GHS is finally here…almost!

OSHA’s recently published the final rule to adopt the Global Harmonization System (GHS), which according to them will not change the framework and scope of the current Hazard Communication Standard (HCS) but will help ensure improved consistency in the classification and labeling of all workplace chemicals. GHS provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets. Under GHS, labels would include signal words, pictograms, and hazard and precautionary statements and safety data sheets would have standardized format. This system was agreed on at an international level by governments, industry, and labor, and adopted by the UN in 2002 with a goal of 2008 for implementation.

According to OSHA this change will affect over 40 million workers in about 5 million workplaces. The change to GHS was a long time in coming and necessary as the global chemical business is more than a $1.7 trillion per year enterprise. In the U.S., chemicals are more than a $450 billion business and exports are greater than $80 billion per year. Existing laws and regulations are currently different enough to require multiple labels for the same product both within the U.S. and in international trade and requiring multiple safety data sheets for the same product in international trade. Several U.S. regulatory agencies and various countries also have different requirements for hazard definitions as well as for information to be included on labels or material safety data sheets. GHS effectively establishes agreed hazard classification and communication provisions with explanatory information on how to apply the system worldwide.

It is important to remember that GHS itself is not a regulation or a standard. The GHS Document (referred to as “The Purple Book”) is simply a mechanism to meet the basic requirements of any hazard communication system, which is to decide if the chemical product produced and/or supplied is hazardous and to prepare a label and/or Safety Data Sheet as appropriate. OSHA’s HCS will incorporate the needed elements of GHS to make international trade and commerce easier.

Of course with change comes the need for training. Employers will need to have trained their employees regarding the new label elements and safety data sheets format by December 1, 2013 with full implementation of GHS taking place December 1, 2015.

OSHA has published a side-by-side comparison of the current HCS with the new GHS elements incorporated which can be found here.  If you need more information or training contact me,  I’d be happy to help you find the needed resources.

4-Year GHS Compliance Transition Period

May 25, 2012 to November 30, 2013
All employers that use, handle, store chemicals
Train employees how to read and interpret chemical labels and (material) safety data sheets in compliance with either:

  • The pre-GHS HazCom standard for labels and MSDSs; or
  • The revised HazCom standard with GHS for new-style labels and SDSs; or
  • Both old and new requirements at the same time
December 1, 2013
All employers that use, handle, store chemicals
Train employees about the new GHS-compliant chemical labels and SDSs.
June 1, 2015
Chemical manufacturers, importers, distributors
Comply with all the requirements of the GHS rule, including classify chemical hazards and prepare new labels and SDSs. Distributors have until December 1, 2015 to comply with the shipping requirements for GHS-compliant labels.
December 1, 2015
Chemical manufacturers, importers, distributors
All shipments of chemical containers must include the new GHS-compliant label (signal word, pictogram, hazard statement, and precautionary statement).
June 1, 2016
All employers that use, handle, store chemicals
Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.
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