3 UNEP ChemControlGuide

UNEP GUIDANCE
Risk Reduction Tools for

Chemicals Control
1
UNEP GUIDANCE
Risk Reduction Tools for
Chemicals Control
UN Environment Guidance on Risk Reduction Tools for Chemicals Control

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EXECUTIVE SUMMARY
Tens of thousands of chemicals exist in commercial Key concepts of risk reduction in a chemicals
products and processes, many of which have control context include:
hazardous properties. Risk reduction measures aim to
protect human health and the environment from the • A preventive approach. This concept is
adverse effects of these hazardous chemicals. embodied in the “Precautionary Principle” (from
the 1992 Rio Declaration), which states that
The establishment and implementation of legal where there are threats of serious or irreversible
frameworks for industrial and consumer chemicals damage, lack of full scientific certainty shall not
is an aspect of sound chemicals management still be used as a reason for postponing cost-effective
lacking in many countries, especially in developing measures to prevent environmental degradation.
countries. In most countries, pesticides are covered in A preventive approach reduces costs and is the
separate legislation and are often subject to stringent most effective approach for protecting health and
requirements. The term “chemicals control” is used the environment.
to refer to the regulation of industrial and consumer
chemicals before or at the point when they are placed • Implementing GHS. Implementing the Globally
on the market in a country. In parallel to establishing Harmonized System of Classification and Labelling
the legal requirements, the related institutional of Chemicals (GHS) in national legislation is the
capacity needs to be established or improved. core element of integrating risk reduction into
daily operations with chemicals. These resources
Adopting chemicals control legislation and provide essential information on safe handling
establishing the related institutional capacity and risk reduction in the supply chain.
to manage chemicals at an early stage is a cost-
effective way of strengthening national chemicals • Clear roles and responsibilities. Legislation
management systems. The United Nations should clearly define roles and responsibilities
Environment Programme’s (UNEP) 2015 publication, for manufacturers and importers. These
Guidance on the Development of Legal and Institutional include gathering information on chemical
Infrastructures and Measures for Recovering Costs properties, hazards and risks; classifying and
of National Administration (LIRA Guidance), offers labelling chemicals in accordance with the
suggestions on ways to establish chemicals control GHS; disseminating information on hazardous
legislation and institutional capacity. properties of chemicals, including providing
Safety Data Sheets (SDSs) to professional
This guidance document aims to support technical users; complying with bans and restrictions;
government officials who are working to build and adopting safer substitutes for hazardous
government capacity for reducing the potential risk to chemicals when possible. Downstream users of
human health and the environment from chemicals. It chemicals should comply with risk management
supplements the suggestions in the LIRA Guidance, measures, choose the safest chemical, and handle
by further describing risk reduction tools for reducing the chemicals they use or dispose of in a safe way.
or eliminating these risks. It provides information Government should ensure that all actors in the
on the prioritization of chemicals for cost-efficient supply chain apply relevant risk management
risk reduction; the range of risk reduction tools for measures.
chemicals; and options for choosing appropriate risk
reduction tools.

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Prioritizing chemicals for risk reduction of Chemicals (REACH); California’s Proposition 65

List; the Chemical Hazard and Alternatives Toolbox
Chemicals subject to risk reduction measures to be (ChemHAT); Decision Guidance Documents prepared
introduced by authorities can be prioritized based for the chemicals listed in Annex III to the Rotterdam
on decisions made in other jurisdictions; the type of Convention; and Pharos, including the GreenScreen
hazard; the degree of exposure; or a risk evaluation List Translator. For web links and descriptions of these
process. resources, see the full guidance document.
All chemicals that have already been prioritized under Classification and labelling, bans, restrictions and
multilateral environmental agreements (MEAs) should authorization systems
be prioritized at the national level. Further prioritization
of chemicals for possible risk reduction measures can Implementing the GHS as a legal requirement for all
be based on additional existing lists of chemicals that chemicals is a core element of risk reduction. Chemical
pose severe and well documented risks. manufacturers and importers should be responsible
for gathering and communicating this information. Use
If prioritization decisions have already been made of the GHS ensures international harmonization of the
in another jurisdiction, it is cost efficient to use the classification and labelling of all types of chemicals.
information generated through those decision-making
processes. Many countries and organizations publish Official/harmonized classifications from other
preparatory work and lists of candidates for regulation countries or regions based on the GHS criteria should
on their websites. be used. These are peer-reviewed by expert groups
and therefore considered reliable.
Chemicals can be categorized and prioritized based
on their known or expected hazards. Hazard-based Bans and restrictions regulate access to chemicals
decision-making focuses on addressing the inherent that are too hazardous to remain freely and openly
hazards of chemicals through substitution or other available, or that a country does not have the national
approaches, rather than calculating an acceptable capacity to manage effectively. They can also help to
level of risk. promote the development and introduction of safer
alternatives that are technically and financially viable.
Chemicals can also be prioritized based on exposure. Bans and restrictions can exist at a variety of levels,
This includes identifying use patterns that may create including total bans, bans with specific exemptions, or
widespread exposure across a population, or intense bans or restrictions for a specific use of a chemical.
exposure for a subset of the population.
In an authorization or pre-market approval system, a
Risk evaluations that have been generated by other manufacturer or importer must have authorization,
countries or regions should be used whenever approval or a licence before placing a chemical on
possible. If another country has already assessed the market. While many countries have laws of this
or acted upon a chemical, information is likely to be kind for pesticides and pharmaceuticals, they are less
available on risk reduction measures that have been common for industrial and consumer chemicals as
adopted, as well as background information for these types of system tend to be resource-demanding
these measures. Countries should allow for the use both for the authorities and industry.
of data and evaluations from other jurisdictions, as
long as they comply with internationally recognized Additional approaches: Economic and informative
standards, such as guidelines from the Organization instruments
for Economic Co-operation and Development (OECD).
Economic instruments include taxes and fees that are
A variety of risk reduction resources are available for designed to shift markets towards safer chemicals.
government and industry employees wishing to find Economic instruments are not a good choice if the
information about chemicals. These include databases chemical poses an unacceptable risk to health or the
on chemical properties and information about safer environment. They can also be resource-demanding
alternatives. Many of these resources are publicly to administer. However, in some cases, well-designed
available; others are available for a subscription fee. economic instruments can be used to complement
These include: OECD Regulations and Restrictions; other instruments.
the eChemPortal; substances restricted under
Registration, Evaluation, Authorization and restriction

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An informational tool aims to achieve a voluntary

reduction in the use of a specific substance or group
of substances. Information can be used to change
behaviour and change production. Informational tools
can be used as a stand-alone measure if the risk from a
specific substance or group of substances is relatively
low.
Public procurement requirements can be useful for

steering consumption towards reduced use of a
substance or product when a specific problem has
been identified. They can be used to reduce risks in
hospitals, schools and other public places, and to
support markets for safer alternatives. Ecolabelling
can drive markets towards safer chemicals by
empowering consumers to make informed choices, if
chemical hazard is included as a core criterion in the
ecolabelling system.
Awareness of chemical hazards facilitates the

introduction of other instruments. Well-informed
consumers can put pressure on politicians to issue
legislation aimed at reducing the use of hazardous
chemicals. Government authorities play a key role
in providing accurate and unbiased information to
the general public and public organizations on the
impacts of chemicals in the local environment.
The “Substitution Principle” refers to the obligation

or option to substitute chemicals for less hazardous
ones or apply an alternative technique, when possible.
Some regulatory approaches create a responsibility
for industry to assess potential options and choose
safer alternatives.
Deciding on risk reduction tools
National legislation must be clear about the level at

which a decision to reduce the risks from chemicals
should be taken. All decision-making begins with
collecting information about the problem, identifying
risk reduction goals and choosing a risk reduction
option. Industry, downstream users, other authorities
and NGOs should be invited to contribute to the
process.
Factors to take into account in choosing the most

appropriate risk reduction instrument include
efficiency, sustainability, cost and administrative
burden. In choosing a risk reduction tool, countries
may consider which actors are using the chemical, as
well as the type of chemical hazard.

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PREFACE
This document is part of a series of guidance documents that aim to complement the information provided in
UNEP’s 2015 publication, Guidance on the Development of Legal and Institutional Infrastructures and Measures for
Recovering Costs of National Administration (LIRA Guidance). More specifically, it provides further information on
risk reduction tools that are part of chemicals control legislation.
The approach suggested in the LIRA Guidance is referred to in this series as “chemicals control” and primarily
addresses regulation of industrial and consumer chemicals before or at the point when they are placed on the
market.
The series is composed of four documents with one document on the benefits of chemicals control and three
guidance documents:
• Benefits of Chemicals Control
• National Authority for Chemicals Control: Structure and Funding
• Risk Reduction Tools for Chemicals Control
• Enforcement of Chemicals Control Legislation
By supporting the development of chemicals management frameworks at the national level, the LIRA Guidance
and these complementary documents contribute to the priorities developed in the context of the Strategic
Approach to International Chemicals Management (SAICM) and the Overall Orientation and Guidance (OOG)
document, as well as the implementation of the Basel, Rotterdam, Stockholm and Minamata Conventions, and
the Sustainable Development Goals under Agenda 2030.
This publication was developed by UNEP in the context of the Inter-Organization Programme for the Sound
Management of Chemicals (IOMC).
The editing and layout were coordinated by UN Publications.
This document has been produced with financial assistance from Sweden through the Swedish International
Development Cooperation Agency (Sida), which was arranged by the Swedish Chemicals Agency, Keml. The
views herein do not necessarily reflect the official opinions of Sida or Keml.

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CONTENTS
Executive Summary.................................................................................................................................................................................. 2
Preface.............................................................................................................................................................................................................5
Acknowledgements................................................................................................................................................................................. 7
1. Introduction..........................................................................................................................................................................................10
1.1 Background..........................................................................................................................................................................11
1.2 Scope and aim.....................................................................................................................................................................11
2. Key concepts of risk reduction.....................................................................................................................................................12
3. Prioritization of chemicals for risk reduction.........................................................................................................................16

3.1 Implementing Multilateral Environmental Agreements......................................................................................16
3.2 Further prioritization..........................................................................................................................................................16
3.2.1 Actions of other jurisdictions......................................................................................................................................17
3.2.2 Hazard-based prioritization.........................................................................................................................................19
3.2.3 Exposure and risk-based prioritization...................................................................................................................19
3.2.4 Data and information supporting prioritization...................................................................................................20
3.2.5 Resources for information on chemicals................................................................................................................21
4. Core risk reduction tools.................................................................................................................................................................24

4.1 Classification and labelling............................................................................................................................................24
4.2 Bans and restrictions.........................................................................................................................................................28
4.3 Authorization or pre-market approval systems.......................................................................................................29
5. Additional risk reduction tools.....................................................................................................................................................32

5.1 Economic instruments......................................................................................................................................................32
5.2 Informative instruments...................................................................................................................................................33
5.2.1 Public procurement.......................................................................................................................................................33
5.2.2 Ecolabelling......................................................................................................................................................................33
5.2.3 Awareness-raising...........................................................................................................................................................34
5.2.4 Substitution and safer alternatives...........................................................................................................................35
5.2.5 Dialogue with industry..................................................................................................................................................36
6. Choosing risk reduction tools.......................................................................................................................................................38
References.................................................................................................................................................................................................41
Annex 1: Additional risk management guidance documents...........................................................................................43
Annex 2: Chemical information resources..................................................................................................................................44
Endnotes......................................................................................................................................................................................................45

