GHS in Taiwan
Taiwan is among the first areas in the world that have adopted GHS.
In December 2007, Taiwan Executive Yuan approved the effective date of December 31st 2008 for GHS implementation in workplace, environmental protection and public dangerous goods control, by following Taiwan GHS standards CNS 15030 'Classification & Labelling of Chemicals' and coordinated by 3 leading ministries in Taiwan i.e. Taiwan Labor Committee, Environmental Protection Agency and Taiwan Fire Bureau, among which Taiwan Labor Committee and Environmental Protection Agency are the 2 most active authorities. A transitional period from December 31st 2008 to December 31st 2009 is designed for industries to convert from current system (UNRTDG, i.e. United Nation Recommendation on Transportation of Dangerous Goods) to GHS.
Taiwan EPA rules the toxic chemicals (as listed by Taiwan EPA, ca. 250 chemicals) shall follow GHS. While Taiwan Labor Committee follows phase-in introduction of GHS system. During the period from 2008 to 2013, Taiwan Labor Committee (name changed to 'Ministry of Labor' in 2014) designated the substances that were highly hazardous and manufactured/imported in large volume for GHS classification and labelling by three-phase announcements. It was also announced by Ministry of Labor in December 2013 that full GHS implementation will be started from January 1st, 2016 for all hazardous chemicals with one-year transitional period (from January 1st, 2016 to December 31st, 2016). During the transitional period, non-GHS SDS and Label are allowed for hazardous chemicals not covered by the three-phase announcements.
For phase I, totally 1,062 substances (including their mixtures) were announced for compliance with GHS latest by December 31st, 2009. In January 2011, second batch of 1089 substances (including their mixtures) were announced as phase II compliance with GHS latest by December 31st, 2011. In December 2013, a third batch of 2010 substance (including their mixtures) were announced as phase III compliance with GHS latest by December 31st, 2014.
Now is in 2016, full implementation of GHS in Taiwan is in place according to the announcement by Ministry of Labor. Violations of the requirement maybe subject to a fine of from NT$30,000 to NT$150,000 (ca. 830~4,120 Euro). Failed improvements within a limited time period will face an additional fine per violation. Taiwan Occupational Safety & Health Agency (OSHA) also announced to target petrochemical and high tech worksites for the inspection in year 2016.
GHS standards in Taiwan are CNS 15030 serial standards, which were firstly issued in October 2005 based on GHS 2005 (Version 1). The latest revised CNS 15030 were issued in January 2015 based on UN GHS 2011. CNS 15030 standards adopts all blocks (categories) of GHS hazards. Although Taiwan CNS 15030 standards are based on UN GHS 2011, while it is ok by referring to latest UN GHS and CNS 15030 standards also say as such.
Official language for Taiwan is Chinese, and it is required that SDS and labels shall be provided in Chinese (traditional) per 'Regulation of Labelling and Hazard Communication of Hazardous Chemicals' issued by Ministry of Labor. When it is necessary, foreign languages can be used as supplement.
For Taiwan SDS, Taiwan has some specific requirements,
1.The Chinese translation of 'Safety Data Sheet', name of each section of SDS, hazard statements shall use the Chinese translation standardized by Taiwan authority, as indicated in 'Regulation of Labelling and Hazard Communication of Hazardous Chemicals' issued by Ministry of Labor and in 'Regulation of Labelling and Safety Data Sheet of Toxic Chemicals' issued by Environmental Protection Agency.
2.Section 1 of SDS shall provide 24hr emergency telephone number, while does not specify the telephone number shall provide Chinese speaking or be in Taiwan.
3.In section 3 of SDS, both Chinese and English name of components shall be provided, as required in the SDS format issued by Ministry of Labor and Environmental Protection Agency in the 2 regulations mentioned above.
4.CBI can be applied for components and name of supplier/manufacturer/importer, after the application is approved by Taiwan authority. While CBI for components of CMR and of category 1~3 acute toxicity as well as well as category 1 of other health classifications can not be applied.
5.Section 16 of SDS shall provide name of the company and name of the person who prepared the SDS.
6.SDS shall be reviewed at least every 3 years, and the revised content shall be kept for 3 years.
For Safety Label, Taiwan also issued format for reference. It is required that the pictograms shall be in color, and all hazard statements shall be provided. If a component is 'toxic chemical' as issued by Environmental Protection Agency, the Chinese and English name of the toxic chemical shall use the names as used by Environmental Protection Agency.
Taiwan authority has made a lot of efforts on supporting GHS implementation. For example, Taiwan OSHA published GHS classifications for more than 6000 chemicals to by referring data from ECHA website and other resources. These non-mandatory GHS classification results can be referred by industry at voluntary basis so to facilitate the industry's work. Taiwan OSHA also set up a website (ghs.osha.gov.tw) with English version for introducing GHS and legislations, industry can refer to the website for further information.
In summary: GHS for SDS and Label in the language of Chinese (traditional) for Taiwan is mandatory. With full implementation of GHS for all hazardous chemicals in Taiwan from 2016, the inspection by authority will be enforced. Get prepared to be in compliance latest by end of 2016.
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Jan. 27, 2016
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