GHS Transition

How GHS Affects Other Chemical Safety Programs

Date First Published on SafetySmart Compliance: May 22nd, 2012
Topics: GHS Transition | HazCom | Hazwoper & Emergency Response | Process Safety Management (PSM) |

Globally Harmonized System MSDS to SDSBy Glenn Demby – Since OSHA published the final GHS rule on March 26, 2012, most of the buzz has been about how GHS affects Hazcom requirements—MSDS and SDS, workplace labels, GHS training for employees and the written Hazard Communication Program (HCP). What has gone largely overlooked are all the chemical safety requirements under other standards affected by GHS. Although they don’t have to be complied with until June 1, 2016, there are 5 “ripple effect” requirements that need to be on your long term planning radar right now.

1. Changes to Chemical Warning Signs

Current Rules: OSHA general industry regulations include roughly 2 dozen standards that require employers to post warning signs for a specific type of hazardous substance. For example, the Asbestos standard requires warning signs in and near “regulated areas” that contain airborne asbestos above PEL levels. (Sec. 1910.1001(j)(3)).

Impact of GHS: GHS doesn’t change the requirement to post a sign. But it does change the system used to classify asbestos and other hazardous chemicals. Chemical importers and manufacturers must re-classify their products by June 1, 2016. Warning signs will then have to be modified to reflect the substance’s GHS re-classification.

What To Do: In addition to asbestos regulated areas, modify other hazard-specific warning signs by June 1, 2016:

[  ] 4-Nitrobiphenyl-regulated areas

[  ] alpha- and beta-Naphthylamine regulated areas

[  ] Methyl chloromethyl ether areas

[  ] 3,3’-Dichlorobenzidine areas

[  ] bis-Chloromethyl ether areas

[  ] Benzidine areas

[  ] 4-Aminodiphenyl areas

[  ] Ethyleneimine areas

[  ] beta-Propiolactone areas

[  ] 2-Acetylaminofluorene areas

[  ] 4-Dimethylaminozobenzene areas

[  ] N-Nitrosodimethylamin areas

[  ] Vinyl chloride regulated areas

[  ] Vinyl chloride hazardous operations

[  ] Inorganic arsenic areas

[  ] Lead areas

[  ] Cadmium areas

[  ] Benzene areas

[  ] Coke oven emissions areas

[  ] Cotton dust areas

[  ] 1-2-Dibromo-3-chloropropane areas

[  ] Acrylonitrile areas

[  ] Ethylene oxide areas

[  ] Formaldehyde regulated areas

[  ] Storage areas for clothing and equipment contaminated with formaldehyde

[  ] Methylenedianiline areas.

2. Changes to Chemical-Specific Warning Labels

Current Rules: Those roughly 2 dozen standards that require employers to post warning signs also require chemical-specific warning labels for containers of the substance.

Impact of GHS: GHS doesn’t change labeling requirements but does affect the format and information of chemical-specific labels.

What To Do: Modify hazard-specific labels for the following substances by June 1, 2016:

[  ] Asbestos

[  ] 4-Nitrobiphenyl

[  ] alpha- and beta-Naphthylamine

[  ] Methyl chloromethyl ether

[  ] 3,3’-Dichlorobenzidine

[  ] bis-Chloromethyl ether

[  ] Benzidine

[  ] 4-Aminodiphenyl

[  ] Ethyleneimine

[  ] beta-Propiolactone

[  ] 2-Acetylaminofluorene

[  ] 4-Dimethylaminozobenzene

[  ] N-Nitrosodimethylamin

[  ] Vinyl chloride

[  ] Inorganic arsenic

[  ] Lead

[  ] Chromium VI

[  ] Cadmium

[  ] Benzene

[  ] Coke oven emissions

[  ] Cotton dust

[  ] 1-2-Dibromo-3-chloropropane

[  ] Acrylonitrile

[  ] Ethylene oxide

[  ] Formaldehyde

[  ] 1, 3 Butadiene

[  ] Methylenedianiline

[  ] Methylene chloride.