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ACKNOWLEDGEMENTS
The development of this UNEP guidance document was coordinated by Maria Delvin and Pierre Quiblier, UNEP
Chemicals and Health Branch. Rachel Massey and Lindsey Pollard, Massachusetts Toxics Use Reduction Institute
(TURI), and Susan Kaplan (consultant) were contributing writers.
The development of this guidance benefited from input from an expert group that included participants from
governments, intergovernmental organizations, private sector organizations, non-governmental organizations
and academia.
Participants of this expert group:
Governments
Alison Kennedy, Manager, Department of Environment and Climate Change, Canada; Bojana Djordjevic, Head
of Unit, Ministry of Environmental Protection, Serbia; Cayssa Marcondes, Ministry of Environment, Brazil; Elize
Lourens, Deputy Director, Health and Hygiene, Department of Labour, South Africa; Fredrick Muyano, Principle
Inspector, Environmental Management Agency, Zambia; Helga Schrott, Senior Legal Adviser, Federal Ministry
of Agriculture, Forestry, Environment and Water Management, Austria; Ingela Andersson, Head of International
Unit, Swedish Chemicals Agency, Sweden; Juan Simonelli, National Ministry of Environment and Sustainable
Development, Argentina; Juergen Helbig, Principal Policy Officer, European Commission; Leticia Carvalho,
Chief of Environmental Quality Branch, Department of Environmental Quality in Industry Ministry of Environment
Brazil; Mangaka Mahlako, Deputy Director, Mfanuwenkosi Mathebula, Assistant Director, Hazardous Chemicals
Management, Department of Environmental Affairs, South Africa; Marthe D. Rahelimalala, Chief of Environmental
Pollution, Ministry of Environment, Ecology and Forest, Madagascar; Nguyen Thi Ha, Head of Division, Viet Nam
Chemicals Agency, Vietnam; Phengkhamla Phonvisai, Deputy Director General, Ministry of Natural Resources
and Environment, Lao PDR; Simone Irsfeld, Federal Ministry for the Environment, Nature Conservation, Building
and Nuclear Safety International Chemical Safety, Sustainable Chemistry, Germany; Szymon Domagalski, Senior
Specialist, Department for Dangerous Substances and Mixtures, Poland.
Intergovernmental organizations
Abdouraman Bary, Regional Subprogramme Coordinator, UN Environment (UNEP); Baogen Gu, Senior
Agricultural Officer, Food and Agriculture Organization (FAO); Carmen Bullon, Legal Officer, FAO, Haddy Guisse,
Associate Legal Officer, UNEP Hilda Van Der Veen, Chemicals and Waste Management Expert, United Nations
Development Programme (UNDP); Jacob Duer, Chief, Chemicals and Health Branch, UNEP; Jordi Pon, Regional
Chemicals and Waste Coordinator, UNEP; Jose de Mesa Programme Officer, UNEP; Juliette Voinov Kohler, Legal
and Policy Adviser, Head of the Legal and Governance Unit, Secretariat of the Basel, Rotterdam, and Stockholm
Conventions (BRS), UNEP; Kakuko Nagatani-Yoshida, Regional Subprogramme Coordinator for Chemicals and
Waste, UNEP; Kei Ohno Woodall, Programme Officer, BRS, UNEP; Kersten Gutschmidt, Technical Officer, Public
Health, Environmental and Social Determination of Health, World Health Organization (WHO); Lena Perenius,
consultant, Strategic Approach to International Chemicals Management (SAICM); Magaran Monzon Bagayoko,
Regional Adviser, WHO; Mijke Hertoghs, Regional Coordinator, UNEP; Nalini Sharma, Programme Officer,
Secretariat of the Special Programme, UNEP; Sylvie Poret, Principal Administrator, Organization for Economic
Co-operation and Development (OECD); Yvonne Ewang, Legal Officer, BRS,UNEP.

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Private sector
Alan P. Kaufman, Senior Vice President, Technical Affairs, The Toy Association, Inc.; Beth Jensen, Senior Director
of Sustainable Business Innovation, Outdoor Industry Association; Catherine Lequime, ICCA representative,
Véronique Garny, Director, Product Stewardship, European Chemical Industry Council.
Non-governmental organizations, academia and other advisers
Baskut Tuncak, UN Special Rapporteur, OHCHR-UNOG; Beverley Thorpe, Clean Production Action; David
Azoulay, Environmental Health Program Director, Center for International Environmental Law, (CIEL); Goh
Choo Ta, Associate Professor, National University of Malaysia; Hanna-Andrea Rother, Head Associate Professor,
University of Cape Town; Ken Geiser, Professor Emeritus, University of Massachusetts Lowell; Linn Persson, Head
of Unit, Stockholm Environment Institute; Mengjiao Wang, Research Scientist, Greenpeace International; Olga
Speranskaya, Director, Chemical Safety Program, IPEN; Sabaa A. Khan, Senior Researcher, University Of Eastern
Finland; Taelo Letsela, Managing Director, Global Environmental Solutions.
Valuable input on a test version was provided by Xiomara Jiménez Soto, Ministry of Health of Costa Rica; Maria del
Mar Solano, Ministry of Environment and Energy, Costa Rica; and staff of the Technical Coordination Secretariat
for the Sound Management of Chemicals in Costa Rica.

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10
INTRODUCTION
Chemicals are integral to modern life, and when there is the greatest opportunity
their sound management is a key aspect for prevention before adverse effects on
of sustainable development. Adoption human health and the environment occur.
and implementation of chemicals control It complements and supports other aspects
legislation is an aspect of sound chemicals of risk management activities, such as
management that many countries often worker protection, prevention of accidents, CHAPTER
1
lack. Risk reduction measures aim to protect transportation regulation and waste
human health and the environment from the disposal. For further information about
adverse effects of hazardous chemicals. the benefits of chemicals control, see the
document, Benefits of Chemicals Control, in
In this document, the term “chemicals this series.
control” is used to refer to the regulation of
industrial and consumer chemicals before As reported by the United Nations
or at the point when they are placed on Environment Programme (UNEP) in the
the market. This includes chemicals used Costs of Inaction report from 2013, the costs
in industrial processes; chemicals used in from the mismanagement of chemicals can
everyday life, such as cleaning products and be substantial.i Although many countries
paints; and chemicals in articles, such as have laws to regulate the release of
clothing, furniture and electrical appliances chemicals into the environment, to protect
(not including pesticides, pharmaceuticals, workers, and to authorize certain chemicals
cosmetic products or food additives). before marketing and use (pesticides,
Placing on the market means supplying pharmaceuticals and/or food additives),
or making available chemicals, whether in there are still many countries that lack
return for payment or free of charge. This regulation to control the manufacture and
includes imports. import of industrial and consumer chemicals
as they are placed on the market. Early action
Chemicals control can be addressed in on risk reduction is often cost efficient.
free-standing law or it can be built into a
broader chemicals management law or A chemical that has several uses may
other framework legislation related to the be subject to several different laws. In
protection of health and the environment. many countries, pesticides are covered
in separate legislation and normally have
Chemicals control focuses on defining more stringent requirements than chemicals
responsibilities for industry in implementing control for industrial or consumer chemicals.
knowledge-based measures as early as Guidance on pesticides is available from the
possible in the life cycle of chemicals, Food and Agriculture Organization of the

11
United Nations (FAO).ii Although guidance 1.2 Scope and aim

on pesticides, pharmaceuticals, cosmetic
products and food additives is not directly This document complements the
provided in this document, there is some information provided in the LIRA Guidance.
overlap in elements of risk reduction for Specifically, it provides additional
all chemical categories – for example, in information on different risk reduction tools
basing labelling provisions on the Globally – legally enforceable as well as voluntary – to
Harmonized System of Classification and reduce or eliminate the risk to human health
Labelling of Chemicals (GHS). and the environment from chemicals. This
document, as well as the LIRA Guidance,
1.1 Background focuses on the risk reduction instruments
in chemicals control legislation. It aims
At the UN World Summit on Sustainable to complement the available resources
Development in 2002, governments identified in the Internet-based OECD
and organizations agreed on “aiming to Toolbox for Implementing Chemicals Safety
achieve, by 2020, that chemicals are used (IOMC Toolbox).vii
and produced in ways that lead to the
minimization of significant adverse effects The aims of this document include:
on human health and the environment”
(often called the 2020 goal). The Strategic • Provide suggestions on prioritization of
Approach to International Chemicals chemicals for cost-efficient risk reduction.
Management (SAICM) is a multi-stakeholder • Provide guidance on the main risk
and multi-sectoral policy framework reduction tools.
adopted in 2006 with the aim of achieving • Assist countries in choosing appropriate
this goal. SAICM recognizes a set of 11 basic risk reduction tools.
elements as critical for achieving the sound
management of chemicals, as outlined in This document is intended for countries that
the Overall Orientation and Guidance (OOG) are currently working to establish, amend,
document from 2015. These basic elements update or implement chemicals control
include legal frameworks; enforcement legislation for industrial and consumer
and compliance mechanisms; strong chemicals, and the associated institutional
institutional frameworks and coordination capacity. Specifically, it is directed at
mechanisms; and defined responsibilities technical government officials who are
for industry across the chemical life cycle.iii actively working to build government
capacity for reducing the potential risk to
In 2015, 17 Sustainable Development Goals human health and the environment from
and 169 associated targets were adopted by chemicals.
the SAICM Heads of State and Government
and High Representatives.iv v In principle, This document does not provide information
Target 12.4 reflects the 2020 goal. about how to perform a risk assessment.
Guidance documents addressing risk
To assist countries in the process of assessment are available on the websites
establishing chemicals control legislation of international organizations such as the
and related institutional frameworks, UNEP OECD, World Health Organization, FAO and
published the LIRA Guidance in 2015.vi It UNEP; a list of risk management guidance
provides options for organizing the legal documents is included in Annex 1.
and institutional infrastructures governing
the placement of chemicals on the market.
It also provides suggestions for ensuring
sustainable financing, including cost
recovery measures.

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KEY CONCEPTS OF RISK

REDUCTION
The key concepts of risk reduction include the environment. It complements and
a preventive approach. Core elements in supports other aspects of downstream risk
chemicals control include implementing management activities, such as worker
the GHS; developing and providing Safety protection, prevention of accidents,
Data Sheets (SDS); and identifying a clear transportation regulation and waste
division of responsibilities between industry disposal. While measures to address the CHAPTER
2
and government, with the main obligations widespread use of chemicals already on the
on manufacturers and importers. market are complicated and costly, early
action can offer greater efficiencies. The EU’s
Preventive approach. A preventive approach Registration, Evaluation and Authorization
is a key concept of chemicals control, as of Chemicals (REACH) regulation explicitly
it reduces costs and is the most effective cites the Precautionary Principle as a basis
approach for protecting health and for decision-making.viii
Box 1. Principles of proactive health and environmental protection
Precautionary Principle is an anticipatory approach that aims to protect human health and the environment
against the potential risks from human action. It marks a shift from post-damage to pre-damage control of risks.ix
An early definition of the Precautionary Principle is found in the Rio Declaration, adopted in 1992. It reads,
“[w]here there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used
as a reason for postponing cost-effective measures to prevent environmental degradation”.x Since then, the
principle has been expanded to encompass the protection of human health.
The principle has four central components: taking preventive action in the face of uncertainty; shifting the
burden of proof to the proponents of an activity; exploring a wide range of alternatives to potentially harmful
actions; and increasing public participation in decision-making.xi The principle is referred to in Article 1 of the
Stockholm Convention.
Polluter pays principle. The polluter pays principle specifies that the costs of addressing pollution from a
wide range of sources should be the responsibility of the industry creating the pollution. Principle 16 of the Rio
Declaration states that “[n]ational authorities should endeavour to promote the internalisation of environmental
costs and the use of economic instruments, taking into account the approach that the polluter should, in
principle, bear the cost of pollution with due regard to public interest and without distorting international trade
and investment”.xii
Extended producer responsibility “is a policy approach under which producers are given a significant
responsibility – financial and/or physical – for the treatment or disposal of post-consumer products. Assigning
such responsibility could, in principle, provide incentives to prevent wastes at the source, promote product
design for the environment and support the achievement of public recycling and materials management
goals”, according to the OECD.xiii A common example is a takeback programme for electronics, in which
electronics manufacturers are assigned responsibility for taking back used electronics and disposing of them
in an environmentally sound manner.

