional period ending on 31 Dec 2011
      • 3rd stage: implemented on 1 Jan 2014 with a one year transitional period ending on 31 Dec 2014
    • 27 Jun 2014: Regulation of Labeling and Hazard Communication of Dangerous and Harmful Materials was renamed as the Regulation of Labeling and Hazard Communication of Hazardous Chemicals, which took effect from 3 July 2014.
    • 1 Jan 2016: full implementation of GHS for all substances and mixtures

    3. Main Regulations and Standards

    Taiwan Laws

    --Occupational Safety and Health Act (Taiwan OSHA)

    Article 10: “The employers shall label, make inventories, and display safety data sheets for hazardous chemicals, and adopt necessary hazard communication measures. Prior to providing the chemicals in the preceding paragraph to business entities or self-employed workers, the manufacturers, importers, or suppliers shall label them and provide safety data sheets; the same requirements apply to any change of information.”

    The “hazardous chemicals” here refer to substances with physical/health hazards that satisfy CNS15030 classification.

    --Toxic Chemical Substances Control Act (Taiwan TCSCA)

    Article 17: “The handler shall mark matters related to toxicity and pollution control measures pursuant to regulations on Class 1, Class 2, Class 3, and Class 4 toxic chemical substance on containers, packaging, handling sites, and facilities, and shall keep safety data sheets for the corresponding toxic chemical substances.”

    The toxic chemical substances are accessible here.

    Taiwan Regulations

    --Regulation of Labelling and Hazard Communication of Hazardous Chemicals (formulated according to Article 10 of OSHA, MoL)

    The amendments of the “Regulation of Labeling and Hazard Communication of Dangerous and Harmful Materials”, renamed as the Regulation of Labeling and Hazard Communication of Hazardous Chemicals was promulgated by MoL No.10302007861 on 27 Jun 2014 and took effect from 3 July 2014. This is the most important regulation in Taiwan for GHS implementation.

    Latest update: MoL issued on 29 Mar 2018 the draft amendments of the Regulation of Labeling and Hazard Communication of Hazardous Chemicals for a 60-day public consultation. The proposed revisions have been summarized by ChemLinked. Please click here to read more. 

    --Toxic Chemical Substances Labelling and SDS Regulation (formulated according to Article 17 of TCSCA, EPA)

    The amendment of Taiwan’s “Toxic Chemical Substances Labeling and Materials Safety Data Sheet Regulation”, renamed as “Toxic Chemical Substances Labeling and Safety Data Sheet Regulation” was promulgated by EPA No. 1030094561 on 10 Nov 2014 and took effect on 11 Dec 2014. It sets out the classification and labeling requirements for toxic chemicals in Taiwan.

    --additional regulations

    • Other Councils and Ministries that govern chemical regulation for example:
    • Council of Agriculture (COA) – Regulations of Pesticides labeling Management
    • Ministry of Economic Affairs (MOEA) – Labelling Criteria for Commercial Product

    Taiwan Standards

    --CNS 15030 series: Classification & Labelling of Chemicals

    The CNS 15030 serial standards are issued as the rules for classification and labeling of hazardous chemicals in Taiwan. The standards were established in 2006 and updated to align with the UN-GHS 4th revision in 2015.

    --CNS 6864: Labels for the Transport of Dangerous Goods

    The standard was revised and promulgated on 12 Dec 2006 adopting 14th revision of UN TDG for Transport.

    4. Obligation

    Taiwan CLA is taking the lead in developing a national chemical inventory for Taiwan’s stage-wise GHS implementation. Taiwan adopted GHS on 31 Dec of 2008 when the first stage of GHS was implemented, which only covers 1,062 hazardous substances. The second stage of GHS implementation was initiated on 7 Jan 2011, covering 1,089 substances. In addition, another 1,020 hazardous substances are designated for the third stage of Taiwan GHS which implemented on 1 Jan 2014. All the three batches were subject to a one-year transitional period.

    Other hazardous chemicals besides the 3,171 substances (three batches) designated by the CLA, if found falling within the scope of the Regulation of Labelling and Hazard Communication of Hazardous Chemicals, should also comply with Taiwan GHS since 1 Jan 2016 while granted with a one-year transitional period which ended on the 31st of Dec, 2016.

    Exemption of Taiwan GHS

    • Hazardous industrial waste
    • Tobacco or tobacco products
    • Food, beverage, drugs, cosmetics
    • Article
    • General consumer products for non-industrial uses
    • Fire extinguisher
    • Intermediate products undergoing chemical reactions in the reactors or processes
    • Other designated by the central competent authority

    Classification

    Issues relating to the classification and labelling of chemicals should refer to the CNS 15030 serial standards. The standards were initiated in 2006 based on the 1st revised version of UN GHS and revised in 2008 to encompass GHS Rev.2. On 26 Jan 2015, Taiwan's Bureau of Standards, Metrology and Inspection (BSMI) of the Ministry of Economic Affairs (MOEA) finalized changes to 11 of the 28 national CNS 15030 serial standards. On 23 Sep 2015, BSMI published the new volume for "hazardous to the ozone layer" (CNS 15030-28). The 12 new standards revised/published in 2015 are aligned with UN GHS Rev.4., which are highlighted below in red.

