Globally Harmonization System


Globally Harmonized System and HAZCOM Standard Summary of Rulemaking


OSHA has modified the current Hazard Communication Standard (HCS) to align with the provisions of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).  The adoption of the GHS by OSHA will require OSHA to propose changes to the Hazard Communication Standard (20 CFR 1910.1200).The primary benefit of the GHS is to increase the quality and consistency of information provided to workers, employers and chemical users by adopting a standardized approach to hazard classification, labels and safety data. The 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 the GHS, labels would include signal words, pictograms, and hazard and precautionary statements and safety data sheets would have standardized format

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. 

OSHA's GHS will change the framework and scope of the current HCS with new training and label requirements being adopted within the next 18-36 months, and will improve quality and consistency in the classification and labeling of all chemicals. The harmonized format of the safety data sheets will enable workers to access the information more efficiently. In addition, currently multiple labels and safety data sheets must often be developed for the same product when shipped to different countries, however this will be greatly reduced but not entirely eliminated. The GHS also impacts other agencies such as the Department of Transportation (DOT), Environmental Protection Agency (EPA), and the Consumer Product Safety Commission (CPSC) and which were actively involved in developing the GHS. DOT has already modified their requirements for classification and labeling to make it consistent with international UN transport requirements and the GHS.

Major changes to the HCS: Hazard classification: 

The proposed rule to the Hazard Communication Standard will address changes to the Material Safety Data Sheet (MSDS) and product labeling.  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.  The criteria for classification of hazards and their signal words and precautionary statements and the classification of mixtures are described in the following Appendices to the revised Standard.

  • Appendix  A –Health Hazard Criteria for classification MANDATORY
  • Appendix  B – Physical Hazard Criteria for classification MANDATORY
  • Appendix  F– Guidance for Classification RE carcinogenicity –Non MANDATORY

Labels:

Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided. A summary of the elements of the new Label Requirements and elements are summarized in the MANDATORY Appendix C.

Safety Data Sheets:

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.  A summary of the elements of the new SDS is summarized in Appendix D.

 Information and training: 

The GHS does not address training. However, the proposed HCS will require that workers are trained within two years of the publication of the final rule to facilitate recognition and understanding of the new labels and safety data sheets.

Benefits of the proposed standard:

OSHA estimates that the revised standard will prevent 43 fatalities and 585 injuries and illnesses annually. The annualized monetized benefits associated with these reductions in safety and health risks are an estimated $266 million a year. OSHA estimates additional annualized benefits of $585 million a year from cost reductions and productivity improvements attributable to the proposed revisions. In total, OSHA estimates that the proposed revisions will provide net annualized savings of $754 million a year.

Implementation Schedule

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.  

OSHA Requirements:

·        Employers must train employees within 2 years of final standard release

·        Manufacturers must comply with all requirements within 3 years of final standard release

·        Employers have 3 months to train employees once new chemical information is received from manufacturers.

·        Financial Impact of the proposed HCS:

o       The costs associated with compliance with the proposed revisions to the HCS would generally be incurred by the affected industries as one-time transition costs over the phase-in period of three years.

o       The cost includes reclassification of all chemicals, development of new SDS by chemical manufacturers, additional training of workers on the new label elements and SDS format, and familiarization of the modified HCS standard.

o       Aside from the transition costs, the ongoing annual compliance costs associated with the proposed revisions to the HCS generally are expected to be the same or lower than under the existing standard.

Preparing for the GHS

For Preparers of labels and SDS

  • Receive training on classification requirements
  • Review current data for classifications
  • Identify gaps between old and new classifications
  • Review testing protocols
  • Develop new labels and SDS
  • Communication to end user of SDS and labels

For Health & Safety Professionals

  • Update Hazard Communication Programs
  • Review all new GHS SDS for new hazards
  • OSHA will require training on the new
    • labels & SDS
    • changes in hazards
    • New terminology & symbols
    • Updated training for chemical standards (e.g. lead, hexavalent chromium, etc.)
  • Prepare training & informational materials
  • Assess workplace controls based on new hazards
  • There may be new hazards for old chemicals as new classifications are made.
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