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Implementing the GHS in national legislation • Make informed choices about chemicals
should be a priority, as it creates a system for in order to avoid hazards and risks.
chemical manufacturers and importers to Substitute chemicals for less hazardous
provide information about chemical hazards ones or apply an alternative technique,
and precautions. The GHS is a cornerstone of when possible (the Substitution Principle
knowledge-based risk reduction measures – described in greater detail below).
as it gives information about the properties
of chemicals and how to handle them safely. • Organize and assure the safe use of
This is further addressed in Section 4.1. chemicals and their storage, transport
and appropriate disposal.
Clear division of responsibilities between
industry and government. Chemicals control • For downstream/professional users of
legislation should make it clear that industry chemicals, comply with risk management
is responsible for its products. Given the measures, choose the safest chemical
large number of chemicals that exist in and handle the chemicals they use or
commerce, it is essential that the legislation dispose of in a safe way.
includes general provisions placing
responsibility on industry to ensure the The European Chemicals Agency provides
availability of health and safety information information for industry on assessing hazard
throughout the supply chain. Information and risk. It states that companies need to
sharing is crucial to ensure that downstream consider the following regulatory, scientific
users can safely handle chemicals and that and technical requirements:
consumers can make informed decisions.
Chemical manufacturers are best placed to • Gather information on uses and current
have or generate the necessary knowledge conditions of use from the supply chain.
about the hazards of the chemicals they Contact your industry association for best
produce. Importers should be responsible for practice in your sector.
obtaining the necessary safety information
from manufacturers. • Collect hazard data as requested by
REACH information requirements
Basic requirements for industry should triggered by the tonnage and uses of the
include: substance.
• Gather knowledge and, if necessary, • Assess the coverage and quality of the
generate new knowledge on chemical hazard information about the substance
properties, hazards and risks. available within the SIEF [Substance
Information Exchange Forum].
• Classify and label chemicals in
accordance with the GHS. • Define a strategy to fill in any resulting
data gaps (e.g. carrying out new studies,
• Disseminate information on the hazardous justifying missing information using
properties of chemicals and on safe scientifically solid read-across, data
handling procedures, including providing waivers, etc.).
SDSs to professional users.
• Agree classification and labelling within
• Supply additional information about the the SIEF (based on the hazard data).
products, when necessary, in order to
enable and facilitate the best choice of • Record all hazard data and classification
products for downstream users and to in the registration dossier.
ensure the safe handling of the products.
• If manufacturing or importing more than
• Ensure that no banned substances are 10 tons per year, carry out the chemical
produced, imported or placed on the safety assessment (CSA) and record it in a
market. chemical safety report (CSR).xiv

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The International Council of Chemical

Associations (ICCA) has developed a
“Responsible Care” commitment as part
of its contribution to the SAICM. Through
Responsible Care, global chemical
manufacturers commit to pursuing the
principles of safe chemicals management,
and to supporting companies to contribute
to achieving the 2020 goal.
The role of government is to ensure that all

actors in the supply chain apply relevant
risk management activities within their
field of responsibility. Government does
this by issuing relevant legislation and
recommendations; enforcing existing laws;
and providing information and guidance.
For chemicals where risks to human health
or the environment may occur, governments
should have the authority to implement risk-
reduction measures.
Governments should therefore:
• Adopt framework legislation clarifying the

roles and responsibilities of industry, as
well as those of the national administration.
• Adopt legislation implementing the GHS

as a requirement.
• Introduce bans and restrictions for

substances when needed.
• Supervise and enforce compliance with

existing national measures, as well as
any international obligations regarding
chemicals management and control.

15

16
PRIORITIZATION OF
CHEMICALS FOR RISK
REDUCTION
The legislation should require industry to Protocol on Substances that Deplete the
take responsibility for reducing the risks Ozone Layer, parties have a responsibility
from the chemicals they produce, import to ban, phase out or restrict chemicals
and use. Implementation of the GHS requires that are recognized as high priority at
industry to classify and label their hazardous the international level. Adopting such
chemicals appropriately before placing requirements domestically is best done via CHAPTER
3
them on the market. Product and transport legislation that implements the provisions
labelling and SDSs provide information to in the MEA, including introducing bans
users about the hazards and how to handle or restrictions on the production and use
the chemicals in a safe way how to protect of a specific chemical. It is important to
oneself and the environment. For many remember that the legislation will probably
chemicals, provisions for communicating need to be updated as further progress or
information in the supply chain provide new decisions are made.
sufficient risk reduction. However, for
certain hazardous chemicals – for which 3.2 Further prioritization
disseminating information is not sufficient
for handling the risks to human health or Chemicals can be prioritized based on
the environment – the authorities should prioritization or regulation decisions
introduce more stringent risk reduction that have already been made in other
measures. There are several options for jurisdictions; the degree of hazard; levels
prioritizing such chemicals or groups of of exposure; or a risk evaluation process.
chemicals. Successful prioritization approaches often
employ more than one of these options.
3.1 Implementing Multilateral
Environmental Agreements As previously noted, legislation should
require industry to take responsibility for the
All chemicals that have already been chemicals they produce, import and use in
prioritized under multilateral environmental order to reduce the risks to human health
agreements (MEAs) should be prioritized at or the environment. However, in cases
the national level. Countries are responsible where such requirements in the legislation
for fulfilling their obligations under MEAs – including disseminating information
related to chemicals. For example, under in accordance with the GHS (see further
the Stockholm Convention on Persistent discussion on Page 17) and taking the
Organic Pollutants (POPs), the Minamata necessary precautions – are inadequate for
Convention on Mercury, or the Montreal managing risks from chemicals, authorities

17
should introduce more stringent measures and make use of information such as the
to address these substances or groups of list of Substances of Very High Concern
substances. (SVHCs) defined under REACH. Canada
has categorized all of the chemicals on the
While these substances might be identified Canadian market; see Canada’s Domestic
through cases of pollution and poisoning, Substances List.xv
it is advisable to try to identify potentially
problematic chemicals before any harm has Many countries publish preparatory work
occurred. and lists of candidates for regulation on
their websites. This information can be
Adopting a national chemicals policy valuable for other countries. It often includes
identifying the types of substances that useful background information on why a
should be prioritized for action could substance is a candidate for risk reduction.
support the work of government, as well as One example of such information is the
that of industry. Such policy contributes to REACH Candidate List of substances that
greater certainty for industry and provides could be subject to authorization within the
guidance on what kinds of substances EU.xvi On the European Chemicals Agency
should be avoided in order to reduce risks. (ECHA) website, information on chemicals
under consideration for harmonized
If there is a particularly high likelihood classification and labelling, and bans is
of exposure due to national conditions, accessible to countries outside the EU. The
this should be taken into account in the US Environmental Protection Agency (EPA)
prioritization process. Preferably, these also publishes information on substances
substances should be identified before any of concern. For example, US EPA’s 2014
harm (cases of poisoning or pollution) has update of the Toxic Substance Control Act
occurred. A systematic approach would (TSCA) Workplan for Chemical Assessments
build on the prioritization of substances that, is a valuable resource, providing an overview
due to their known or assumed hazards and/ of dozens of chemicals considered to be
or use patterns, are likely to give rise to risks priorities for assessment and action.xvii
that need to be eliminated.
The information available under the
3.2.1 Actions of other jurisdictions Rotterdam Convention can help a country
make a decision as to whether they wish
Actions taken and priorities set in other to take further action to restrict or ban a
countries can be an important and cost- chemical. For all parties to the Rotterdam
saving resource when making prioritization Convention, export of the listed chemicals
decisions. should be accompanied by information
about the chemical, including information
If prioritization decisions have already for classification and labelling. Such
been made in another jurisdiction, it is notifications give the importing country
cost-efficient to use the information already valuable information about the decisions
developed through that particular decision- of other countries to ban and restrict the
making process. There is no need to re- chemical, and give them an opportunity
assess hazard if a chemical has already to consider the need to introduce similar
been assessed. The inherent properties of measures.
chemicals are always the same, regardless
of the place, type of production and use. The Rotterdam Convention requires each
party to notify the Secretariat when it has
For example, within the US, a state will often adopted a final regulatory action to ban or
use the work already completed in other severely restrict a chemical;xviii this provides
states, to decide on which chemicals to information about chemicals that have
prioritize. This is more efficient than each been identified as priorities by individual
state creating a new list from first principles. countries. The EU has a Prior Informed
Internationally, countries can draw upon Consent (PIC) procedure governing exports
prioritization approaches in other countries,

18
from the EU of any substance that is banned manufacturers and importers to make
or severely restricted within the EU.xix This informed decisions about which chemicals
lengthy list, which has more than 180 to invest in, use and import, as well
chemicals, can also be a good resource for as decisions about possible chemical
any government interested in identifying substitutions.
high-priority chemicals for regulatory action.
For chemicals whose inherent properties
can cause severe or irreversible effects,
Box 2. The Rotterdam Convention focuses on hazard information should be sufficient
information exchange and currently includes 50 for risk reduction decisions. This would
chemicals that are subject to the PIC procedure.
These chemicals have been identified by the
apply, for example, to chemicals that are
international community as presenting a severe persistent, bioaccumulative and toxic (PBT)
hazard to human health or the environment, and or very persistent and very bioaccumulative
are already banned or restricted in many parts of the (vPvB); carcinogenic, mutagenic or toxic to
world. For these substances, a decision guidance
document is available, which contains valuable
reproduction (CMR), meeting the criteria for
background information on the substances and the GHS CMR category 1A or 1B (especially
their properties.xx those without a non-threshold for effects); or
associated with other severe and irreversible
health effects.
vPvB substances accumulate in the

Box 3. Additional examples of resources for lists environment and in organisms over time,
of restricted substances
even if emissions are small. In many cases,
OECD Regulations and Restrictions: vPvB chemicals have been found to be toxic
http://www.oecdsaatoolbox.org/Home/Regulations after they have already accumulated in the
environment and human tissue. Therefore,
ECHA, Substances Restricted under REACH:
prioritization would be an appropriate
https://echa.europa.eu/substances-restricted-
under-reach measure. Similarly, substances that are CMR
may be prioritized based only on hazard, as
State of California, US: The Proposition 65 List: these have very severe effects, and it cannot
https://oehha.ca.gov/proposition-65/proposition-
be assumed that all potential users will
65-list
handle these substances safely.
Under the European Union’s REACH

regulation, chemicals that are CMR category
1A or 1B under the GHS; PBTs; vPvBs; and
3.2.2 Hazard-based prioritization other substances of equivalent concern are
defined as SVHCs and are prioritized for
Hazard-based decision-making focuses regulation.
on addressing inherent hazards through
substitution or other approaches, rather
than calculating an acceptable level of risk. Box 4. SAICM Objective for Risk Reduction
Reducing the use of the most hazardous
In the Strategic Approach to International
chemicals can lead to cost savings and other Chemicals Management (SAICM), the Objective
financial benefits, in addition to protecting for Risk Reduction (paragraph 14) states that
human health and the environment. One chemicals or chemical uses that pose an
useful source of hazard information is the unreasonable or otherwise unmanageable risk
to human health and the environment are no
GHS classifications of CMR (carcinogenic, longer produced or used. Examples of groups
mutagenic or toxic to the reproductive of chemicals that might be prioritized for such
system) substances or other serious assessment are PBTs; vPvBs; chemicals that are
hazardous properties. carcinogens and mutagens or that adversely
affect, among others, the reproductive, endocrine
or nervous system; and mercury and other
By identifying hazard-based prioritization chemicals of global concern.
criteria, governments can provide clear,
transparent signals to industry, allowing

19
3.2.3 Exposure and risk-based likely to be used by pregnant women, by

prioritization children, by individuals who are illiterate,
or to a large extent in the informal sector or
Chemicals can also be prioritized based by other vulnerable parts of the population.
on use patterns that are likely to create Additionally, if monitoring or surveillance
conditions of widespread exposure across a studies have documented widespread
population, or intense exposure for a subset exposure, this could provide a reason
of the population. to prioritize the chemical, even if little
information is available on inherent hazard.
National-level exposure data may be Risk evaluations that have been
important as an additional factor in raising generated by other countries or regions
concern about a chemical if particularly may sometimes be useful as well. This
high exposures exist in a given country. information can be augmented, when
The volume of a substance produced or appropriate, with information on use and
imported can be used as a simple proxy exposure domestically, in order to tailor the
for potential exposure. Similarly, if there is evaluations to the conditions in a specific
a large number of producers and/or users, country.
or the chemical is widely available to the
general public, extensive exposure is likely. Canada uses a pre-market approval process,
A lack of detailed exposure data should not with the government responsible for risk
prevent authorities from taking appropriate assessment for a prioritized number of
action to protect human health and the industrial and consumer chemicals. Their
environment. priorities and risk assessments can provide
useful information to other countries.xxi
Use patterns can be a consideration in
elevating the level of concern about a
chemical – for example, if the chemical is
Box 5. Prioritization of chemicals for risk assessment in Costa Rica
Costa Rica developed Guidelines for Prioritization of Industrial Chemicals in 2018. The guidelines were
developed as part of the country’s commitments to the process of accession to the OECD. The prioritization
of chemical products is the first step in a new process for assessing the safety of existing chemical products.
The guidelines provide a methodology for prioritization: a relative value will be obtained for each chemical,
based on a set of criteria, which will then be used to determine if that product requires a subsequent risk
assessment. The selected criteria for the evaluation are:
• Import/production volumes
• Potential harm to human health and the environment
• Persistence in the environment (biodegradability)
• Listed in international agreements
• Reported emergencies
• Potential risk of damage, whether physical, health or environment-related (aquatic environment and/or
ozone layer) as established in the GHS
Following an initial “screening”, a list of candidate chemicals will be generated for risk analysis; based on the
results, a set of preventive and corrective actions will be developed.
Source: Jordi Pon and Costa Rica workgroup, personal communication, 2018

