The Role of the Civil Society in GHS Implementation Presentation by: Rachel Kamande PSR – Kenya (IPEN PO)

What are NGOs? NGOs belong to the category of organizations that are non-profit in nature and therefore not a part of the business community. They are also, as the name suggests, not a part of government. Like governments however, NGOs are intended to work for society’s common good and like businesses, they define their own agenda. NGOs play an important complimentary role to governments and businesses.

What are some of the main functions of NGOs? To create public awareness on important issues of concern; To create public awareness on important issues of concern; To advocate for necessary changes in society or society’s ways of doing things; To advocate for necessary changes in society or society’s ways of doing things; To monitor the activities of governments, multinational organizations and other powerful entities with a view to ensuring good governance; To monitor the activities of governments, multinational organizations and other powerful entities with a view to ensuring good governance; To help develop alternative models of development that governments’ bureaucracies might not have the flexibility to develop but which they (governments) could be interested in adopting if proved to be successful; To help develop alternative models of development that governments’ bureaucracies might not have the flexibility to develop but which they (governments) could be interested in adopting if proved to be successful;

To help implement programmes especially at the grassroots level. To help implement programmes especially at the grassroots level.

In Kenya, NGO representation in chemicals management efforts is evident with most active NGOs in issues of chemical safety actively NGOs in issues of chemical safety actively participating in sound chemicals management participating in sound chemicals management activities. The number of NGOs operating in the area of chemicals management is operating in the area of chemicals management is not many but their contributions in not many but their contributions in terms of increased awareness on the need to a more integrated approach towards chemicals management in both the relevant public management in both the relevant public authorities and various other organizations is exemplary.

NGOs and Chemical safety NGOs work extensively to promote better management of chemicals in all sectors. They generate guidance and policy, and create opportunities for information and experience sharing on matters related to chemicals regulation. They serve as effective advocates, watchdogs, and as effective partners in the design and implementation of activities that enhance chemical safety. NGOs work extensively to promote better management of chemicals in all sectors. They generate guidance and policy, and create opportunities for information and experience sharing on matters related to chemicals regulation. They serve as effective advocates, watchdogs, and as effective partners in the design and implementation of activities that enhance chemical safety.

The Intergovernmental Forum on Chemical Safety (IFCS) recognizes the vital role of non- governmental organizations (NGOs) in raising public awareness and priority setting. Involvement of these organizations helps create synergies in addressing the various global environmental issues. NGOs have been engaged in the SAICM process right from the beginning… we are hoping that the process will be successfully concluded in Dubai next year (2006).

Public interest NGOs (international, national, regional and local) have a critical role to play in influencing democratic and popular opinion about chemical safety and its importance. They also have a critical role in helping to ensure that the design and the implementation of the activities and programs are appropriate and effective, and that the intended results are both well designed and achieved.

PSR – Kenya’s interest in GHS implementation The organization has been and continues to be an active participant of the International POPs Elimination Network (IPEN). It co-hosted the Second NGO Forum on the Inter-governmental Negotiation Forum (INC2) in Nairobi; and is currently the regional focal point for East Africa besides being a member of IPEN’s Coordinating Committee. We are also members of Health Care Without Harm (HCWH) and the current Vice President of International Society of Doctors for the Environment (ISDE) Africa.

PSR - Kenya is the vice-chair of the national steering committee on POPs, and chairs the DDT sub-committee. In addition, PSR-Kenya has been instrumental in the development of the National Chemicals profile and the national implementation plan for the Stockholm convention. These initiatives are vital in paving way for the implementation of the GHS.

Studies we conducted on the POPs (Persistent Organic Pollutants) situation in the country together with other participating organizations of the International POPs Elimination Project (IPEP) revealed that Africa has a lot of ground to cover with regard to proper management of chemicals. We also established that there is urgent need to develop chemicals information network within the continent.

IPEN The International POPs Elimination Network (IPEN) links over 350 organizations on issues related to POPs and other chemicals. The International POPs Elimination Network (IPEN) links over 350 organizations on issues related to POPs and other chemicals. The mission of IPEN, achieved through its participating organizations, is to work for the global elimination of persistent organic pollutants, on an expedited yet socially equitable basis. The mission of IPEN, achieved through its participating organizations, is to work for the global elimination of persistent organic pollutants, on an expedited yet socially equitable basis.

The IPEP The formal title of the IPEP project is “Fostering Active and Effective Civil Society Participation in Preparations for Implementation of the Stockholm Convention.” The short name being International POPs Elimination Project.

IPEP has three goals: Encourage and enable NGOs in 40 developing and transitional countries to engage in activities that provide concrete and immediate contributions to country efforts in preparing for the implementation of the Stockholm Convention; Encourage and enable NGOs in 40 developing and transitional countries to engage in activities that provide concrete and immediate contributions to country efforts in preparing for the implementation of the Stockholm Convention; Enhance the skills and knowledge of NGOs to help build their capacity as effective stakeholders in the Convention implementation process; Enhance the skills and knowledge of NGOs to help build their capacity as effective stakeholders in the Convention implementation process; Help establish regional and national NGO coordination and capacity in all regions of the world in support of longer term efforts to achieve chemical safety. Help establish regional and national NGO coordination and capacity in all regions of the world in support of longer term efforts to achieve chemical safety.

IPEP projects include country situation reports, POPs inventories, sampling of breast milk and POPs inventories, sampling of breast milk and eggs, social and economic impact of POPs pesticides, participation in the National Implementation Plans, policy briefs and public awareness material. Findings from these studies form the basis for analysis of the chemical situation in the respective countries in order to aid in development of strategies for the aid in development of strategies for the Implementation of MEAs.

