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California DPR Clarifies Position on GHS Labeling (April 2015)

California’s Department of Pesticide Regulation (DPR) issued California Notice 2015-05 to clarify its position regarding the implementation of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). DPR also provided registrants with a template to identify GHS changes on proposed labels.

Federally, GHS was adopted by the U.S. Occupational Safety and Health Administration (OSHA). By aligning its Hazard Communication Standard (HCS) with GHS, OSHA requires chemical manufacturers to classify chemicals according to the new criteria, and to update both product labels and safety data sheets. However, for pesticide products requiring registration with the U.S. Environmental Protection Agency (EPA), DPR decided to follow the guidance provide in EPA’s Pesticide Registration (PR) Notice 2012-01, which states that in granting a registration, EPA must determine the pesticide’s “labeling” complies with the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). EPA has not amended its labeling regulation to reflect GHS.

California DPR further clarifies that for pesticide products that require registration in California, but do not require federal registration (e.g., spray adjuvants), registrants should adhere to both GHS label features and the California labeling requirements in Title 3 of the California Code of Regulation §6235-6243. If there is a conflict, registrants may follow GHS labeling. Such conflicts could occur from the following elements:

    ▲ Signal Words

    ▲ Hazard Statements

    ▲ Precautionary Language

    ▲ First Aid Statements

    ▲ Storage and Disposal Statements

More Information
Certification of OSHA GHS Template
PR Notice 2012-01
OSHA GHS Details
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