What is the Globally Harmonized System and Why Do I Care?
On September 12, 2006, OSHA published an Advanced Notice of Proposed Rulemaking in the Federal Register to seek comments on how to implement the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS has been adopted by the United Nations to facilitate international trade by developing consistency between laws in different counties.
But since 2006 this proposed rule has seen little action. Under the Obama administration that may change. In a December 2008 meeting between the Obama transition team and the ASSE (American Society of Safety Engineers) the ASSE is recommending that this rule move forward. ASSE has stated publicly “OSHA can help U.S. companies save jobs. Rulemaking on global harmonization of US hazard communications (GHS) will help U.S. employers compete across the globe and should be completed. An engaged OSHA can help ensure OSH issues are addressed fully in US trade agreements”.
The adoption of the GHS by OSHA will require OSHA to propose changes to the Hazard Communication Standard (20 CFR 1910.1200). It is important to realize that GHS is not a regulation or standard, but is a system for standardizing and harmonizing the classification of chemicals internationally. Its purposes are to create a logical and comprehensive approach to defining health, physical, and environmental hazards; to create a classification process that uses data on chemicals with comparison with the define hazards criteria; and to standardize the communication of those hazards.
The GHS was developed because the global chemical business generates more the $17 trillion per year. Just in the US alone, chemicals are more than a $450 billion business and exports are more that $80 billion per year. While laws are similar, they are different enough to require multiple labels for the same product. It is estimated that there are over 100 different types of Hazard Communication Standards for global products. For large global companies, labeling is costly and time consuming. The various global regulations are complex and expensive and can prevent medium and small companies from entering into the global market. In the US alone, chemical manufactures, importers, suppliers, and users must comply with regulations from the CSPC, OSHA, DOT and EPA.
The proposed rule to the Hazard Communication Standard will address changes to the Material Safety Data Sheet (MSDS) and product labeling. In the US, workplace labels are “performance oriented” and result in labels that have product identity, hazard statements, and supplier information, but tend to be confusing. Some global US companies follow the voluntary ANSI Z129.1 Precautionary Labeling Standard that includes several of the core elements to GHS. The GHS label elements are Symbols (hazard pictograms) that show health, physical, and environmental hazards; Signal Words such as “Danger” or “Warning”; and Hazard Statements that would include standard phrases assigned to a hazard class and category. All symbols, signal words, and hazard statements have been standardized and assigned to a specific hazard category and class.
Under the GHS, the MSDS will become the SDS (Safety Data Sheet), which will have 16 required sections. A few of the new subjects that will be covered include Ecological, Transport Information, and Disposal Considerations. All three sections will have detailed information; for example, under the Disposal Considerations, the SDS will include a description of waste residues and information on the safe handling and methods of disposal, including any contaminated packaging.
The proposed changes to the Hazard Communication Standard will take time. For companies that are interested in entering into the global market or companies that are currently in the global market, the intent is to help streamline the process of providing information and to reduce the redundancies of all the various required labels resulting in less cost and time.
Click here to see “A Guide to The Globally Harmonized System of Classification and Labeling of Chemicals (GHS)”.
Ann Pierce Towles is the President and a Safety Consultant for Advanced Safety & Health, LLC and is a Louisville, KY based Safety Consultant. She can be reached at atowles@advancedsafetyheatlh.com or (502)240-6910
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