Chemicals

Are You Ready for GHS Changes to Hazard Communication?

The United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) is revamping the way the entire world classifies, labels, and communicates information about chemical hazards. In the United States, that means plenty of changes are on tap for anyone required to comply with the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (HCS).

The GHS is a cooperative international effort to create one consistent, standardized system for chemical hazard communication associated with the thousands of chemicals in use worldwide everyday. The goal is to eliminate confusion associated with different countries using a variety of different symbols, formats, and processes so that everyone is familiar with and uses the same information for the same chemicals.

To incorporate the GHS, OSHA has made changes to the HCS in three main areas, as follows:

Hazard classification–Hazard definitions will now provide specific criteria for classification of mixtures and health and physical hazards to ensure that evaluations of hazardous effects are consistent across manufacturers, and that there is accuracy in labeling and safety data sheets (SDSs) (formerly material safety data sheets (MSDSs) in the United States).

This hazard classification approach differs from the former HCS performance-oriented approach by providing specific criteria for each health and physical hazard, with detailed instructions for evaluation and by establishing  both hazard classes and categories for many of the health hazards covered. General provisions for hazard communication are included in the revised rule and applicable criteria have been added in Appendixes A and B at https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099.


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Labels–New labels required of chemical importers and manufacturers must include a harmonized signal word, pictogram, and hazard statement for each hazard class and category; precautionary statements must also be provided.

Signal Words are defined as either “danger” or “warning” and are used to establish the relative severity of the hazard alerts, with “danger” used for the highest level of severity and “warning” used for less severe hazards.

Pictograms include symbols, borders, background patterns, and colors used to convey hazard information. Each pictogram is essentially a red-framed square diamond shape with a white background containing a symbol. The GHS provides nine pictograms; however, the HCS requires only eight of them. HCS pictograms are available for download at https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099.

Hazard Statements are assigned by hazard class and category and describe the nature of the chemical hazard(s) and the degree of hazard, if appropriate.

Precautionary Statements are the recommended measures to take in the event of an exposure or improper handling or storage of a hazardous chemical.

Although label preparers must now include the identity of the chemicals and the appropriate hazard warning, no single prescribed label format is required.

In the area of workplace labeling, OSHA is allowing employers to choose either to use the original labels or alternative labels from such organizations as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS), as long as they are consistent with the revised HCS and do not contain conflicting hazard warnings or pictograms.


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Safety Data Sheets–A single 16-section format is now required. However, the information contained therein is essentially the same as in the original 1994 Hazard Communication Standard although OSHA now requires SDS information be provided using the following headings in this specific sequence:

Section 1 – Identification
Section 2 – Hazard(s) Communication
Section 3 – Composition/Information on Ingredients
Section 4 – First-Aid Measures
Section 5 – Fire-Fighting Measures
Section 6 – Accidental Release Measures
Section 7 – Handling and Storage
Section 8 – Exposure Controls/Personal Protection
Section 9 – Physical and Chemical Properties
Section 10 – Stability and Reactivity
Section 11 – Toxicological Information
Section 12 – Ecological Information
Section 13 – Disposal Considerations
Section 14 – Transport Information
Section 15 – Regulatory Information
Section 16 – Other Information, including date of preparation or last revision

Although Sections 12 to 15 are mandatory, OSHA will not enforce the content because it is within the jurisdiction of other federal agencies. Additional SDS information is available at https://www.osha.gov/dsg/hazcom/SDSitems.html.