Situation and Gap Analysis for GHS Capacity Building in Consumer Product Sector Chemical Safety Section Food and Drug Administration Thailand National.

Situation and Gap Analysis for GHS Capacity Building in Consumer Product Sector Chemical Safety Section Food and Drug Administration Thailand National Focal Point for IFCS

IFCS Forum IV Forum V 2003 2006 Member State Thailand APEC (by 2006 for industrial chemicals) WSSD (by 2008) GHS practice Background Situation analysis Gap Analysis Comprehensibility Test Synergy development of policy and implement n plan Methodology Outcome Strategies Legislation / Measure Capacity Building Contribute Global Goal for GHS implementation Rationale/Objectives To analyze strategies needed for 4 sectors in Thailand Industrial Agriculture Transport Consumer

ImportStorage Product n / Package Transport Storage IndustryAgriculture Consumer Environment /Health Locally made Waste storage Transport Treatment Recycle Disposal Transport Domestic Export Waste storage Distribut n Use In case of no treatment Note : Yellow = Acute, Local adverse effect Red = Chronic, Widespread adverse effect Life Cycle of Chemicals

Common Causes of Consumer Products adverse effects Inefficient enforcement and control over diverse consumer products Inadequate chemical hazard information on product labels Insufficient understanding /concerns Incorrect public perception about risk & benefit of chemicals Accidents, esp. with Children Misuse for suicide attempts

ScopeTarget Population Household pesticides Pesticides for commercial application Cleansing products Disinfectants Water treatment chemicals Other Household and Personal care products having potential risks Pharmaceutical chemicals Chemicals used in manufacturing consumer products Chemicals used in medical care and public health Youths - Primary /Secondary schools - Vocational colleges/ Universities Consumers Public Commercial applicators for pest control Business sector for consumer products & service Regulators Medical / Public health staff, esp. poison center Consumer Product Sector

Major Regulators in Consumer Product Sector Food and Drug Administration (FDA) Thai Industrial Standards Institute (TISI) Consumer Protection Administration (CPA)

Related Legislation FDA Hazardous Substance Act 1992 Cosmetic Act 1992 Psychotropic Substance Act 1975 Narcotics Act 1979 Emergency Decree on Volatile Substance 1990 Drug Act 1967 Medical Device Act 1988 Notification of Commerce Ministry RE: Importation of Pharmaceutical Chemicals into Thailand 2002 CPA Consumer Protection Act 1998 Workplace regulators Factory Act 1992 Notifications RE: Occupational Safety Other agencies Notification RE: LPG packaging Armament Control Act 1987

Industrial Chemical Trade Source: Ministry of Commerce

Pesticide Trade Source: Ministry of Commerce

Consumer Product Trade Source: Ministry of Commerce

Nature of Thai Consumer Product Sector Mainly produced and used in country Export > > Import Exportation to countries in the region Business for Production, Export, Import, Commercial Service of Hazardous Substances under FDA Control - Local >>Multinational companies 84% 16% Source: Hazardous Substance Control Group, FDA, as of 31/01/2006 Most categorized as SMEs (production---having not more than 200 employees and 200 million Baht of property)

Civil Societies and Research Institutes NGOs: Foundation of Consumers Campaign for Alternative Industry Network Others dealing with Public Health, OHS etc Having specific outreach towards communities, vulnerable groups (research, monitoring, campaign) Research Institutes: Thailand Research Fund Thai Health Promotion Foundation Thai Systems Research Institute etc Getting more involved in developing national chemical policy Strong need to build up concern and network of NGOs regarding GHS and Chemical Hazard Communication

Current Situation in Thailand: Classification of Consumer Products Measure-based approach for consumer protection Pre-marketing control Post-marketing control License /permit for Settlement Monitoring -Product Surveillance Hazardous Substance Act 1992 Production/ import/ export / possession of Hazardous chemical products for household and public health use: Type I : No need for registration and license Type II : Notification to authority, Registration needed Type III : License needed Type IV : Ban for all activity

AgencyTypeTotal IIIIIIIV Dept. of Industrial Works572821168364 FDA225106114247 Dept. of Agriculture017539102658 Dept. of Fisheries318012 Dept. of Livestock03003 Office of Atomic for Peace00808 Dept. of Energy Business00303 Total62748752841295 Hazardous Substance Act Source: Thailand Chemicals Management Profile 2005

Other Measure-based approaches for Consumer Protection Psychotropic Substance Act 1975Chemical/ product with psychotropic effect Narcotics Act 1979Chemical/ product with narcotic effect Emergency Decree on Volatile Substance 1990 Chemical with volatile property Drug Act 1967Pharmaceutical chemical Medical Device Act 1988Chemical/ reagent for medical test & care Cosmetic Act 1992Chemical / product for all personal care