    The CNS 15030 serial standards (CN/EN documents) can be purchased on the CNS website (http://www.cnsonline.com.tw/?locale=en_US).

    Hazard

    Standard No.

    Classification of Hazard

     

    CNS 15030

    General rules

    Physical Hazard

    CNS 15030-1

    Explosives

    CNS 15030-2

    Flammable gases (including chemically unstable gases)

    CNS 15030-3

    Aerosols

    CNS 15030-4

    Oxidizing gases

    CNS 15030-5

    Gases under pressure

    CNS 15030-6

    Flammable liquids

    CNS 15030-7

    Flammable solids

    CNS 15030-8

    Self-reactive substances and mixtures

    CNS 15030-9

    Pyrophoric liquids

    CNS 15030-10

    Pyrophoric solids

    CNS 15030-11

    Self-heating substances and mixtures

    CNS 15030-12

    Substances and mixtures which, in contact with water, emit flammable gases

    CNS 15030-13

    Oxidizing liquids

    CNS 15030-14

    Oxidizing solids

    CNS 15030-15

    Organic peroxides

    CNS 15030-16

    Corrosive to metals

    Health Hazard

    CNS 15030-17

    Acute toxicity

    CNS 15030-18

    Skin corrosion/irritation

    CNS 15030-19

    Serious eye damage/eye irritation

    CNS 15030-20

    Respiratory or skin sensitization

    CNS 15030-21

    Germ cell mutagenicity

    CNS 15030-22

    Carcinogenicity

    CNS 15030-23

    Reproductive toxicity

    CNS 15030-24

    Specific target organ toxicity-Single exposure

    CNS 15030-25

    Specific target organ toxicity-Repeated exposure

    CNS 15030-26

    Aspiration hazard

    Environment Hazard

    CNS 15030-27

    Hazardous to the aquatic environment

     

    CNS 15030-28

    Hazardous to the ozone layer

    SDS Requirement

    The 16-sections SDS is align with UN GHS. SDS shall be provided using Chinese characters as standard, and foreign languages as a supplement if necessary. A Safety Data Sheet shall be reviewed at least once every three years.

    content and sample of Taiwan SDS

    To protect security and confidential business information, data protection of the name, content, manufacturers, importers or suppliers of the hazard chemicals can be applied for prior to SDS compilation. However, hazardous chemicals with the following hazard classification according to the CNS 15030 are not eligible for data protection.

    • Acute toxicity: Category 1, 2, 3
    • Skin corrosion/irritation: Category 1
    • Serious eye damage/eye irritation: Category 1
    • Respiratory sensitization/skin sensitization
    • Germ cell mutagenicity
    • Carcinogenicity
    • Toxic to reproduction
    • Specific target organ toxicity (single exposure): Category 1
    • Specific target organ toxicity (repeated exposure): Category 1

    If the applicant is an overseas manufacturer/supplier, a Taiwanese company or institute should be designated as a representative to apply for confidential information protection. The letter of authorization (LOA) should be provided.

    Online CBI application: https://ghs.osha.gov.tw/CHT/intro/SDSApply.aspx

    Label Requirement

    Employers shall label the following items on containers containing hazardous chemicals, using Chinese characters as standard and foreign languages as a supplement if necessary. In addition, manufacturers, importers or suppliers shall label the containers prior to providing business entities or self-employed workers with hazardous chemicals.

    https://cdn.chemlinked.com/chem-list/taiwan_label_cn.png

    **Small package: If the volume of the container is 100ml or less, the container may only be labelled with the hazard pictogram, name, hazard pictograms, and signal word.

    Industries are required to ensure the compliance of their SDS, labeling and other required hazardous communication measures as per regulation. The hazard data of some GHS-classified hazardous substances are accessible on Taiwan’s chemical hazards database in traditional Chinese, including the English and Chinese name, CAS No., UN No., physic-chemical, toxicity and eco-toxicity data, SDS template, transportation markings, etc. The database is dynamically updated to incorporate more substances.

    In addition, in Mar of 2017, the Occupational Safety and Health Administration of Taiwan (OSHA) published a list of classified chemicals which contains 3,000 substances and their recommended classification results. Another 6,000 hazardous substances have been classified and their recommended GHS classifications (accessible here) were issued in Jan of 2016. Relevant stakeholders can refer to the online database and the additional list for reference in preparation of SDS and label.

    Another supporting tool developed by the authority is the mixture classification system. It assists enterprises to classify and label mixture products under Taiwan GHS.

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