Summary of Group Discussions Group 3 : TT, Antigua, Jamaica, St. Vincent & the Grenadines, Guyana, Bahamas, St. Lucia.

Technical Aspects (1) What are the current technical challenges to GHS implementation? (e.g. differences in classification results using GS criteria; application of the ‘building block’ approach; changing label and SDS formats; lack of agreed international list of classified chemicals etc.)

Technical Aspects Revisions in the GHS Criteria. It is noted that these changes are done on a 2 year basis timeframe. This may be onerous on countries. An alternative will be to draft the relevant legislation or regulations in such a way that will allow compliance without needing to amend. (eg. Use of annexes). However there will still be implementing changes to be instituted that require additional capacity. Importation of pesticides that are not GHS compliant. Regionally, we are small scale importers and as such we are unable to influence the change.

Technical Aspects There is a need for a regional agreement as per the adaptation of the GHS format. Regional countries have not declared or committed to adoption of this system and there are countries utilizing other systems as per WHO, ISO and CROSQ. A collaborative regional approach which redound economic and trade benefits and the negotiating power of the group. It is noted however, that countries will be able to customize to a certain extent their labeling and so nationally instituted practices (e.g. the “For use in Guyana” label requirement) can still be utilized.

Inability to track illegal importation for countries that share borders. Inability of current customs applications to properly monitor importation of chemicals/pesticides Lack and/or standardization of SDS data sheets. Lack of technical capacity/understanding of GHS Communicating to different stakeholders heads of governments technicians Industry consumers/users Technical Aspects

There will be challenges in sensitizing the public and the consumers as per the changes (e.g. labeling changes) that the GHS system will bring. There will be the need for intensive PR to effect these changes. A suggestion is a “regional registration system” that will cover elements such as testing and analyses. A challenge is the international grant funding opportunities available for capacity building exercises in the implementation. There is the current opportunity being considered under GEF- 6.

Technical Aspects The capacity required to shift from the established systems to another system (whatever will be the regionally accepted model) is great. It is noted that for industries, the GHS system will be useful. It will also be useful tool for Customs and can allow for regional training in this regard. However individual countries will still have specific import regulations and this can be considered a hindrance.

Technical Aspects (2) What steps need to be taken by stakeholders (especially govt and industry) to overcome these challenges in a coordinated way?

Technical Aspects National internal co-ordination mechanisms need to be strengthened, for example a lead agency to be identified. The need for Caricom recognition of the CGPC body will improve their functioning and give clout to their recommendations.

Technical Aspects Training at the level of the regulatory body after which there can be strengthened PR campaigns which can be done regionally, for example sharing of produced items such as booklets, posters etc. Facilitating technology transfer between countries will reduce the capacity costs and not duplicate costs. Apply currently used system until the transition is made. Co-coordinated regional data bank for resources that can be accessed by all countries. This will see a reduced cost as individual countries will only pay for maintenance

Technical Aspects Technical Capacity building for all stakeholders Tailor communication tools to specific stakeholders

Technical Aspects (3)What further technical issues will be faced in the future and how should all stakeholders prepare to address them?

Technical Aspects Updating the GHS system changing every two years and this can be addressed by the way in which the legislation is drafted such as the use of Annexes. The role of the region in influencing the changes within the GHS, as such the region should be represented on the GHS oversight committee to influence decision making.

Technical Aspects Resistance of countries to the change in chemical process management Amending of existing legislation to accommodate the GHS. Proper sensitization of all stakeholders Funding to carry out the transition.

Technical Aspects The regional website can be used to keep the countries au currant with the latest technologies and information. The use of research institutions such as the UWI should also be explored to give regional analyses. The verification processes as per lab accreditation and analytical services should be addressed regionally and capacity built within institutions such as the UWI.

Implementation Process Issues (1)What are the current procedural challenges to GHS implementation (e.g. ensuring harmonization of transition phrases with trading partners; undertaking appropriate training; raising awareness of workers, consumers and the public; etc?)

Implementation Process Issues The issue of harmonization is key to GHS Implementation. Procedurally, a regional approach is necessary. However, training as per customs and other regulatory bodies should be harmonized as related to the technology transfer as above. Procedurally, each country utilizes a different system. And so the transition period will involve coordination. As referred recognition of a regional body such as CGPC as the negotiating body.

Implementation Process Issues The referred body of the CGPC will have to undertake other chemical regulatory bodies/authorities requisite legislation. Gap Analysis: This should be undertaken on each country to access the capacity required to implement the GHS. Resource Requirements: As per the training required for involved stakeholders and for public education and awareness campaigns a regional technology transfer mechanism can be utilized.

Implementation Process Issues There will be need for the formulation of policy because of lack of commitment. Consensus and support from regulating agencies Accessing information Accurate, reliable & current data Financial & technical Support Delivery within appropriate timeframe

Implementation Process Issues Coordinated Timelines: The timeframes for transition should be agreed upon whereby most countries can fit into a period to achieve the obligations. National Compliance and Enforcement mechanisms have to be looked at as a complementary arm to GHS implementation. Therefore this is an additional capacity and procedural challenge. Capacity building for Trainers should be addressed.