The Kitengela study within IPEP Study on a contaminated site (Kitengela obsolete pesticides store) in Kenya pesticides store) in Kenya ( which revealed in Kenya there is no national chemical hazard communication system and regulations/legislation on production, hazard communication system and regulations/legislation on production, export/import and use of chemicals are weak. However, these regulations are being developed and therefore the GHS would be very instrumental in and therefore the GHS would be very instrumental in shaping these regulations.

Other findings from the study include: Poor or lack of labeling; Poor or lack of labeling; Lack of criteria for hazards; Lack of criteria for hazards; Untrained personnel to man the store; Untrained personnel to man the store; Poor disposal methods – “barbequing” of the obsolete stocks at KIWM “barbeque”!! Poor disposal methods – “barbequing” of the obsolete stocks at KIWM “barbeque”!!

Unlabelled Chemicals at the Kitengela Obsolete Pesticide store

Civil Societies Role in GHS implementation Awareness creation and dissemination of data particularly at the grassroots level (consumer level) Awareness creation and dissemination of data particularly at the grassroots level (consumer level) Identification of gaps within the GHS and providing recommendations for amendments Identification of gaps within the GHS and providing recommendations for amendments Monitoring the implementation/compliance of the GHS by the governments and other stakeholders that have acceded to the use/adoption of the GHS Monitoring the implementation/compliance of the GHS by the governments and other stakeholders that have acceded to the use/adoption of the GHS Research on hazards of chemicals, and establishing the hazard criteria Research on hazards of chemicals, and establishing the hazard criteria

assist in assessing the applicability of the GHS on chemicals classification and labeling in their respective countries prior to adoption; assist in assessing the applicability of the GHS on chemicals classification and labeling in their respective countries prior to adoption; influence policies of the national governments to adopt/incorporate the GHS by 2008 – the target set by the WSSD; influence policies of the national governments to adopt/incorporate the GHS by 2008 – the target set by the WSSD; securing implementation of the Multilateral Environmental Agreements (MEAs) in line with the provisions of the GHS. securing implementation of the Multilateral Environmental Agreements (MEAs) in line with the provisions of the GHS. to define/develop a strategy for effective implementation and domestication of the GHS; to define/develop a strategy for effective implementation and domestication of the GHS;

To enhance public participation in GHS implementation deliberations and programs To enhance public participation in GHS implementation deliberations and programs Generation of relevant data to aid the development of a comprehensive chemical hazard system commensurate with country situation; Generation of relevant data to aid the development of a comprehensive chemical hazard system commensurate with country situation; Gap analysis to beef-up the GHS and the development of user-friendly tools for risk assessment. Gap analysis to beef-up the GHS and the development of user-friendly tools for risk assessment.

Expected Outputs of NGO involvement in GHS implementation better regulation of chemicals especially in developing countries, including better control over imports, adherence to packaging and labelling requirements, quality controls and product registration; better regulation of chemicals especially in developing countries, including better control over imports, adherence to packaging and labelling requirements, quality controls and product registration; better management of hazardous chemicals, including storage and handling, as a result of monitoring the enforcement of GHS compliant standards; better management of hazardous chemicals, including storage and handling, as a result of monitoring the enforcement of GHS compliant standards; decentralization of chemical hazard communication systems; decentralization of chemical hazard communication systems;

greater awareness of the importance of adherence to the GHS standards of chemicals classification and labelling. This will result in greater attention being given to the way hazardous chemicals are handled and clarity and comprehensiveness in labelling on the part of national authorities, industry, donors and others; greater awareness of the importance of adherence to the GHS standards of chemicals classification and labelling. This will result in greater attention being given to the way hazardous chemicals are handled and clarity and comprehensiveness in labelling on the part of national authorities, industry, donors and others; strengthening of national regulations on production, export/imports and use of chemicals, compliant with the GHS on chemicals classification and labeling; strengthening of national regulations on production, export/imports and use of chemicals, compliant with the GHS on chemicals classification and labeling;

 facilitate/ boost public access to data – government agencies vary widely in the extent to which they provide the data in a form that is usable to any but a small group of experts and the level of effort that they require a citizen to expend to get the data

Activities that NGOs can undertake to contribute to GHS implementation Data collection/generation Data collection/generation Facilitate and call for testing of chemicals Facilitate and call for testing of chemicals Risk assessment Risk assessment Risk Reduction Risk Reduction Policy Analysis Policy Analysis

Training and Education Training and Education Monitoring implementation and enforcement Monitoring implementation and enforcement Development of information exchange networks (regional, national and local) Development of information exchange networks (regional, national and local)

Challenges facing NGOs in the implementation of the GHS NGOs albeit high credibility among the public and decision makers, need assistance in building strategies, training, and even coordination between themselves. NGOs albeit high credibility among the public and decision makers, need assistance in building strategies, training, and even coordination between themselves. Environmental NGOs face different problems and different political systems around the world. NGOs in developing countries and countries with economies in transition face various challenges like lack of resources – financial and technical, conflicts with the governments and powerful business interests. Environmental NGOs face different problems and different political systems around the world. NGOs in developing countries and countries with economies in transition face various challenges like lack of resources – financial and technical, conflicts with the governments and powerful business interests.

It is encouraging to see that most governments recognize the significant role of NGOs in GHS implementation. Sadly, some evidence also suggests that there are still other government agencies that are becoming less willing to work with the NGO community to provide effective access to information for the public. END END