Much of the “buzz” in the US Regulatory Community this year, at least as regards the area of Hazardous Communication, has been about a three letter acronym that may still be a mystery to many: “GHS.” What does this acronym stand for, and how will it affect you and your company as it relates to hazard communication?
The United States Occupational Safety and Health Administration (OSHA) issued the first Hazard Communication Standard (HCS) as far back as 1983, to standardize such information presentation in the United States. In its preamble, the initial American rule called for international agreement on standards to assist in the, “broadest recognition of the identified hazards.” OSHA has progressively updated and modified the standard through the years to reflect the advances of technology, industrial hygiene, risk management, and health concerns over the intervening decades. The US standard often did and in some ways still does serve as a de facto global standard, due to the position of dominance the US has enjoyed in the global trade community. However, even as early as 1992 it was recognized that a more standardized system based on globally recognized standards and using more “user-friendly” information and pictorially based ways of presenting it would be of benefit. Thus was born the Globally Harmonized System—GHS.
In 1992 the United Nations held a “Conference on Environment and Development” in Rio De Janeiro, Brazil, which among other things called for “A globally harmonized hazard classification and compatible labeling system, including Material Safety Data Sheets (MSDS), and easily understandable symbols, should be available, if feasible, by the year 2000.” Needless to say, this deadline has stretched a little! However, this was the genesis event of the GHS movement. In the intervening years, GHS has slowly but surely worked its way into much of the international trade structure, especially in the European Union (EU). GHS harmonization has been an ongoing and much further advanced project in the transportation of dangerous goods, with the USDOT 49 CFR already significantly harmonized with agreed international standards. However, until now, the GHS has had little impact on the OSHA directed hazard communication system (HCS) rules. That has changed!
For many years the standard way of communicating hazard information in the United States has been through the use of and training in the various types of non-specified hazard communication labels (think the common NFPA 704 format, for example), and the ubiquitous Material Safety Data Sheet, or MSDS. The modification of the current HCS to a GHS based system under the new OSHA rule (Docket No. OSHA-H022K-2006-0062) RIN 1218-AC20, promulgated in the Federal Register on March 26, 2012) implements significant change right from the beginning. Note the changed purpose invoked by the modified rule:
“…to ensure that the hazards of all chemicals produced or imported are classified, and that information concerning the classified hazards is transmitted to employers and employees. The requirements of this section are intended to be consistent with the provisions of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), Revision 3.” (Ref: US 29 CFR 1910.1200)
OSHA has fully embraced the GHS based system and is explicitly directing its implementation across the board in terms of Hazard Communication in the workplace. As with any new or revised Federal Regulation, there is a timeline for compliance with its varying aspects. Here are the dates OSHA has set forth as required for implementation:
May 26, 2012 – New Standard is made effective
December 1, 2013 – Employers must have employees trained regarding new label elements and safety data sheet formats.
June 1, 2015 – Chemical manufacturers, importers, distributors, employers to be in compliance with all modified provisions of the new HCS with the following exceptions:
December 1, 2015 – Distributors shall not ship containers not labeled in compliance with the new HCS.
June 1, 2016 – Any alternative workplace labeling shall be updated to conform with the HCS.
During the transition period, it is allowable to conform your label’s format with either the HCS as promulgated on 10-11-2011, or to the updated standard. For more specific guidance, you should consult the standard itself. However, a clear directive exists as to the requirement to train employees in both the new label elements and in the new Safety Data Sheet (SDS) format no later than December 1st, 2013—a mere two weeks away!
Labelmaster offers a full line of training products to assist companies in meeting this rapidly approaching deadline. However, regardless of how it is accomplished, do not place your company at risk of non-compliance—schedule and conduct your training ASAP!
To see Labelmaster’s full line of GHS training products, see: http://www.labelmaster.com/shop/safety/ghs-hazcom-products