20
Criteria for prioritization of chemicals in Costa Rica; from “Report on Costa Rica’s Industrial
Chemicals Management Programme”.
Source: Jordi Pon and Costa Rica workgroup, 2018
3.2.4 Data and information supporting measures that have been adopted, as well
prioritization as the background for these measures.
Information is also often available on
ECHA maintains information on as many additional concerns that are still under
as 135,000 chemicals. These include consideration. All of this information can be
all substances subject to registration useful for a country in its initial assessments
under REACH, as well as all substances of a chemical. In all cases, it is essential to
placed on the market that are classified make use of existing data sources rather
as hazardous.xxii Under REACH, chemicals than reinvent the wheel.
must be registered if they are placed on the
EU market at a volume above 1 ton/year.1 Countries should make use of data and
The Toxic Substances Control Act provides evaluations in other jurisdictions, as long
information on reporting requirements in as they comply with recognized standards,
the United States.2 such as guidelines from the OECD. Data
on chemical properties is shared through
Manufacturers and importers are responsible various platforms, such as the OECD
for gathering and conveying knowledge on eChemPortal and the ECHA databases.
hazards and necessary precautions. The Existing GHS classifications are another
costs of testing and assessing chemicals for important source of information. Database
hazardous properties will vary. Importers can resources that are available internationally
obtain this information primarily by requiring include databases of chemical hazard
it from their suppliers in other countries. information; regulatory information; and
This can include ecotoxicological and ingredients in consumer products. Section
toxicological data. Within the EU, sharing of 3.2.5 and Annex 2 provide information on a
data and of testing costs among companies number of such resources.
is formalized and is a legal obligation.
If another country has already assessed

or acted upon a chemical, information is
likely to be available on the risk reduction
1 As of June 2018, the ECHA registration database contained 21,551 unique substances. Registration of a substance indicates that manufacturers or
others intend to continue supplying it to the EU market. The tonnage threshold for registration means that there is an unknown number of chemicals on
the European market with production volumes under 1 ton per year.
2 https://www.epa.gov/tsca-inventory/tsca-inventory-notification-active-inactive-rule

21
criteria for determining such requirements

need to be clear, and firms need to provide
Box 6. Mutual Acceptance of Data (MAD) credible justifications. Such proprietary
For assessment purposes in chemicals
management can help to minimize the costs
protections should also have time limits
of laboratory tests. The OECD Council adopted and periodic reapplication procedures.
a decision in 1981 on MAD. It states that “test Governments should require that health
data generated in any member country in and safety information be ineligible for CBI
accordance with OECD Test Guidelines and
Principles of Good Laboratory Practice (GLP)
protection, and grant access to CBI data
shall be accepted in other member countries to workers for safety purposes; to health
for assessment purposes and other uses professionals; and to states, provinces and
relating to the protection of human health and foreign countries for administrative and law
the environment”. Additional OECD Council
Acts “establish procedures for monitoring GLP
enforcement purposes.xxv
compliance through government inspections
and study audits”, as well as a framework for A publication from the US Department
international liaison among monitoring and of Treasury describes best practices for
data-receiving authorities; and set out “a step-
wise procedure for non-OECD countries to take
regulatory data collection. Following such
part as full members in this system”.xxiii best practices can help to protect CBI.
The advice includes defining the business
purpose for collecting the data; developing
clear and precise definitions; and creating
Annex 3 of LIRA provides some further collection specifications.xxvi
examples of sources of information or
databases for chemicals management. As 3.2.5 Resources for information on
discussed in the LIRA Guidance 3.3.3.1, chemicals
the databases also include information
on exposure, accident reporting and safer A range of resources are available for
alternatives. government and industry employees
wishing to find information about
An issue that may arise when collecting chemicals. Many of these resources are
the relevant data and information is publicly available; others are available for a
confidentiality. Several resources are subscription fee.
available for regulators that can help
determine how to balance protecting The list below provides information on a
a company’s confidential business number of these resources. For general
information (CBI) with colleting the information about chemical hazards
necessary data and information. An ECHA and other properties, resources such as
manual provides information on online ChemHAT, the ECHA REACH registration
access to information on registered chemical database, and Pharos can be useful. The
substances, and on the content and University of Massachusetts Lowell Toxics
assessment of confidentiality requests.xxiv Use Reduction Institute’s (TURI) webpage
ECHA is required to publish information on Environmental, Health and Safety Data
on registered substances on its website, in Resources can also help direct the user
the “Information on Chemicals” section. to relevant resources that are most useful
However, in some cases, information can be for particular health or environmental
withheld if the registrant requests that it be endpoints. For existing GHS classifications,
kept confidential and provides a justification see additional information in Section 4.1.
for why publishing it might harm their Below are brief descriptions of many of these
commercial interests or those of another resources. For web addresses, see Annex 2.
party. ECHA must then make a decision on
such requests. • Chemical Hazard and Alternatives
Toolbox (ChemHAT). ChemHAT
While the case can be made for some was initiated through a partnership
information to remain confidential because it between the Industrial Division of the
may affect a company’s competitiveness, the Communications Workers of America
and the BlueGreen Alliance, and has

22
since incorporated the work of university regulatory requirements, nanomaterials

and government experts, among others. and related areas. The information in
It is an online database that aims to HSDB has been assessed by a scientific
provide easy-to-use information for review panel.”
workers, families and other interested
parties, to help protect themselves from • OECD eChemPortal. This web resource
the harm that chemicals can cause. It provides information on physical
provides answers to the question: “Is chemical properties, ecotoxicity,
there a way to get this job done without environmental fate and behaviour, and
using dangerous chemicals?” toxicity.
• Chemical Hazard Data Commons. This • OECD Regulations and Restrictions.

resource is built on the Pharos platform This resource provides a table of
(described below) and helps users restricted substances and related
identify “problematic chemicals and laws and regulations organized by
collaborate to find safer alternatives”. geographic scope. The lists provide
descriptions of substances and
• Decision Guidance Documents chemicals that are legally or voluntarily
prepared for the chemicals listed in restricted or recommended for
the Rotterdam Convention. These restriction due to their hazards or that
contain basic information on chemicals, have been examined by jurisdictions
including hazard classifications, based on potential concerns of a similar
additional sources of information and nature.
possible alternatives.
• Pharos. Developed by the non-profit
• ECHA Classification and Labelling Healthy Building Network, this website
Inventory. This resource provides provides health and environmental
classification and labelling information information about building products.
for all chemicals that have been notified It includes the GreenScreen List
or registered under REACH. It is also a Translator, which provides information
good resource for reviewing the EU’s on toxicological and regulatory
approach to harmonized classifications, classifications. It is only accessible to
and it includes an Excel file showing an subscribers, for a relatively small fee.
up-to-date list of chemicals with their
harmonized classifications. • Proposition 65 List. California’s Safe
Drinking Water and Toxic Enforcement
• ECHA REACH Registration Database. Act of 1986, commonly referred to as
This website offers users a “Chemical Proposition 65, requires the State of
Property Data Search”. Data comes from California to publish a list of chemicals
registration dossiers submitted to ECHA. known to cause cancer, birth defects
or other reproductive harm. The list
• ECHA, Substances Restricted under is updated at least once a year and is
REACH. This resource provides a table available to view or download online.
of substances for which use is limited or
banned in the EU. • ToxPlanet. This subscription-based
resource provides access to a variety
• Hazardous Substances Data Bank of databases on chemical hazards,
(HSDB). Part of the US National Library properties, regulatory requirements and
of Medicine, HSDB is, according to its other information.
website, “a toxicology database that
focuses on the toxicology of potentially
hazardous chemicals. It provides
information on human exposure,
industrial hygiene, emergency handling
procedures, environmental fate,

23
• University of Massachusetts Lowell

Toxics Use Reduction Institute
(TURI) – Environmental, Health and
Safety Data Resources. This website
provides links to a variety of pages
for finding general and/or detailed
information on chemicals, including
physical properties, health effects and
environmental fate.
• Global Product Strategy, GPS

Chemicals Portal provides access to
information on chemicals. Establishing
a base set of information and publishing
GPS Safety Summaries for chemicals in
commerce is part of the commitment of
ICCA member companies to the GPS.

24
CORE RISK REDUCTION

TOOLS
Classification and labelling, bans, restrictions GHSxxvii is a system to ensure accurate

and authorization systems comprise the core management and communication of
risk reduction tools in chemicals control. information on chemical properties and
safe handling. The “right-to-know” is a
4.1 Classification and labelling fundamental goal of risk reduction activities.
This refers to the right to know about CHAPTER
4
Implementing the GHS and SDSs as a chemicals to which one might be exposed.
legal requirement for all chemicals is a Chemical manufacturers and importers
core element of risk reduction. Hazard are required to gather and communicate
assessments, and classification and accurate information, and ensure the flow
labelling should be done in accordance of this information through supply chains.
with the GHS because it is internationally Use of the GHS ensures international
recognized and the most widely used harmonization of classification and labelling
standard. Both manufacturers and importers of all types of chemicals. It also facilitates
should be held accountable for establishing international trade in chemical substances
and maintaining appropriate systems for and products containing chemicals,
classification and labelling, and SDSs. including facilitating access to markets in
compliance with international requirements.
GHS applies to chemical substances and
mixtures of chemical substances that meet
the harmonized criteria for physical, health
or environmental hazards under the GHS.
GHS uses the following definitions:
Substance means chemical elements and

their compounds in their natural state
or obtained by any production process,
including any additive necessary to
preserve the stability of the product and any
impurities derived from the process used,
but excluding any solvent, which may be
The Hazard Pictograms in the GHS are separated without affecting the stability of
internationally recognized the substance or changing its composition.

