Cassandra Taylor
Regulatory Specialist,
Nexreg Compliance Inc.
Regulatory International
Influences
Mexican GHS deadline approaches
Do you sell hazardous products into Mexico? This is your
friendly reminder that the new Mexican Official Standard,
NOM-018-STPS-2015, Harmonized System for the
Identification & Communication of Hazards &Risks of Hazardous
Chemicals in the Workplace (Sistema armonizado para la
identificación y comunicación de peligros y riesgos por sustancias
químicas peligrosas en los centros de trabajo) becomes enforceable
and mandatory in October 2018. In addition to implementing the
5th revised edition of the United Nations Globally Harmonized System
of Classification and Labeling of Chemicals (5th Rev. GHS) in Mexico,
NOM-018-STPS-2015 establishes new requirements for chemical
hazard communication in the Mexican workplace. Once the
new standard NOM-018-STPS-2015 comes into force, the current
standards, NOM-018-STPS-2000 and NOM-018-STPS-2014, will be
repealed.
NOM-018-STPS-2015 implements all available building blocks
of the 5th Rev. GHS. Since the U.S. Occupational Safety & Health
Administration (OSHA) HCS 2012 and the Canadian Workplace
Hazardous Materials Information System (WHMIS) 2015 did not
adopt all GHS building blocks, there are some prominent differences
between Mexican GHS requirements and those in the U.S.
and Canada. Some hazard classes that are optional in the U.S. and
Canada, such as ecological toxicity hazards, must be disclosed under
Mexican GHS. Additional hazard categories/levels that must
also be considered for Mexican compliance include Acute Toxicity
5 and Skin Irritation 3.
Mexico’s adoption of the 5th Rev. GHS means that classification
of aerosols differs from the U.S. and Canada. According to Mexican
GHS, aerosols fall into one of three categories/levels: Flammable
Aerosols 1 and 2 and Non-Flammable Aerosols 3. Whereas, to
date, there is no Aerosol 3 classification in the U.S. and Canada,
only the gases-under-pressure categories apply to non-flammable
aerosol products. Mexican GHS regulations do not expressly
forbid applying the gases-under-pressure classification alongside the
aerosol classification. Therefore, this difference doesn’t necessarily
prevent the combination of U.S., Canada and Mexico safety data
sheets (SDS).
The new Mexican GHS standard requires a 16-section Spanish
language SDS for hazardous products. Some specific requirements
outlined in the standard include an in-country telephone number
for emergency services and specific statements,
abbreviations and acronyms to be displayed in
section 16. NOM-018-STPS-2015 has not adopted
any list of harmonized substance classifications.
This means that the chemical data used to
classify products for other jurisdictions may also
be used for Mexican classification.
In theory, it may be possible to combine
your Mexican SDS with your current OSHA/
WHMIS GHS documents. However, we don’t
typically recommend proceeding in this way due
to the differences in classification requirements.
Mexico has not opted to include any
of the non-GHS hazard classifications
that have been adopted
by the U.S. and Canada,
such as combustible dust
or simple asphyxiant.
Also, Mexico has
implemented all 5th Rev. GHS building
blocks. Therefore, to achieve compliance
throughout North America, over-classification
may become an issue. For example, label
elements that are optional in the U.S.
and Canada, such as the aquatic toxicity
pictogram, can make a product appear
more hazardous compared to competitors that may not have
included these classifications on their labels and SDS.
NOM-018-STPS-2015 sets minimum pictogram sizes, ranging
from 3.1 to 37.5 centimeters (1.22"–14.57"), depending on the
distance of the observer from the label or sign. Additionally, the
standard includes employee training requirements. Workers must
undergo training at least once per year, and additionally each time
a new hazardous product is introduced, or when a SDS and label
are updated.
Proposed standard for Mexican cleaning products
In March of 2018, Mexico’s Secretariat of Health (Secretaría de
Salud) released a proposed standard on the labeling and packaging
of household cleaning products, PROY-NOM-189-SSA1/SCFI-
2016. The objective of the proposed standard is to establish label-
24 Spray September 2018
Aquatic toxicity pictogram