Existing Classification of Chemical by Hazard Notification of Ministry of Public Health RE: Label and Toxic Level of Hazardous Substance under FDA Control comply with WHO recommended classification of pesticides by hazard Classification of Acute Health Hazard by LD50 For product registration, information about other health hazards are needed (e.g. irritation, mutagenicity, carcinogenicity, etc.) But there is no requirement for classification

Acute Hazard Classification THAI1A1B23 Oral LD50 (mg/kg) < 55-5050-500>500 GHS12345 Oral LD50 (mg/kg) 5 50 300 2000 5000

Existing Classification & Labelling of Acute Hazard THAI1A1B23 Oral LD50 (mg/kg) < 55-5050-500>500 Labelling

GHS Classification & Labelling of Acute Hazard GHS12345 Oral LD50 (mg/kg) 5 50 300 2000 5000 Pictogram Signal word Danger Danger Danger Warning Warning Hazard statement Precautionary statement

Acid / Base 10% 10% Thai Pictogram GHS Category123 Acid /Base 1% -- Pictogram Signal Word Danger Warning Warning Hazard Statement Cause severe skin burn Cause skin irritation Labelling of Skin Corrosion & Irritation

Existing Pictograms in Consumer Product Labels

Some Pictograms of Physical Hazard on Consumer Products--- in TDG format Pictogram on label of Napthalene = Flammable Solid Pictogram on label of Methanol = Flammable Liquid

Gap between Thai and GHS in consumer product labelling In Thai system, No labelling Pictogram is need for : - Health hazards other than Acute Hazard and Corrosiveness - Some Physical hazards - Environmental hazard

Labelling Pictograms in GHS Health hazards : Physical hazards: Environmental hazard:

Benefit of GHS for Government Current Measure-based approach Hazard / Risk-based approach (Acute / Chronic adverse effect) GHS: Systematic way of classification and labelling of chemical hazard in consumer product In line with International Standard Partnership development with Business and Civil Societies for effective Chemical Safety Scheme in sustainable manner

Benefit of GHS for Business Good Image of products: Social responsible care Avoid confusion in product labelling Obtaining long-term business benefit Facilitating international trade

Benefit of GHS for Civil Society & Public Obtaining clear, understandable message of chemical hazard on consumer product label Creating civil society having high concern and correct understanding about chemical hazard Safe use of chemicals and related products Reduction of chemical risk over public health & the environment

Application of GHS in Consumer Product Sector Risk Assessment Classification Risk Communication Product Labelling Risk Management Risk Reduction

Existing Legislation and Management Scheme - Complicated control by various ministries - Inefficient enforcement and implementation Overlapping in authorities of related laws Loopholes of uncontrolled chemicals and products, e.g. fireworks, new chemicals, certain consumer products Barrier to GHS practice in Consumer Product sector Government:

Barrier to GHS in Consumer Product sector (continued) Capacity of business, esp. SME Technical difficulty of classification, esp. Mixtures/ Products Business: Diverse levels of awareness and knowledge Complex nature of public consumption and interest Conventional approach Vs. Advertisement Civil Society and Public:

Achievements Participation in GHS movement Awareness raising : - Government - Business - the Public Relevant Government Agencies/ Industry Associations / NGOs (labour, civil society) / Academia

Achievements (continued) Situation and Gap Analysis Comprehensibility Test Identifying GHS as priority & Intregating into 3 rd National Master Plan for Chemical Management (2007-2011) Submit for Cabinet Approval Translation into action through yearly work plan

GHS initiative is incorporated into 3 rd National Master Plan for Chemical Management (2007-2011) For Sustainability of GHS implementation and benefit Strategy II: Reduction of Chemical Risk Strategy III: Public Participation and Empowerment

Future Work Setting Priority List of Consumer Products for GHS implementation Capacity building for Regulators, Health care & Poison center & ER personnel Business technical aspect of classification and labelling, esp. mixture, formulation Public: Public Campaign for GHS, through mass media Educational Curricula / Activities Secondary Schools / Little FDA Vocational Colleges Universities

Future Work (continued) Motivation program for SMEs Supporting NGOs networking and advocacy GHS related action plan under 3 rd National Master Plan on Chemical Management (2007-2011) Consumer products of high priority concerns Supporting Regional Cooperation Follow-up and monitoring Analysis for further action

Situation and Gap Analysis for GHS Capacity Building in Consumer Product Sector Chemical Safety Section Food and Drug Administration Thailand National.

Documents

consumer product sector

consumer product trade

cpa consumer protection

ifcs slide

ministry of commerce

drug act

cosmetic act

narcotics act