25
Mixture means a mixture or solution well as referring to a national standard or

composed of two or more substances in the UN publication. This approach is likely to
which they do not react. be the most efficient way to build the GHS
into domestic law, while keeping up with
When introducing the GHS, it is best to changes. Guidance for GHS implementation
provide a transition period to allow industry is available from the United Nations Institute
to learn how the system works and have for Training and Research (UNITAR).xxix
time to implement it. It is also necessary
to provide a later entry-into-force date for As hazards depend on the intrinsic properties
mixtures, as those who are required to of a chemical, which are always the same,
classify and label mixtures need to have official/harmonized classifications using the
access to the classification of all ingredients GHS criteria from other countries or regions
in the mixture. should be used, as these are normally peer-
reviewed by expert groups and thus can be
SDSs should be adapted to the prevailing considered reliable.xxx Using this list ensures
conditions and circumstances of the country that the whole market is using the same
in which the chemical is used. Otherwise, classification for the same substance. This
the recommendations may be inadequate also ensures that small- and medium-sized
or not applicable.xxviii enterprises are able to provide accurate
information to their downstream users,
GHS can be seen as the first level of risk and international trade is facilitated by
reduction, as it provides the necessary using the same official classification as in
information to allow manufacturers and other countries or regions. Making use of
importers, as well as government, to make other countries’ official lists will reduce the
appropriate decisions. By implementing the need for additional administrative time and
GHS requirements, governments create the personnel, although it is necessary to ensure
conditions that will enable the adoption of that the list is updated regularly.
other risk reduction measures. The intrinsic
properties of a chemical, such as its toxicity, Examples: GHS implementation: The EU
must be established first, in order to take legislation implementing the GHS – the CLP
steps to regulate and manage it throughout (Classification, Labelling and Packaging)
its life cycle. Regulationxxxi – aims to ensure that the
hazardous properties of chemicals are
Many chemical products are incorporated identified and clearly communicated to
in finished products or articles during all users through labelling and SDSs (the
the production phase. In some countries, latter applies to professional users only).
specific substances have been regulated as Classifying chemicals before making them
part of a group of articles but, in general, they available on the market is the responsibility
are largely unregulated with regards to their of chemical manufacturers and importers.
chemical content. Examples of chemicals
in articles include paints and lacquers in On 7 November 2017, the Ministry of Health,
furniture, polymers and metals in electric Chile, published the draft of a regulation
and electronic products, dyes in textiles, and implementing the GHS. The draft classifies
flame retardants in plastics. substances and mixtures predominantly
in terms of the sixth revised edition of the
Responsibility for maintaining, updating GHS, and with the same requirements for
and promoting the GHS at the international labels and SDSs. The proposed regulation
level lies with the United Nations includes a transitional period of one
Subcommittee of Experts on the GHS and year to implement the classification for
the UN Subcommittee of Experts on the substances and five years for mixtures, once
Transport of Dangerous Goods. This body the regulation has been finalized. There is
updates the GHS every second year. Some currently no proposed date of adoption or
countries have chosen to implement the entry into force.xxxii
system through general legislative text
about the obligation to apply the law, as

26
In the US, the GHS focuses on the right of Table 1. Additional GHS classification
workers to information about chemicals in resources that link users to the public GHS
their workplace, which is required as part classification lists for individual countries
of the US Occupational Safety and Health
Administration’s Hazard Communication European https://echa.europa.eu/information-on-
Standard. Union chemicals/cl-inventory-database
Australia http://hcis.safeworkaustralia.gov.au/Hazard-
Costa Rica provides an example of a country ousChemical
that, in introducing the GHS, adapted and Japan www.safe.nite.go.jp/english/ghs_index.html
improved on existing national labelling Republic http://ncis.nier.go.kr/en/main.do
systems. In Costa Rica, existing regulations of Korea
required SDSs that generally followed the Malaysia http://www.dosh.gov.my/index.php/en/legis-
GHS guidelines. In June 2017, the Costa lation/codes-of-practice/chemical-manage-
Rican Government published a requirement ment
for labelling in accordance with the GHS New https://www.epa.govt.nz/database-search/
“for workplace and supplier chemicals”, Zealand chemical-classification-and-information-data-
providing a five-year transition period base-ccid/
(until December 2022) for compliance.xxxiii
In November 2017, the government
published a requirement that, in order to be
registered, hazardous chemicals must have
a GHS-compliant Safety Data Sheet; again,
transitional periods are provided for renewal Box 7. Additional resources for GHS
of registrations. implementation: Web pages
A key resource for checking existing GHS GreenScreen List Translator, through Pharos:
www.pharosproject.net
classifications is the ECHA Classification
and Labelling Inventory, which offers a Toxplanet: https://toxplanet.com/
free, up-to-date list of substances classified
by the EU.xxxiv This resource shows both eChemPortal: https://www.echemportal.org/
echemportal/index.action
harmonized and non-harmonized GHS
classifications developed within the EU. For UNITAR – in partnership with the International
non-EU classifications, a useful resource Labour Organization and Inter-Organization
is Pharos, an independent subscription- Programme for the Sound Management of
Chemicals – guidance on GHS implementation:
based chemical database aggregated http://www.unitar.org/cwm/ghs
from numerous lists generated by various
countries for chemicals of concern. If a National Institute of Technology and Evaluation
subscription to Pharos is not available, it – Support Tools for Implementation of GHS:
http://www.safe.nite.go.jp/english/ghs/ghsrefs.
is also possible to use the websites listed
html
in Table 1 to view GHS classifications for
countries outside of the EU.
Box 8. Information resources for GHS implementation
There are some subscription-based database services that can help governments to gain quick access to
other countries’ GHS classifications, among other information. One such resource is the GreenScreen List
Translator available through Pharos, a US-based non-governmental organization. The Massachusetts Toxics
Use Reduction Institute has compiled a guide covering a wide range of databases, including both publicly
available and subscription-based services. Toxplanet, a subscription-based service, is a useful source for both
toxicological and regulatory information from many countries. The Chemical Hazard and Alternatives Toolbox
(ChemHAT) provides publicly available information in an easy-to-read format. The OECD’s eChemPortal
provides information on the properties of chemicals, including physical chemical properties, ecotoxicity,
environmental fate and behaviour, and toxicity. UNITAR’s guidance on GHS implementation describes how
countries can assess their capacity for implementing the GHS, engage stakeholders in capacity-building, and
develop a national GHS implementation strategy.

27
Addressing challenges to GHS adoption. The capacity to implement the GHS requires
UNITAR notes: “The current global situation resources for developing legislation and
is a patchwork of sometimes conflicting guidance, technical knowledge, and funds
and diverse national and international for implementation costs and staff time.
requirements…The GHS was created to A study published in November 2017xxxvi
harmonize the different or lacking hazard found that, as of April 2017, 50 countries
classification and communication systems had fully implemented the GHS; 15 had
within a country and between countries and partially implemented it; and 128 had not.
regions”.xxxv Broad implementation of the It also found that most countries that have
GHS across countries will lead to information implemented the GHS have a higher gross
being more consistently communicated via domestic product per capita than those that
labels and SDSs – with benefits for human have not. Full implementation was most
health, the environment and business. It common in Europe and parts of Asia. One
is also essential to adopt best practices for country in Latin America, Ecuador, had fully
confidentiality, with provisions that health implemented the GHS, as had two in Africa:
and safety information in SDSs be exempt. Zambia and Mauritius. Among the 15 that
had partially implemented the GHS, most
SDSs come from suppliers, and the had implemented the system for workplaces
information they contain must be correct. It only – not for the consumer and agriculture
is critical that information included in labels sectors.
is easy to understand for all users; labelling
requirements must be tailored to the target
audience, as well as use internationally
recognized pictograms.
Source: Stockholm Environment Institute Policy Brief, “Reducing chemical risks in low-income
countries: strategies for improved coverage of basic chemicals-management legislation”,
2018.xxxvii xxxviii

28
The study also finds that regulatory capacity, a circular economy4 in which waste and
as measured by government effectiveness pollution are reduced and resources can be
indicators, is positively associated with recycled in a safe way.
GHS implementation – highlighting the
importance of capacity to formulate 4.2 Bans and restrictions
and introduce legislation. Additional
influences may include EU membership Bans and restrictions regulate access to
or the aspiration to join other international chemicals that are too hazardous to remain
organizations or agreements. freely and openly available, or which a
country does not have the national capacity
In the case of Zambia, “it seems that to manage effectively. According to the
sustained capacity-building and donor LIRA Guidance,5 bans and restrictions
support for the GHS implementation have “set forth a schedule, or list, of specific
served as a factor of importance. Zambia has compounds which are considered to cause
received support from UNITAR under the unacceptable risk to human health and/or
SAICM Quick Start Programme (QSP)” and the environment. While bans strictly prohibit
from other donors, according to the study. the production, sale and/or use of the
“Indeed, the need for capacity-building substance, restrictions limit the availability
and awareness-raising for successful GHS of the chemicals to specific uses/condition”.
implementation in low-income countries They may apply to the manufacture, import
has been long standing on the agenda of and/or use of a chemical. They may apply to
international collaboration…”xxxix Similarly, a substance as such or to a substance in a
Viet Nam’s chemicals management efforts mixture or in an article.
have been supported by several donors
and organizations; the outcome was the Bans and restrictions can exist at a variety
establishment of the Viet Nam Chemicals of levels, including total bans, bans with
Agency. This support is likely to have specific exemptions, or bans or restrictions
influenced GHS implementation through for a specific use of a chemical. In some
parallel institutional strengthening and cases, a ban or restriction may cover just
broad chemicals management capacity- the manufacture and use of a chemical in
building efforts. the country, while in other cases it may also
apply to imported products or articles. An
Chemicals in Products Programme. The example is the EU’s ban on nonylphenol
GHS system is designed for classification ethoxylates (NPEs), a group of chemicals
and labelling of individual chemicals and mainly used as cleaning agents, but also
chemical mixtures. The system does not added to plastics and rubbers, pesticides,
provide information on the occurrence of pharmaceuticals, cosmetics, paints and
specific chemicals in an article (e.g. toys, coatings, agro-chemicals and chemicals
electronics, clothes).3xl To address this used in paper making.xlii However, they
gap, a voluntary information programme remained present in the environment as
called Chemicals in Products (CiP) has been many imported products, such as textiles,
developed within the framework of SAICM. continued to include the substance, which
It aims to identify chemicals in articles/ could be emitted during washing.xliii This
products and the means for improving the triggered the need to ban or restrict their
sharing of this information through the presence in articles as well.
supply chain, including with recyclers/waste
managers.xli Bans or restrictions can also help to promote
the development and introduction of
This voluntary programme is intended for safer alternatives that are technically and
use by companies, to provide information financially viable. Substantial innovation
to downstream users, including final often occurs during the phase-out period.
customers, on the content of specific It is often useful to involve stakeholders
chemicals in products and articles. This when designing a ban, increasing the
information is also important for creating likelihood that it will be designed in a way
that facilitates compliance.
3 “Article” is defined in the EU REACH regulation as an object that is given a special shape, surface or design during production which determines its
function to a greater degree than does its chemical composition.
4 A circular economy is an economy where the value of products, materials and resources is maintained for as long as possible, and the generation of
waste minimized. Definition from COM (2015) 614 final, Communication from the Commission to the European Parliament. ‘Closing the loop – An EU
action plan for the Circular Economy’
5 UNEP, LIRA Guidance, section 4.4.3

29
As noted in the LIRA Guidance, a

Box 9. Efforts to eliminate lead in paint government’s authority to impose a ban
Infants and young children are particularly
or to restrict the supply or use of chemical
vulnerable to the effects of lead. The Global substances should generally be established
Alliance to Eliminate Lead Paint (GAELP) in framework legislation (also referred to as
is working to promote a phase-out of the primary legislation). Framework legislation
manufacture and sale of paints containing lead,
and to eventually eliminate the risks that such
identifies basic principles and obligations,
paints pose.xliv Activities include catalysing while leaving details to further legislation,
the design and implementation of prevention- programme development or other
based programmes and identifying paint government activities. Details, such as the
manufacturers.xlv GAELP has produced a Toolkit
for Establishing Laws to Control the Use of Lead in
list of substances banned or restricted and
Paint. The Toolkit provides a variety of resources the schedule for restricting their supply, can
for countries working to establish legal controls be included in secondary legislation, also
on lead paint.xlvi referred to in some cases as regulations.6
UNEP has developed guidance and a model law
Manufacturers and importers are responsible
for regulation of lead in paint. Elements include for understanding and complying with
legal limits on total lead content; penalties for existing bans and restrictions, and must
violation of these limits; and a requirement to use not produce, import or market banned
applicable elements of the GHS for any activities
related to transport, storage, disposal or other
products, or sell restricted products, except
activities related to lead-containing paint.xlvii as permitted by the legislation.
Nevertheless, WHO reports that only “34% of
countries have confirmed that they have legally Bans and restrictions have proven effective
binding controls on the production, import, sale
and use of lead paints”.xlviii According to WHO
in controlling or eliminating the use of
data, 67 countries report that they have legally hazardous substances. For example, bans
binding lead controls; 69 report that they do on the use of lead in petrol/gasoline have
not have legally binding lead controls; and 58 been essential in reducing rates of lead
countries have provided no data.
poisoning. Similarly, bans on the use of
A 2016 report by the International POPs certain persistent organic pollutants (POPs)
Elimination Network (IPEN) describes gains that have reduced body burdens of these
have been made in eliminating lead paint. Data chemicals in many parts of the world.
on lead paint is available in 46 countries; binding
regulatory controls limiting the lead content of
paint have been enacted or are pending in six 4.3 Authorization or pre-market approval
Asian countries and four African countries; the systems
East African Community has adopted mandatory
standards restricting the use of lead paint in its
five Member States; and the world’s largest paint
Authorization or pre-market approval
producer reported that it had removed leaded systems provide another – but more
ingredients from its consumer paint brands and resource-demanding – means to control
products in all countries.xlix which chemicals are allowed on the market.
According to the IPEN report, data on the presence
In such a system, a manufacturer or importer
of lead paints on the market is available in just 23 must have authorization, approval or a
of the 126 countries that do not have regulatory licence before placing a chemical on the
controls. IPEN notes that “much more needs to be market. Many countries have laws of this
done” in order to reach GAELP’s target date for all
countries to adopt legally binding requirements.l
kind for pesticides and pharmaceuticals.
Challenges for many countries include a lack They are not common for industrial and
of legislative authority, a lack of regulatory consumer chemicals as the system is
experience, and slow rule-making processes. complex and resource-demanding, both
Countries that have adopted regulatory controls
may also encounter difficulties related to
for the authorities and industry. Licensing
enforcement, according to IPEN’s report. systems can be used for sale, manufacture
and import, in addition to use. For ozone-
depleting substances, some countries
use an import licensing system. Under
such a system, restricted chemicals can be
imported only if the importer has a licence.
6 UNEP, LIRA Guidance, section 4.4.3

