GHS is on the way. It’s been called a “sea change” in the way we communicate chemical hazards. Are you prepared?
A plan to bring the United States into alignment with other countries in its approach to hazard communication, the Globally Harmonized System (GHS), could become part of the OSHA Hazard Communication standard within the next year.
For OSHA right now, the big issue concerning GHS is that various federal agencies have different requirements for classification and chemical labeling.
According to OSHA: "The inconsistencies between the various laws are substantial enough that different labels and safety data sheets must often be used for the same product when it is marketed in different nations. The diverse and sometimes conflicting national and international requirements can create confusion among those who seek to use hazard information."
Under the current system, hazard symbols and statements can be unfamiliar and poorly understood, OSHA explains. Containers may be labeled with such a large volume of information that important statements are not easily recognized.
Furthermore, developing multiple sets of labels and data sheets is a compliance burden for chemical makers, distributors, and transporters. This problem is especially significant for small business.
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Proposed Revisions
Proposed revisions to HazCom to conform to GHS include changes to:
- Chemical classification
- Label content
- Safety data sheet content (mandatory 16 section SDS)
- Employee training on new labels and SDS within 2 years of GHS implementation
There are no proposed changes to:
- Scope and exemptions of HazCom;
- Requirement that all containers be properly labeled
- Safety data sheet distribution and availability in the workplace
- Requirement that all affected employees be trained to recognize hazards and take proper precautions
- Trade secrets (except to include percentage)
Impact of GHS
Health and regulatory affairs consultant Bernard K. Russiello of RC2 Consulting in West Grove, Pennsylvania, calls GHS "a sea change in the way we do things." He believes the biggest impact would be on the way safety data sheets are produced.
For years manufacturers and other businesses that operate beyond U.S. borders have been frustrated in trying to determine what they should include on the data sheet. There are even subtle differences among U.S. states in terms of what information is required.
"If you ship something to Germany or England, it might be considered hazardous there, but would not be considered hazardous here. That’s kind of absurd—how could something be hazardous in Peoria, but not in London?" Russiello wonders.
The confusion has caused problems and disruptions in international commerce and is a significant legal liability for manufacturers and shippers. Adds Russiello, "The GHS system has started to alleviate this."
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Nearly a Decade in the Making
In 2003, the United Nations adopted the Globally Harmonized System of Classification and Labeling of Chemicals. Countries around the world are now adopting GHS into their national regulatory systems.
GHS is made up of building blocks that represent 5 degrees of implementation. Each participating country chooses the degree of implementation according to hazards in sectors such as transportation, consumer, pesticide, and workplace.
Over the past several years OSHA has been moving toward implementation of GHS in the United States. The agency published its rulemaking proposal in September 2009 and held public hearings in 2010.
The revised proposal, which would amend HazCom to align with GHS, has recently been before the Office of Management and Budget for a review. If all goes as planned, GHS could become part of HazCom with the next year, with compliance staggered over a 3-year period.
Tomorrow, we’ll continue to examine how GHS will change HazCom, and how that may affect compliance.