The Globally Harmonized System of Classification and Labelling of Chemicals (GHS)

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Differences between TDG and GHS

• Canadian TDG Regulations are based on the United Nations Recommendations on the Transport of Dangerous Goods Model Regulations (UN Recommendations)
• Only acute health and physical hazards are addressed
• Symbols used are the same as those used in the GHS.
• UN Sub-Committee of Experts on the Transport of Dangerous Goods acted as a focal point for physical hazards during the development of the GHS.
• Implementation of the GHS should have minimal impact on the Canadian TDG Regulations.
• Most significant impact on current Canadian TDG Regulations will be on acute toxicity
• Alignment of existing Packing Group criteria with GHS Category breakpoints.
• Acute Toxicity: Oral
  • More solid formulations and a fewer liquid formulations will be regulated.
• Acute Toxicity: Skin
  • More formulations will be in Packing Group I.
• Acute Toxicity: Inhalation (vapour)
  • Extremely toxic substances would be in Packing Group (PG) I.
  • The remainder of substances currently in PG I would be in PG II. Existing PG II and III substances would be in PG III.
• Acute Toxicity: Inhalation (gas)
  • All toxic gases would be treated as if they were in GHS Category 1.
• TDG Sub-Committee will be considering the harmonization of acute toxicity criteria with those of the GHS during the current biennium.
• Expected changes to the Canadian TDG Regulations could occur as early as 2005.
• GHS criteria for environmentally hazardous substances introduced into the 13th revised edition of the UN Recommendations
• Expected to be implemented by 2005.
• These criteria should replace requirements in the current Canadian TDG Regulations for Marine Pollutants

Future Considerations

TDG Sub-Committee could consider whether certain hazards (e.g. Target Organ Systemic Toxicity) that are not taken into account in TDG regulations, would also have to be regulated.

Topics of interest currently before the UN GHS Sub-Committee

• Water-Activated Toxicity Hazard,
• Substances and Mixtures which cause Respiratory Tract Irritation and Corrosion, and
• Narcotic Effect Hazard.

These would be considered for the Canadian TDG Regulations after approval by the TDG Sub-Committee.

TDG Implementation Schedule

Canada will follow the UN Recommendations for Implementation

• Dec 2004 - Approval of 14th UN Recommendations Will include elements of GHS
• July 2005 - 14th UN Recommendations will become compulsory
• 2006 - 14th UN Regulations should be incorporated in TDG Regulations; Consultation and Gazette I
• 2008 - Full implementation of GHS (within UN TDG Framework)