30
In the European Union, the authorization

approach is used for industrial chemicals
that are considered to be Substances of
Very High Concern and that are prioritized
for further action. In these cases, use is
prohibited unless an explicit authorization
is provided for the specific use in question.li
Canada uses a pre-market approval

process, with the government responsible
for risk assessment for a prioritized
number of industrial and consumer
chemicals.lii Substances that meet certain
criteria may be considered for various
risk-management measures, including
regulations, guidelines or codes of practice
to control aspects of the substances’ life
cycle. The Domestic Substances List (DSL)
contains approximately 23,000 substances.
Additional lists identify various priorities
for action for the chemicals on the DSL;
about 4,000 chemicals are to be assessed
and considered for risk management
measures. These pre-approval efforts could
provide useful information for industry
and governments in other countries in
implementing cost-efficient and knowledge-
based risk reduction measures.

31

32
ADDITIONAL RISK
REDUCTION TOOLS
In addition to the main administrative risk administrative costs, both for the authorities
reduction instruments described above, a and for industry, and compare them to other
government may decide to use additional options before considering the introduction
approaches. These options may include of an economic instrument.
economic instruments and informative
instruments, or tools to influence business Economic instruments are not a good choice CHAPTER
5
or consumer behaviour, including chemical if the chemical poses an unacceptable risk
requirements in public tenders and support to health or the environment. It should not
for substitution for safer alternatives. be possible to pay for the right to use or
release a substance that is highly hazardous.
5.1 Economic instruments
However, economic instruments that
An economic instrument can consist of are correctly designed might usefully
taxes or fees that must be paid for the use complement other instruments – for example,
of a specific substance that is considered to where there is a need for a reduction in the
create health or environmental problems. use of moderately hazardous substances,
To promote the use of less hazardous but a total phase-out is not needed. In such
substances, different forms of subsidies cases, market forces may be harnessed
can be considered. Taxes and fees as to help reduce use while keeping costs
economic policy instruments must be low. Economic instruments can be used
based on legislation in the same way as the to accelerate a process of substitution and
traditional risk reduction instruments. They innovation, and to support safer alternatives,
also need the same basis for decisions and helping them to reach the market or increase
socioeconomic considerations, as well as a their market share. For example, a tax or fee
system for control and enforcement. There on the use of a chemical of particular concern
needs to be a pre-existing system for the can help to encourage substitution for safer
collection of taxes and fees in the country; alternatives. Differentiated fees based on
otherwise it will be difficult to establish an different properties could create incentives
efficient economic instrument. to seek out less harmful alternatives.
However, these potential advantages can
In general, economic instruments are be undermined by increased administrative
not an important element of chemicals burden.
control in developed countries as they
can be resource-demanding to establish When there are good opportunities to
and maintain effectively. Therefore, it is increase the market share of alternatives –
important to assess the accompanying that are less harmful in terms of health and/

33
or the environment – economic instruments A drawback with informative instruments

may be a suitable complementary measure. is that the outcome is less certain than
Lead in petrol, for example, was phased with administrative measures such as
out with an environmental tax (often in classification and labelling requirements or
combination with a subsequent ban) in controlling the entry of a chemical on to the
many countries. The most successful uses market. For risk reduction to be sustainable,
of economic instruments have been in the it is necessary to continuously follow up
European Union – to address air pollutants activities over a longer period of time. This
such as sulphur oxides and nitrogen should not discourage the government or
oxides. For a limited period, Sweden other authorities from carrying out such
used an economic instrument to address activities, especially if they are combined
cadmium contamination in fertilizer, adding with other measures such as introducing
an additional cost to bring the price of legal restrictions at a later stage.
cadmium-containing fertilizer up to the price
level of safer fertilizer. 5.2.1 Public procurement
5.2 Informative instruments Government entities can help support the

market for safer alternatives by specifying
An informative instrument aims to achieve a safer options for public purchasing. Many
voluntary reduction of the use of a specific governments now have Environmentally
substance or group of substances. It aims to Preferable Purchasing (EPP) programmes.7
change behaviour and change production. In the United States, many state
Informative instruments can be used as governments, as well as local municipal
stand-alone measures if the risk from a governments, have EPP programmes. In the
specific substance or group of substances is EU, criteria are available through the Green
relatively low but still needs to be reduced. It Public Procurement programme.46 Since
is sometimes possible to see more immediate 2014, it has been possible for EU authorities
results with informative instruments than to set specific environment-related criteria
with a ban or a restriction. in public procurement, according to the EU
Procurement Directive.liii
An informative instrument could be used:
Municipalities and other agencies who
• to encourage the reduction of the use put out calls for tenders, should be able to
and the substitution of a substance or set well-founded requirements in relation
a group of substances with unwanted to chemicals. To support them in this,
properties that pose a moderate risk to central authorities can provide criteria and
human health and/or the environment. guidance. Such criteria could, for example,
contain requirements that substances or
• to speed up the elimination of a specific mixtures meeting specific GHS criteria
substance or a group of substances cannot be used for the purpose of a tender.
before a ban or a restriction is adopted One way to reduce risks from hazardous
and/or enters into force. substances used in public procurement is to
request ecolabelled articles and services, or
• to inform industry, at an early stage, of products with equivalent documentation.
substances that might require measures
due to the emerging weight of the 5.2.2 Ecolabelling
evidence.
Ecolabelling can drive markets towards
Informative instruments are, however, not safer chemicals by empowering consumers
suitable as stand-alone measures when to make informed choices, if chemical
there is a severe hazard or when target hazard is included as a core criterion in the
groups are difficult to reach. ecolabel system. This is a voluntary method
or system of certifying or identifying more
environmentally preferable products.
7 See, for example, Washington (https://www.ecy.wa.gov/Regulations-Permits/Guidance-technical-assistance/Sustainable-purchasing) and California

(http://www.calrecycle.ca.gov/epp/).

34
For example, in Germany, the Blue Angel other risk-reduction instruments because
ecolabelling system evaluates products in general awareness about chemicals
relation to health, climate, water and resource and their potential effects provides the
goals.liv The EU ecolabel regulation specifies basis for achieving the intended effects
criteria to be used in the EU ecolabelling of the instruments. Many countries and
system.8 The US Environmental Protection organizations have developed websites
Agency has ecolabelling programmes and/or printed material to inform the general
including ENERGY STAR™, WaterSense® public about chemicals and their risks. When
and Safer Choice, which identify products needed, informational material, including
that meet certain benchmarks for energy press releases, is issued for specific issues of
efficiency, water efficiency and green concern.
chemistry. Examples of non-government
ecolabelling programmes are EcoLogo Targeted information for a specific problem.
and Green Seal, which are used to identify Information pamphlets, websites, press
more environmentally preferable cleaning releases and other similar material can be
products. used to educate the public about chemical
hazards. This can contribute to a reduction in
Ecolabelling has become a useful tool the use of harmful substances, as it can affect
for governments to encourage sound the demand from downstream users as well
environmental practices, and for businesses as the general public. Greater awareness
to identify and establish domestic and, of a problem might trigger questions on
sometimes, international markets for their the availability of alternatives and how to
environmentally preferable products. avoid buying products containing specific
The requirements for ecolabels need to substances. In this way, public awareness
be clear, unambiguous and objectively might trigger substitution as well.
verifiable in order to ensure transparency
and fair competition for the suppliers in the It is valuable to inform downstream users of
procurement processes. It is important to the need or the desirability to substitute a
understand the criteria used for a particular specific type of substance for one that is less
ecolabel, as it is possible that a product that hazardous; in this way they can put pressure
is deemed environmentally friendly could on their suppliers to provide alternatives.
still pose a risk to human health.
Well-informed consumers can put pressure
5.2.3 Awareness-raising on national and local politicians to issue
legislation that aims to reduce the use of
General awareness-raising. Authorities play hazardous chemicals and create a less
a role in providing accurate and unbiased toxic local environment. Depending on
information to the general public and public the resources available to the authority,
organizations on chemicals in the everyday information provided directly to consumers
environment. Detailed information on how to by government authorities or non-
handle a specific chemical in a safe manner governmental organizations regarding
and to enable people to make informed particular substances, or the substances
choices needs to be supplied by the used in mixtures and articles, can be
manufacturer or importer. Civil society also considered. Such efforts can lead to well-
has an important role to play in generating, informed, stronger consumer groups that
using and disseminating information about refuse to buy products that contain specific
chemicals. hazardous chemicals. Their behaviour
can put pressure on downstream users
The authorities can support general and, through them, the primary suppliers,
awareness-raising about chemicals and to substitute such chemicals with less
their effects, and how to handle them – for hazardous ones. Targeted information from
example, in school curricula and through authorities aimed at private consumers
general information material, websites, about a specific problem is an effective
etc. Broad awareness-raising supports all
8 For general EU ecolabel information, see: http://ec.europa.eu/environment/ecolabel/index_en.htm.

For the regulation itself, see: http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010R0066&from=EN.
ECHA Strategy to promote substitution to safer chemicals through innovation

35
informative instrument, where the desired Governments can encourage businesses

result is to promote substitution of the target to develop solutions ahead of legislation.
substance. Within the REACH regulation there
is a process for identifying the most
The aim could also be to raise awareness hazardous chemicals – defined as SVHCs
of the effects and properties of chemicals, – and subsequently placing them on the
and how to use and handle them Candidate List; EU Member States have
correctly. Consumers in many countries decided that the use of these substances
are increasingly asking for information to should be strictly limited. This list can be
enable them to make safer choices with used by companies and others to identify
regard to hazardous substances in products which chemicals to start moving away from.
and articles.
Businesses may also be encouraged or
5.2.4 Substitution and safer alternatives required to use non-chemical methods
(process changes). For example, for
The Substitution Principle9 refers to the businesses using toxic solvents in
obligation or option to substitute a hazardous degreasing applications, toxic chemicals
chemical for a less hazardous one, or apply can sometimes be phased out by working
an alternative technique, when possible. The within the supply chain to substitute the
assessment of alternatives is a process for contaminant in the part that requires
identifying, comparing and selecting safer cleaning, or by exploring alternative
alternatives to replace hazardous chemicals, materials to prevent contamination and
with the objective of promoting sustainable cleaning altogether. The role of industry
production and consumption. can include conducting alternatives
assessments, supporting and promoting
Some regulatory approaches create a research on safer alternatives, facilitating
responsibility for industry to assess and the commercialization of safer alternatives,
choose safer alternatives to banned or and adopting non-chemical alternatives
restricted chemicals. In some cases, (process changes) when possible.
governments may require businesses to use
the least hazardous alternatives available. For Governments can also promote research
example, under the EU’s REACH regulation, and development for safer alternatives and
if a substance is subject to authorization, create incentives by providing criteria for
businesses must adopt safer alternatives, potential future bans or restrictions.
unless they are able to make the case that
there is an important need that cannot be
Box 10. Options for building substitution
met by any other chemical or process. But in capacity
these cases, they must show that they have
fully assessed the alternatives. The OECD Substitution and Alternatives
Assessment Toolbox compiled an inventory
of chemical hazard assessment tools and data
In the United States, the states of California sources. A listing of non-hazard assessment tools,
and Maine have laws requiring businesses case studies and regulations that are driving the
to carry out alternatives assessments, increase need for substitution and alternatives
under certain circumstances. The US assessment approaches are also available.lvi
Environmental Protection Agency (EPA) A University of Massachusetts Lowell project
notes that alternatives assessments can was set up to identify specific priorities that
“encourage industry to move to safer the European Chemicals Agency and other
alternatives, complement regulatory government authorities could support in the near
term in order to advance chemical substitution
action by showing that safer and higher programmes and practices among EU Member
functioning alternatives are available, States. Recommendations included expanding
or point out the limitations to chemical ECHA and Member State authority staff capacity
substitution for a particular use”.lv over time, to support substitution through
training and recruitment; coordinating EU and
Member State grant mechanisms and private/
9 ECHA Strategy to promote substitution to safer chemicals through innovation

