Globally Harmonized System (GHS) Effects?
On September 30, 2009, OSHA announced a proposed rule to align current Hazard Communication (HazCom) requirements with the United Nation’s (UN) hazardous material labeling system, referred to as the Globally Harmonized System (GHS). This announcement has left many wondering, “What will I have to change to remain in compliance?”
OSHA has yet to define specific requirements regarding GHS alignment, but after reviewing the elements of GHS and current HazCom requirements, some assumptions can be made. HazCom has five key requirements; written program, hazardous material inventory, employee training, chemical labeling and material safety data sheets (MSDS). Aligning HazCom to GHS standards will primarily effect labeling and MSDS components of HazCom. MSDS (or SDS) changes will require more detail then most MSDS currently provide, but the primary effects will be on manufacturers who will have to revise current documents (and possibly conduct additional testing to quantify hazard risks). The impact on MSDS users will primarily be limited to updating their document files. Labeling changes could require a bit more.
GHS labeling, like HazCom, requires a chemical name that aligns to a Safety Data Sheet (SDS, basic equivalent to MSDS), but the similarities end there. GHS uses symbols (pictograms), signal words, hazard statements and precautionary statements to convey physical and environmental hazards. Hazards are quantified in 31 classes and 81 hazard categories. Tables detail the labeling requirements for each hazard category. Needless to say, GHS labeling will affect how chemical manufacturers must label materials offered for sale, but provisions in GHS states; “Products falling within the scope of GHS will comply to GHS at the point where they are supplied to workplace, and that label should be maintained on the supplied container in the workplace….However, the competent authority (OSHA) can allow employers to use alternate means of giving workers the same information in a different written or displayed format….”* This provision should allow for current secondary container labeling systems to remain after GHS implementation.
Employee training on how to understand labels will be more involved under GHS, but hopefully our competent authority (OSHA), will provide guidance that will allow us to maintain our current secondary container labeling and minimize the need for safety management system re-design as a result of GHS.
*From 1.4.10.5.5.1 of Introduction
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