Implementation Process Issues (2)What steps need to be taken by stakeholders to overcome these challenges in a coordinated way?

Implementation Process Issues Identify the lead agency and stakeholders involved Comprehensive understanding of the information gathered at the workshops and the benefits in adopting the GHS. Sharing experiences of countries that have already implemented the GHS to get influence the move towards implementation. Training ( Customs, Agricultural Sector, Transportation Sector) Public Education and Awareness Capacity Building Coordinated Internal Mechanisms

Implementation Process Issues (3)What further implementation process issues will be faced in the future and how should all stakeholders prepare to address them?

Implementation Process Issues The issue of project continuity into national developmental agendas. Transitioning of the regional authority as changes in scope occur. The current structure of the proposed regional regulatory authority will not be adequate to accommodate further transition. Resistance to issues of enforcement Legal Framework needed to ensure continuity Administrative costs associated to sustain capabilities. One solution can be to utilize administrative fees. A comprehensive chemical disposal system.

Legal Aspects (1)Scope of Legislation: which areas are covered? Which Blocks used? Responsibilities of actors?

Legal Aspects Import/ Export, Transportation, Labeling for various categories from Pesticides (exception of Bahamas), Toxic Chemicals and Pharmaceuticals. There is usually several Standards act that regulate labeling. Plant Protection Act, Environmental Management Act, Precursor Chemicals Act, OSH Act However harmonization of varying pieces of legislation is required.

Legal Aspects Modification of current Pesticides and Toxic Chemicals Act and Regulations Multilateral agreements and conventions signed by the countries in the region The responsibility will lie with the relevant government bodies to which the aforementioned pieces of legislation belong.

Legal Aspects (2)How is GHS Regulated? New law(s) or modification of existing law(s)? Transition period for entering into force of GHS? Adaptation of law(s) to new amendments of GHS? GHS obligations for imported chemicals.

Legal Aspects Proposed regional regulatory body will provide a model document that can act as a guide for all countries to amend or create their relevant laws. New laws (from modifying existing laws) Make preparation in original legislation to have scope for adaptation of new GHS Laws as they come out New entrants must comply with GHS before they are allowed to Import

Legal Aspects The transition period proposed will commence with a heads of government buy in by June 2014, the anniversary of the CGPC meeting for the region.

Legal Aspects (3)How is GHS implementation ensured? Support/guidance to industry? List of classified substances? Awareness raising, training? Monitoring of implementation? Sanctions of violation?

Legal Aspects Legislation is written to accommodate amendments to any regulation related to GHS updates or changes. Enforce existing legislation. Regional Registration System – issuance of certificates through the local inspectorate. Regional Body charged with Implementation Training and awareness raising for stakeholders Data Bank of resources

Legal Aspects Audits/inspections from the inspectorate of the regulatory body Ensure that legislation will adequately address enforcement, violations and sanctions. Amendments of legislation to ensure relevance to the industry so that proper sanctions are in place.

Communication #1: What are the current regional communication and information sharing challenges for GHS implementation (e.g. identification of regional focal points, platforms for regional information exchange; etc)?

Communication - challenges The absence of regional technical body to evaluate the requirements for aspects of implementation such as communication and information sharing for Sound Management of Chemicals. Use of the existing regional entities to oversee the implementation such as CAHFSA or the CGPC which are currently not scoped to provide the support required. Funding for the SMC regional body to implement the GHS. Identification of an actual focal point that is ubiquitous for all countries in the region.

Communication - challenges Access to technology for communication.

Communication - Steps #2: What steps could be taken by stakeholders to overcome these challenges in a coordinated way? (e.g. development of a regional electronic “forum” to provide a platform for an exchange of information, tracking of progress, learning from experiences to date, and planning for the future, etc.)

Communication - Solutions Use of available technology such as web conferencing, Skype, video conferencing, teleconferencing. Use of social networking to transfer information at a better rate regionally/real time. Development of a cost effective UNITAR app. to get information regarding pictograms, SDS etc. Establish milestones, set timelines, tasks associated with milestone accomplishment and report of achievement of same. Annual reports (standardized format).

Communication – further challenges #3: What further regional communication and information sharing issues will be faced in the future and how will all stakeholders be prepared to address them?

Communication - solutions Adequate training for personnel involved in GHS implementation and retention of knowledge in the requisite areas. Ensure that whatever communication strategy is used will be able to properly evolve with the change in growth and scope of technology. Continued access to technology to receive information for different levels of stakeholders.

Communication - solutions Develop a sustainable succession plan. Develop a communication strategy for all stakeholders. Use of local and regional organized events such as the local Health Week and the Pesticides Awareness Week hosted by the CGPC which reaches out to all levels of stakeholders. Integration of GHS at the primary school level of education.