Report on the United Nations (UN) Sub-Committee of Experts (SCE) on the Globally Harmonized System of Classification and Labelling of Chemicals (GHS)

To ensure consistency between regulatory systems throughout the world, the United Nations (UN) established a sub-committee dedicated to address classification of chemicals. Known as the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), the new system addresses classification by types of hazard and proposes harmonized hazard communication elements, including labels and safety data sheets. The UN Sub-Committee of Experts (SCE) on GHS considers proposed changes to the system. The subcommittee meetings are democratic processes where a proposal is adopted if it gathers a simple majority of votes cast by country delegations. The UN SCE GHS meets twice per year in Geneva, Switzerland, and conducts its work on a biennium system. In other words, the subcommittee has two years to accomplish any work for that biennium before a new set of changes to GHS are published.

ACA, through the World Coatings Council, is proactively engaged in UN efforts to ensure changes to the GHS are effective and work for the paints and coatings industry. As such, the World Coatings Council attends the UN SCE GHS meetings to record discussions of proposals of interest and advocate for the paint and coatings industry.

The 46th Session of the Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals will take place in July 2024. Among other issues, the subcommittee will consider adoption of new hazard classes already adopted into the European Classification, Labeling and Packaging Regulation (CLP). As of March 2023, Europe updated the CLP with the following non-GHS hazard classes:

• Endocrine disruption for human health (Cat. 1 & 2)
• Endocrine disruption for the environment (Cat. 1 & 2)
• PBT (persistent, bioaccumulative and toxic) and vPvB (very persistent and very bioaccumulative)
• PMT (persistent, mobile and toxic), vPvM (very persistent and very mobile)

The GHS Subcommittee initiated a working group to further evaluate the need for adoption. The working group will develop mandates to the OECD for further input starting with endocrine disruption. Although the working group was unable to agree on a definition of endocrine disruption, in July it submitted its mandate to the OECD for further consideration. The OECD is currently evaluating whether existing GHS hazard classes affectively address endocrine disruption or whether a separate hazard class is needed. To that end, OECD opened a call for further data from its group of experts, closing on October 6, 2023. OECD anticipates developing an informal working paper by October 2024. The informal working paper will either contain OECD’s recommendation or detail progress and further steps towards a recommendation.

The working group formed to advise the GHS Subcommittee is currently developing a mandate to the OECD regarding the PMT and vPvM hazard classes. The working group is currently considering definitions, testing requirements and scope of application, and it expects to develop an informal working paper for further discussion at the 46th Session of the Subcommittee of Experts in July 2024.

The WCC has been actively participating in the working group and will continue to do so as the work progresses. The working group intends to submit an informal document to the OECD by May 2024 capturing discussion related to definitions of persistence and mobility, as separate chemical properties, rather than a joint characteristic. The working group has also had vigorous discussion around whether persistence and mobility are inherent chemical properties rather than characteristics impacted by external, environmental factors, to the extent such distinction can be made.

At its 46th Session, the Subcommittee of Experts will also consider the following issues:

• Several proposals related to the clarification on the combination of aerosols and chemicals under pressure
• Proposed revision of the term “radioisotopic.”