I have a comment on your Dec 2011 newsletter - an article titled "Brazil: leading chemicals control in South America".
Regarding "Labelling", there is an ambiguos statement in there saying:
"Chemical products that are GHS classified as non-hazardous must have a simplified label at least indicating the chemical name and any information about the non-hazardous procuct and reccommendations of use".
This is not a typo, because it continues in the "SDS" section beneath it:
"They must also supply an SDS for chemical products classified as non-hazardous, but whose predicted or recommended uses will have increased risks to worker safety and health".
Can somebody clarify if or why non-hazardous ingredients have to be disclosed on labels in Brazil? This does not match up with the EU CLP.
Posted on behalf of Edgar Rodriguez Sierra, ChemADVISOR:
Dear Patrick,
Thank you very much for your inquiry regarding the Brazilian Article in Chemical Watch. In regards to your question, please note that the text included in the article is a direct translation of July 27, 2011, Workplace Safety Markings Regulatory Standard NR-26 update of the Brazilian Hazard Communication Program. NR-26 is not in line with EU-CLP because is a Brazilian internal regulatory standard related to workplace markings and used as a regulatory tool to change the current GHS “soft-law” into a compulsory law. As you can read in the translated text of the article, it mentions the current Brazilian GHS standard as a source of compliance but NR-26 is the regulatory law for non-hazardous classification of substances.
The office of the Labor Inspection Secretary is the competent authority for NR-26.
Please do not hesitate to contact me if you have further questions.
Sincerely,
Edgar Rodriguez Sierra, ASHM Regulatory Compliance Specialist ChemADVISOR, Inc. T: +1 412-203-4096 (direct line) T: +1 412-847-2000 or 800-466-3750 (main) erodriguezsierra@chemadvisor.com www.chemadvisor.com
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