The GHS Rule and How It Changes HazCom

Date First Published on SafetySmart Compliance: March 26th, 2012
Topics: GHS Transition | HazCom |

On March 26, 2012, OSHA published the final GHS rule in the Federal Register. 90 days from now, May 25, 2012, the GHS rule officially takes effect. In the coming days, weeks and months, SafetySmart Compliance will explain the rule and the things you’ll have to do to comply with it. But first, we’re going to give you the big picture of what GHS is all about.

The GHS Conundrum: Same Hazard(s), Different Rules

In the US, millions of workers are exposed to hazardous substances at work. So are workers in Canada, Mexico, Europe, Asia, South America and all over the world. The good news is that most of the world’s industrialized nations have adopted regulations to protect workers against these hazards; the bad news is that the rules in each country are different. These national differences compromise both safety and commerce.

Example: Brazil and the US both require chemical manufacturers to mark their products with warning labels. But US OSHA requirements are stricter than equivalent rules in Brazil. Accordingly, a US company can’t import those products from Brazil unless a new label is created that meets US OSHA requirements.

GHS, short for Global Harmonized System (GHS), is an international system created by the United Nations to eliminate national differences in workplace chemical hazard regulations. In developing GHS, the UN reviewed existing national and multinational systems and formed a nucleus of a new system around their features. GHS is based on:

  • Hazcom and its Canadian cousin, WHMIS (short for Workplace Hazardous Materials and Information System);
  • The EU (European Union) system for preparation, classification and labeling of substances; and
  • The UN Transportation of Dangerous Goods system for communicating hazards.

The end result of having a uniform system will be greater safety and fewer barriers to commerce, the UN claims.

GHS Means Hazcom Has to Change

Having a uniform international standard of communicating workplace chemical hazards should go a long way toward improving both safety and commerce. But as the old saying goes, you can’t make an omelet without breaking some eggs. To transition from national regulation to GHS, each participating country has to change its rules. The new GHS Rule is OSHA’s effort to rework Hazcom to fit GHS.

The pillars of the Hazcom system—hazard classification, i.e., identifying and grouping substances by their hazards, and hazard communication, i.e., ensuring exposed workers know about the chemical hazards they face—will remain in place. But GHS does make significant changes to how the system operates. The 5 key requirements:

1. Re-Classification of Hazardous Substances

Hazcom currently requires companies that manufacture, import or distribute hazardous chemicals to classify their products. Under GHS, these companies will have to re-classify their products using hazard classification criteria and the following 4 sub elements:

  • Health hazards;
  • Environmental hazards;
  • Physical hazards; and
  • Mixtures.

Deadline: June 1, 2015.

2. Replace MSDS with SDS

Companies that manufacture, import or distribute hazardous substances for sale in the US will also have to keep creating a Material Safety Data Sheet (MSDS) that lists required information about a hazardous substance. But while the basic MSDS will remain in use, under GHS, it will be called an SDS, or Safety Data Sheet. (The “M” is being dropped.) More significantly, the substance of the SDS is changing. The new SDS must:

  • Use a specific format/design to present the required information; and
  • List different kinds of information from what was required in the MSDS.

HAZCOM V. GHS COMPARISON

HAZCOM MSDS

GHS-SDS

SAFETY DATA SHEET REQUIREMENTS

MSDS must list:

The identity of the hazardous chemical or mixture of chemicalsPhysical and chemical characteristics

The physical hazards including the potential for fire, explosion and reactivity;

Health hazards of the hazardous chemical, including signs and symptoms of exposure

The primary route(s) of entry;

The chemical’s PEL, ACGIH TLV and any other exposure limit used

Whether the chemical is listed in the National Toxicology Program Annual Report on Carcinogens or has been found to be a potential carcinogen in the International Agency for Research on Cancer Monographs, or by OSHA;

General precautions for safe handling and use;

General control measures;

Emergency and first aid procedures;

Date of preparation of the MSDS or the last time it was changed;

Name, address and phone number of the manufacturer, importer, employer or other responsible party

The information in a safety data sheet (SDS) should be presented using the following 16 headings in the following order:1) Identification2) Hazard identification

3) Composition/information on ingredients

4) First aid measures

5) Fire-fighting measures

6) Accidental release measures

7) Handling and storage

8) Exposure controls/personal protection

9) Physical and chemical properties

10) Stability and reactivity

11) Toxicological information

12) Ecological information

13) Disposal considerations

14) Transport information

15) Regulatory information

16) Other information

As before, employers will have to ensure that each hazardous substance has an appropriate SDS and keep all SDSs in the workplace where they’re accessible to employees. But effective June 1, 2016, the MSDS must be replaced with the newfangled SDS.

Deadlines:

  • June 15, 2015: Re-Classification and preparation of new SDSs must be complete; and
  • June 1, 2016: Employers must replace all MSDSs with new SDS.

3. Replace Hazcom Labels with GHS Labels

Companies that manufacture, import or distribute hazardous substances will still have to prepare labels warning of the dangers of their products. And downstream employers will still have to ensure each container of hazardous substance has an appropriate label. But as with the MSDS, the new GHS  label must follow a specific format and display different kinds of information.

HAZCOM V. GHS COMPARISON

HAZCOM

GHS

LABEL REQUIREMENTS

Labels must list:[ ] The identity of the hazardous chemical(s), i.e., its chemical name under IUPAC nomenclature, or common name (code name, code number, trade name, brand name or generic name) as listed on the MSDS; and[ ] Appropriate hazard warnings or words, pictures, symbols or a combination, that provide:

* At least general information about the chemical’s hazards; and

  • That, in conjunction with the other information immediately available to employees under the hazard communication program, furnish employees specific information about the chemical’s physical or health hazards.

[ ] Employers must ensure that labels and other warnings are:

[ ] Legible;

[ ] In English—or other languages employees speak to the extent that information is also listed in English, e.g., as opposed to graphically; and

[ ] Prominently displayed on the container, or readily available in the work area through each shift.

A GHS label requires the following information:1) Signal words2) Hazard statements

3) Precautionary statements and pictograms

4) Product identifier

5) Supplier information

All hazard pictograms should be in the shape of a square set on a point.

The hazard pictograms, signal word and hazard statement should be located together on the label.

In addition to its use on pictograms, colour can be used on other areas of the label to implement special labelling requirements.

 

4. Provide Training to Employees

Employers must ensure that all affected employees know how to read and use the new GHS labels and SDSs. The deadline for training was Dec. 1, 2013—24 months before the new labels and SDSs have to be used.

5. Effect of GHS on Other Programs

Many of the requirements in the Hazcom standard are incorporated into other OSHA standards, e.g., chemical safety for confined space entry or hazard assessment for bloodborne pathogens. As a result, may require you to implement changes to other health and safety programs. For employers, dealing with this “ripple effect” may prove the trickiest part of complying with GHS.

Conclusion

The transition to GHS will unfold in stages and not be completed until June 1, 2016.

DEADLINE

ACTION

Dec. 1, 2013

Employers must have trained employees to use new GHS labels and SDSs

June 1, 2015

Companies that manufacture, import or distribute hazardous chemicals must re-classify products according to GHS criteria

June 1, 2015

Companies that manufacture, import or distribute hazardous chemicals must replace MSDS with new SDS

Dec. 1, 2015

Companies that manufacture, import or distribute hazardous chemicals must replace labels with new GHS labels

June 1, 2016

Employers must modify their Haz Communication Program and use new GHS labels and SDSs

 

 
 
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