3. Ensure Containers of Welding/Cutting Contaminants Have Proper GHS Labels

Current Rules: Containers of dangerous chemicals used in welding and cutting must have a workplace label meeting Hazcom requirements.

Impact of GHS: GHS changes the format and information required in a workplace label. It also requires certain kinds of dangerous welding and cutting chemicals to list additional information not found on the typical label.

What To Do:

From Now Until 1, 2015

  1. Make sure containers of potentially hazardous materials used in fluxes, coatings, coverings and filler metals have a proper GHS workplace label and that all filler metals and fusible granular materials list either of the following messages:

Option 1: Do not use in areas without adequate ventilation. See ANSI Z49.1-1967 Safety in Welding, Cutting and Allied Professions published by the American Welding Society; or

Option 2: CAUTION:

Welding may produce fumes and gases hazardous to health. Avoid breathing these fumes and gases. Use adequate ventilation. See ANSI Z49.1-1967 Safety in Welding and Cutting published by the American Welding Society

  1. Make sure brazing (welding) filler metals containing “significant amounts” of cadmium have either:

Option 1: A label indicating the hazards associated with cadmium including cancer, lung and kidney effects and acute toxicity effects.

Option 2: The following notice:


Do not breathe fumes. Use only with adequate ventilation such as fume collectors, exhaust ventilators or air-supplied respirators. See ANSI Z49.1-1967. If chest pain, cough or fever develops after use call physician immediately.

  1. Make sure brazing and gas welding fluxes containing fluorine compounds have either:

Option 1: A label indicating the hazards associated with fluorine compounds including eye and respiratory tract effects.

Option 2: A cautionary wording to indicate that the chemical contains fluorine compounds. Recommended warning:



This flux when heated gives off fumes that may irritate the eyes, nose and throat.

  • Avoid fumes—use only in well ventilated spaces
  • Avoid contact of flux with eyes or skin
  • Do not take internally

After June 1, 2015

4. Modify Any Other Chemical Safety Programs Affected by GHS

Current Rules: Other OSHA general industry standards require employers that handle certain kinds of chemicals or perform certain operations to adopt written safety programs. To ensure uniformity of chemical safety requirements, these standards incorporate some of the same key terms and requirements used in Hazcom (which, for simplicity’s sake, we’ll refer to as the “Hazcom ancestor definitions”).

GHS Changes: GHS changes several of the key Hazcom ancestor definitions, e.g., “SDS” rather than “MSDS.” Rather than leave the old definitions, OSHA has decided to incorporate the ancestor definitions into the other standards they appear in to match GHS.  While it doesn’t change the substance of requirements (in terms of which employers must have a particular kind of chemical safety program and what that programs must do), this change in definitions will require at least cosmetic changes to the affected program.

What To Do:  By June 1, 2016, make sure you revise all chemical safety programs that use Hazcom ancestor definitions changed by GHS. For example, references to MSDS in the chemical safety provisions of permit required confined space entry programs will need to be changed to SDS—and, of course, employees will actually require access to SDSs rather than MSDSs.

3 other written chemical safety programs will also have to be modified by June 1, 2016 to reflect changes in other key Hazcom ancestor definitions:

  1. Chemical Hygiene Plans for Laboratories (required by the Occupational Exposure to Hazardous Chemicals in Laboratories standard Section 1910.1450(e)) (revised definitions of “health hazard,” “reproductive toxins” and “mutagen”);
  2. Operating Procedures for safe handling of highly hazardous chemicals, e.g., flammable liquids and gases, in operations covered by the OSHA Process Safety Management standard (PSM) (revised flashpoints and definitions of “flammable liquids”  and “flammable gases”); and
  3. Safety and Health Programs for employees in hazardous waste operations and Emergency Response Plans at hazardous waste sites required by the Hazwoper ( Hazardous Waste Operations and Emergency Response standard) (revised flashpoints and definitions of “flammable liquids”  and “flammable gases”).