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Aligning the Hazard Communication Standard to the GHS

OSHA's recently adopted new standard, the Globally Harmonized Standard (GHS), has a training compliance date of December 1, 2013. Following are some facts you should know about the GHS:

Proposal to modify the HCS to align with the GHS: OSHA is proposing to modify the current Hazard Communication Standard (HCS) to align with the provisions of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The HCS requires that chemical manufacturers and importers evaluate the chemicals they produce or import and provide hazard information to downstream employers and workers by putting labels on containers and preparing safety data sheets. Under the current HCS, all employers must have a hazard communication program for exposed workers, including container labels, safety data sheets, and training.

GHS: 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 a standardized format. This system was agreed on at an international level by governments, industry, and labor, and adopted by the UN in 2002 with a goal of 2008 for implementation.

Why modify the HCS: OSHA's proposal to adopt the GHS will not change the framework and scope of the current HCS but will help ensure improved quality and more consistency in the classification and labeling of all chemicals. This will enhance worker comprehension, resulting in inappropriate handling and use of 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. This creates a major compliance burden for chemical manufacturers and those involved in international trade, increasing the cost of providing hazard information. The adoption of GHS will minimize this burden.

Major proposed changes to the HCS:

  • Hazard classification: Provides specific criteria for the classification of health and physical hazards, as well as the classification of mixtures.
  • 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.
  • Safety Data Sheets: This Will now have a specified 16-section format.

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.