January 2018; https://echa.europa.eu/documents/10162/13630/250118_substitution_strategy_en.pdf/bce91d57-9dfc-2a46-4afd-5998dbb88500;
Substituting hazardous chemicals (ECHA website) https://echa.europa.eu/substitution-to-safer-chemicals

36
Dialogue between the authorities and

public funds to invest in innovative research industry is an ongoing, long-term process.
to support alternatives development; building
structures to provide technical assistance to The initial stage involves establishing
companies; and expanding chemical substitution contact and building trust between the
as part of government sustainability procurement different parties; it is important to allow all
programmes.lvii actors to exchange views on the difficulties
The Swedish Chemicals Agency’s web-based and possibilities of implementing chemicals
tool, PRIO, is an example of a website that control. Dialogue also gives the participating
supports industry actors to choose appropriate authorities a better understanding of the
chemicals – helping to reduce the health and conditions faced by different industries.
environmental risks from chemical substances.lviii
The aim of PRIO is to support industry in the An effective dialogue can hopefully lead
assessment of health and environmental risks to ongoing work within industry towards
from chemical substances so that people who reducing risks from the use of hazardous
work as environmental managers, purchasers substances, without the involvement of
and product developers can identify the need for
risk reduction. In order to achieve this goal, PRIO authorities in the future.
provides a guide for decision-making that can
support in setting risk-reduction priorities. A practical approach to carrying out a
dialogue would be to concentrate on a
The SIN (Substitute It Now!) List consists of
lix
chemicals that have been identified as SVHCs, specific group of articles, such as toys, textiles
based on the criteria defined within REACH. It or electronics that might contain a number
also serves as a tool for companies and others to of chemicals that need to be reduced. It is
identify which chemicals to start moving away also useful to involve, if available, sector-
from before they are classified as SVHCs and
placed on the Candidate List. The SIN List is specific organizations because they can
developed by ChemSec (International Chemical reach a broader group of companies.
Secretariat) in collaboration with scientists and
technical experts, as well as an NGO advisory In some cases, discussions and dialogue
committee of leading environmental, health
and consumer organizations. The list is based with industry might result in a voluntary
on publicly available information from existing commitment from industry to substitute a
databases and scientific studies, as well as hazardous substance with a less hazardous
new research. The SIN List is implemented in alternative substance or an alternative
procurement requirements all over the world.
Health, environmental and consumer NGOs technique. However, it is important to follow
are using the SIN List as a tool for prioritizing up on these discussions, to verify that any
individual chemicals or groups of chemicals as proposed actions are actually taken and
part of their campaigns for safer products and continue over time.
stronger chemicals regulations.
Authorities should avoid committing to

5.2.5 Dialogue with industry doing something in return for a commitment
from industry (i.e. enter into a mutual
An important objective of dialogue between agreement). This is legally complex, and
authorities and industry is to increase in some countries, it is not even legally
awareness and knowledge about the risks of possible.
using hazardous substances – on their own
or in mixtures or articles – and to encourage The voluntary programme, Chemicals
continuous substitution of hazardous in Products (CiP), mentioned in section
chemicals with less hazardous alternatives, 4.1, was set up to promote more effective
whenever possible. Industry-sector dialogue information sharing about chemicals in
can be useful to speed up the elimination of articles (e.g. toys, electronics, clothes) in
a specific substance or group of substances the supply chain.lx This programme can be
before a ban or a restriction is adopted and/ promoted by national administrations for use
or enters into force. Dialogue with prioritized by companies to enhance their knowledge
industry sectors can also be very useful for base and capacity to provide information
reducing the use of a specific substance to downstream users, including recyclers/
or group of substances with unwanted waste managers. The programme aims
properties that cause a moderate risk to to improve information sharing between
human health and/or the environment. companies and downstream users about

37
specific chemicals in products and articles chemical or product. Such information can
that users should be aware of – for example, enable/influence downstream users’ choice
when there is a need for proper handling of chemicals and encourage producers to
during the use and/or disposal of the substitute for less hazardous chemicals.

38
CHOOSING RISK
REDUCTION TOOLS
Factors to take into account in choosing the choice of instrument should be described
most appropriate risk reduction instrument in a way that can be easily understood by
may include the type of hazard and the both decision makers and stakeholders.
level of risk; actors using the chemical; Industry, downstream users, other
efficiency and sustainability over time; and authorities and NGOs should be invited to
the administrative burden and costs. contribute to the process. When it comes to CHAPTER
6
introducing safer alternatives, downstream
Decision-making normally begins with users can provide important perspectives.
collecting information about the problem, The recycling and waste sector is also an
identifying risk reduction goals, and important stakeholder, as reducing the use
choosing a risk reduction option. When of hazardous chemicals can facilitate waste
phase-out of a substance such as mercury management. In general, risk reduction tools
has been identified internationally, national are most effective if a range of stakeholders
efforts should focus on applying risk representing different groups within the
reduction measures. sector are involved in their development.
A clear process for involvement in the
National legislation must be clear about development of the legislation and adoption
the level at which a decision to reduce the of risk reduction measures – as well as
risks from chemicals should be taken. In transition periods before they take effect –
some cases, an agency or other authority facilitates compliance.
is mandated to make these decisions in
regulations, often referred to as secondary In developing approaches to risk reduction,
legislation; while in other cases, the decision it is essential to maximize transparency.
rests at the level of the legislature. For example, any assumptions involved in
developing a risk reduction measure must
The rationale behind the decision to be clearly specified.
introduce risk-reduction measures and the
General scheme of the legislating process

39
Some basic assessment of the regulatory Many countries have a large informal sector
socioeconomic impact may be needed. It that uses and sells chemicals. In assessing
is often sufficient to identify the industry the need to regulate a chemical, it is
sectors that are likely to be affected by the important to assess its marketing and use in
ban or restriction. Effective communication both the informal and formal sector. When
with the relevant industries helps to a hazardous chemical is marketed or used
facilitate an assessment. If the chemical predominantly in the informal sector it may
has already been successfully banned or be difficult or impossible to control exposure
restricted in other parts of the world, making due to a lack of engineering controls,
use of information about other countries’ personal protective equipment and training
socioeconomic experiences can help save on correct handling. In this instance, bans
resources.lxi 10 and restrictions on supplying the chemical
may be suitable.
A transition period prior to entry into force
helps to ensure that stakeholders have time If the risk from a specific substance or group
to understand the requirements and come of substances is relatively low but the use
into compliance. still needs to be reduced, an economic
or informative instrument could be more
In choosing a risk reduction tool, it is appropriate – either on its own or combined
important to consider the administrative with other measures.
burden and costs over time for both the
government and the industry. Any country Hierarchy of Controls
introducing new legal requirements will
need to consider how the law will be The concept of a “hierarchy of controls” is
enforced. Any instruments that are chosen used frequently in the occupational health
require administrative capacity; and for and safety field. The hierarchy of controls
legal instruments, capacity for effective makes clear that the most effective way
enforcement is a prerequisite. For more to protect against harm from hazardous
information, see Enforcement of Chemicals chemicals is to eliminate chemicals of
Control Legislation: Guidance Document. concern. Substitution for a safer alternative
is the next most effective approach. The
The effectiveness of different risk reduction least effective approach, which should be
instruments needs to be compared and used when no other options are available,
evaluated in the national context. The is to rely on personal protective equipment
implementation of the GHS is a very (PPE). Adopting and implementing
effective measure for reducing the risks chemicals control legislation helps to make
from any hazardous substances handled in clear which chemicals need to be eliminated
the workplace and/or used by consumers. or substituted. It also ensures that accurate
For highly hazardous chemicals, bans or information flows through the supply chain
restrictions are often the appropriate tool. when there is a need for measures lower
Substitution for safer alternatives or methods down the hierarchy (engineering controls,
is then a high priority. In cases where there administrative controls and PPE). A diagram
are suspicions of severe adverse effects of the hierarchy of controls is shown below.
from a substance, but full scientific evidence
is lacking, precaution should be applied.
10 Regulatory Impact Analysis (RIA) is a systematic approach often used by OECD countries. For more information, see: OECD, Regulatory Impact
Analysis, www.oecd.org/gov/regulatory-policy/ria.htm. However, this approach can be administratively and technically challenging.

40
Source: US Center for Disease Control and Prevention (CDC), National Institute for
Occupational Safety and Health (NIOSH). 2016. “Hierarchy of Controls”. Viewed at
https://www.cdc.gov/niosh/topics/hierarchy/, February 2018.

41
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Press.
World Health Organization (WHO). “International Programme on Chemical Safety.” Web resource accessed at
http://www.who.int/ipcs/en/, April 20, 2017.

43
Annex 1:
Additional risk management guidance documents
European Commission, Seveso Directive – Technological Disaster Risk Reduction: http://ec.europa.eu/

environment/seveso/
International Labour Organization, C170 – Convention Concerning Safety in the Use of Chemicals at Work
(1990): http://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO::P12100_ILO_CODE:C170
International Labour Organization, Chemical Safety and the Environment (2009-2014): http://www.ilo.org/
safework/areasofwork/chemical-safety-and-the-environment/lang--en/index.htm
IOMC Strategy for Strengthening National Chemicals Management Capacities (2011): http://www.who.int/iomc/
publications/strategy_english.pdf?ua=1
IOMC: Assisting Countries with the Transition Phase for GHS Implementation (2008): http://www.who.int/iomc/
publications/ghs_impl_english.pdf?ua=1
Inter-Organization Programme for the Sound Management of Chemicals (IOMC), IOMC Toolbox for Decision Making
in Chemicals Management (updated 2017): https://iomctoolbox.oecd.org/Default.aspx?idExec=58d24f84-
e109-473a-a80a-a9895d8a77a7
National Implementation of SAICM: A Guide to Resource, Guidance and Training Materials of IOMC Participating
Organizations (August 2012): http://www.who.int/iomc/saicm/resource_guide.pdf?ua=1
OECD Substitution and Alternatives Assessment Toolbox: http://www.oecdsaatoolbox.org/
OECD Guiding Principles for Chemical Accident Prevention, Preparedness and Response http://www.oecd.org/
env/ehs/chemical-accidents/Guiding-principles-chemical-accident.pdf
Responsible Care, ICCA. Through Responsible Care, global chemical manufacturers commit to pursue an ethic
of safe chemicals management. https://www.icca-chem.org/responsible-care/
Swedish Chemicals Agency, 2018. Risk reduction of chemicals. Guidance 2/18. Stockholm: KemI. https://www.
kemi.se/global/guidance-on-national-chemicals-control/guidance-2-18.pdf
UNEP, Flexible Framework for Addressing Chemical Accident Prevention and Preparedness (2010): http://www.
capp.eecentre.org/Flexible-Framework-Guidance.aspx
World Health Organization, Developing a Capacity Assessment for the Sound Management of Chemicals and
National SAICM Implementation (2007): http://www.who.int/iomc/saicm/capacity_assessment_en.pdf?ua=1
World Health Organization, Guidance for Developing SAICM Implementation Plans (2009): http://www.who.int/
iomc/publications/saicm_impl_en.pdf?ua=1

44
Annex 2:
Chemical information resources
Chemical Hazard and Alterna- http://www.chemhat.org/en General information – designed for workers
tives Toolbox (ChemHAT)
Chemical Hazard Data https://commons.healthymaterials.net/ Hazard and regulatory information

Commons
Decision Guidance http://www.pic.int/TheConvention/ Hazard information

Documents, Annex III to the Chemicals/DecisionGuidanceDocu-
Rotterdam Convention ments/tabid/2413/language/en-US/
Default.aspx
ECHA Classification and https://echa.europa.eu/regulations/ Includes GHS classifications

Labelling Inventory clp/cl-inventory
https://echa.europa.eu/regulations/
clp/harmonised-classification-and-
labelling
https://echa.europa.eu/information-on-
chemicals/annex-vi-to-clp
ECHA REACH Registration https://echa.europa.eu/informa- General information

Database tion-on-chemicals/registered-sub-
stances
ECHA, Substances Restricted https://echa.europa.eu/substances-re- Regulatory list, includes GHS classifications

under REACH stricted-under-reach
Hazardous Substances Data https://toxnet.nlm.nih.gov/newtoxnet/ General information – hazards and other prop-
Bank (HSDB) hsdb.htm erties
OECD eChemPortal https://www.echemportal.org General information
OECD Regulations and http://www.oecdsaatoolbox.org/ Overview of resources from multiple countries,

Restrictions Home/Regulations hazard information
Pharos, including https://www.pharosproject.net/ Hazard and regulatory information, subscrip-

GreenScreen List tion-based
Translator
Proposition 65 List https://oehha.ca.gov/proposition-65/ Regulatory list – hazard information
proposition-65-list
ToxPlanet https://toxplanet.com/ Hazard and regulatory information, subscrip-

tion-based
University of Massachusetts http://guides.turi.org/beyondmsds Overview of multiple data resources
Lowell Toxics Use Reduction
Institute (TURI) – Environmen-
tal, Health and Safety Data
Resources
GPS Chemicals Portal, http://icca.cefic.org/ The GPS Safety Summaries provide product
ICCA safety information from companies on the
chemical products they manufacture

45
ENDNOTES
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Retrieved from http://wedocs.unep.org/handle/20.500.11822/8412-Costs of inaction on the sound management
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ii Food and Agriculture Organization of the United Nations (FAO). 2006. International code of conduct on
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iii Strategic Approach to International Chemicals Management (SAICM). 2015. Overall orientation and guidance
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iv Strategic Approach to International Chemicals Management (SAICM). (n.d.). Launch of the Beyond
2020 process. Retrieved December 11, 2018, from http://www.saicm.org/Resources/SAICMStories/
LaunchoftheBeyond2020process/tabid/5530/Default.aspx
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vi United Nations Environment Programme (UNEP). 2015. UNEP Guidance on the development of legal and
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viii Breithaupt, H. 2006. The costs of REACH. REACH is largely welcomed, but the requirement to test existing
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pdf
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htm

46
xiv European Chemicals Agency (ECHA). 2018. Assess hazard and risk. Retrieved December 12, 2018, from
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xv Government of Canada. (n.d.). Domestic substances list. Retrieved December 12, 2018, from https://www.
canada.ca/en/environment-climate-change/services/canadian-environmental-protection-act-registry/substanc-
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xvi European Chemicals Agency (ECHA). (n.d.). Candidate List of substances of very high concern for
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xvii U.S. Environmental Protection Agency Office of Pollution Prevention and Toxics. 2014. TSCA work plan
for chemical assessments: 2014 Update. Retrieved from https://www.epa.gov/sites/production/files/2015-01/
documents/tsca_work_plan_chemicals_2014_update-final.pdf
xviii Rotterdam Convention. (n.d.). How it works. Retrieved December 12, 2018, from http://www.pic.int/
TheConvention/Overview/Howitworks/tabid/1046/language/en-US/Default.aspx
xix European Parliament. 2004. Regulation (EU) No 649/2012 of the European Parliament and of the council of 4 July
2012 concerning the export and import of hazardous chemicals. Official Journal of the European Communities.
xx Rotterdam Convention. (n.d.). Annex III Chemicals. Retrieved December 12, 2018, from http://www.pic.int/
TheConvention/Chemicals/AnnexIIIChemicals/tabid/1132/language/en-US/Default.aspx
xxi Government of Canada. (n.d.). Lists of substances: Canadian Environmental Protection Act, 1999. Retrieved
December 12, 2018, from https://www.canada.ca/en/environment-climate-change/services/canadian-
environmental-protection-act-registry/substances-list.html
xxii European Chemicals Agency (ECHA). (n.d.). Classification and Labelling Inventory. Retrieved December 12,
2018, from https://echa.europa.eu/regulations/clp/cl-inventory
xxiii Organisation for Economic Co-operation and Development (OECD). (n.d.). Mutual Acceptance of Data
(MAD). Retrieved December 10, 2018, from http://www.oecd.org/env/ehs/mutualacceptanceofdatamad.htm
xxiv European Chemicals Agency (ECHA). 2018. Dissemination and Confidentiality under the REACH Regulation.
Helsinki, Finland. Retrieved from https://echa.europa.eu/documents/10162/22308542/manual_dissemination_
en.pdf/7e0b87c2-2681-4380-8389-cd655569d9f0
xxv Denison, R. 2007. Not that innocent: A comparative analysis of canadian, European Union and United States
policies on industrial chemicals. Washington, DC: Health Program, Environmental Defense. Retrieved from https://
www.edf.org/sites/default/files/6149_NotThatInnocent_Fullreport.pdf
xxvi U.S. Department of Treasury. Office of Financial Research. 2016. OFR Viewpoint: Developing best practices
for regulatory data collections. Retrieved from https://www.financialresearch.gov/viewpoint-papers/files/
OFRvp-2016-01_Best-Practices-Data-Collection.pdf
xxvii United Nations. 2013. Globally harmonized system of classification and labelling of chemicals (GHS), Fifth revised
edition. New York and Geneva. Retrieved from https://www.schc.org/assets/docs/ghs_un _update-sept_2013.
pdf
xxviii Jordi Pon and Costa Rica workgroup, personal communication. 2018.
xxix United Nations Institute for Training and Research (UNITAR). Inter-Organization Programme for the Sound
Management of Chemicals (IOMC). ILO. 2010. Developing a national GHS implementation strategy. Geneva, Swit-
zerland. Retrieved from http://cwm.unitar.org/national-profiles/publications/cw/ghs/GHS_GD_September2010.
pdf

47
xxx Swedish Chemicals Agency (KEMI). 2018. Guidance on national chemicals control, Risk reduction of chemi-
cals (Guidance 2/18). Sundbyberg. Retrieved from https://www.kemi.se/en/global/guidance-on-national-chemi-
cals-control/guidance-2-18.pdf
xxxi European Chemicals Agency (ECHA). (n.d.). CLP Legislation. Retrieved December 12, 2018, from https://
echa.europa.eu/regulations/clp/legislation
xxxii Veronique Garny, ICCA, personal communication. 2018.
xxxiii Chemical Watch. (n.d.). Costa Rica, Chile released details of GHS implementation, 12 December 2017. Re-
trieved December 12, 2018, from https://chemicalwatch.com/62477/costa-rica-chile-release-details-of-ghs-im-
plementation
xxxiv European Chemicals Agency (ECHA). (n.d.). Classification and Labelling Inventory. Retrieved December
12, 2018, from https://echa.europa.eu/regulations/clp/cl-inventory
xxxv United Nations Institute for Training and Research (UNITAR). Inter-Organization Programme for the Sound
Management of Chemicals (IOMC). ILO. 2010. Developing a national GHS implementation strategy. Geneva, Swit-
zerland. Retrieved from http://cwm.unitar.org/national-profiles/publications/cw/ghs/GHS_GD_September2010.
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xxxvi Persson, L., Karlsson-Vinkhuyzen, S., Lai, A., Persson, Å., & Fick, S. 2017. The globally harmonized system of
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xxxvii Ibid
xxxviii Persson, L. 2018. Reducing chemical risks in low-income countries: strategies for improved coverage
of basic chemicals-management legislation. Stockholm Environment Institute (SEI) Asia Centre. Retrieved from
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xxxix Persson, L., Karlsson-Vinkhuyzen, S., Lai, A., Persson, Å., & Fick, S. 2017. The globally harmonized system of
classification and labelling of chemicals-Explaining the legal implementation gap. Sustainability, 9(12).).
xl European Chemicals Agency (ECHA). 2011. Guidance on requirements for substances in articles. Retrieved
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315d2f7be7ac
xli Strategic Approach to International Chemicals Management (SAICM). (n.d.). Chemicals in Products (CiP). Retrieved
December 12, 2018, from http://www.saicm.org/EmergingPolicyIssues/Chemicalsnbsp;innbsp;Products/
tabid/5473/language/en-US/Default.aspx
xlii Scottish Environment Protection Agency (SEPA). (n.d.). Nonylphenol ethoxylates. Retrieved December 12,
2018, from http://apps.sepa.org.uk/spripa/Pages/SubstanceInformation.aspx?pid=154
xliii Massey, R. I., Hutchins, J. G., Becker, M., & Tickner, J. 2008. Toxic substances in articles: The need for information.
Nordic Council of Ministers, Copenhagen. Retrieved from http://internal-pdf//200811-Toxic Substances in
Articles- The Need for Information-2755185669/200811-Toxic Substances in Articles- The Need for Information.
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xliv World Health Organization (WHO). (n.d.). Global Alliance to Eliminate Lead Paint. World Health Organization.
Retrieved December 12, 2018, from https://www.who.int/ipcs/assessment/public_health/gaelp/en/
xlv World Health Organization (WHO). 2011. Operational framework, Global alliance to eliminate lead paint. Retrieved
from https://www.who.int/ipcs/assessment/public_health/framework.pdf?ua=1

48
xlvi United Nations Environment Programme (UNEP). (n.d.). Toolkit for establishing laws to eliminate lead paint.
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xlvii United Nations Environment Programme. 2017. Model Law and Guidance for Regulating Lead Paint,
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xlviii World Health Organization (WHO). (n.d.). Legislation. Retrieved December 12, 2018, from https://www.who.
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xlix nternational POPs Elimination Network (IPEN). 2016. Global lead paint elimination report. Retrieved from
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control/guidance-2-18.pdf

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UNEP GUIDANCE

Risk Reduction Tools for

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

Prioritizing chemicals for risk reduction of Chemicals (REACH); California’s Proposition 65

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

An informational tool aims to achieve a voluntary

Public procurement requirements can be useful for

Awareness of chemical hazards facilitates the

The “Substitution Principle” refers to the obligation

Deciding on risk reduction tools

National legislation must be clear about the level at

Factors to take into account in choosing the most

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

• Benefits of Chemicals Control

• National Authority for Chemicals Control: Structure and Funding

• Risk Reduction Tools for Chemicals Control

• Enforcement of Chemicals Control Legislation

The editing and layout were coordinated by UN Publications.

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

2. Key concepts of risk reduction.....................................................................................................................................................12

3. Prioritization of chemicals for risk reduction.........................................................................................................................16

4. Core risk reduction tools.................................................................................................................................................................24

5. Additional risk reduction tools.....................................................................................................................................................32

6. Choosing risk reduction tools.......................................................................................................................................................38

Annex 1: Additional risk management guidance documents...........................................................................................43

Annex 2: Chemical information resources..................................................................................................................................44

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

Participants of this expert group:

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

Non-governmental organizations, academia and other advisers

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

United Nations (FAO).ii Although guidance 1.2 Scope and aim

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

KEY CONCEPTS OF RISK

Box 1. Principles of proactive health and environmental protection

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

The International Council of Chemical

The role of government is to ensure that all

Governments should therefore:

• Adopt framework legislation clarifying the

• Adopt legislation implementing the GHS

• Introduce bans and restrictions for

• Supervise and enforce compliance with

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

vPvB substances accumulate in the

Under the European Union’s REACH

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

3.2.3 Exposure and risk-based likely to be used by pregnant women, by

Box 5. Prioritization of chemicals for risk assessment in Costa Rica

UN Environment Guidance on Risk Reduction Tools for Chemicals Control

If another country has already assessed

UN Environment Guidance on Risk Reduction Tools for Chemicals Control