GHS – Globally Harmonized System

GHS means changes for manufacturers, transporters and users of hazardous chemicals in the United States. Safety Data Sheets, labels and chemical classification will be revamped.

During late 2011 and early 2012, OSHA implemented new regulations on chemical safety data which have been adopted from GHS standards set forth by the United Nations as a way to bring into conformity the chemical regulations and standards of different countries. The UN’s GHS was an international attempt to get everyone on the same page. The hope is that every country will integrate the GHS concept into their own chemical management systems with the goal of making the international sale and transportation of hazardous chemicals easier, as well as, making workplace conditions safer for all employees exposed to chemical hazards.

The U.S. officially adopted the GHS on March 26, 2012. OSHA’s adoption is actually a revision of the HCS (Hazard Communication Standard) to align with the GHS. OSHA calls this revision, “HazCom 2012”.  HazCom 2012 is expected to affect every U.S. workplace with exposure to hazardous chemicals, ultimately covering over 5 million facilities and over 40 million workers.  Compliance deadlines also affect chemical manufacturers and distributors.

Employers, manufacturers and distributors should be aware of the following compliance dates:

 December 1, 2013 — Employees must be trained on how to read the new labels and SDS (Safety Data Sheet) formats. OSHA makes this the first priority because GHS-formatted documents are already making their way into U.S. workplaces and can be very different from what workers are used to seeing. OSHA is calling this standard the “Right to Understand.”

June 1, 2015 – Manufacturers and Distributors must comply with the revised HCS. This includes reclassifying chemicals and producing GHS formatted labels and SDS’s. Distributors get an additional 6 months to distribute old inventory already labeled.

December 1, 2015 – Distributors must fully comply with revised HCS. (Grace period ends.)

June 1, 2016 – Employers must fully comply with revised Hazard Communication Standard, the Hazcom 2012, complete training of employees on newly identified hazards and any updates to all new Safety Data Sheets and uniform labeling systems.

The most noticeable changes brought by GHS for most organizations will be changes to hazard classification, labels, safety data sheets, information and training.

• Hazard classification:  The will be a new system and set criteria for classifying the hazardous properties of chemicals. This classification system offers very specific instructions as to the classification of any and all health and physical hazards in additional to mixtures’ classifications.
• Labels:  Under the new labeling system all chemical importers and manufacturers will be expected to utilize labels that include a signal word, pictogram and hazard statement from the new harmonized system. However, it is unlikely OSHA will require chemical manufacturers to produce SDSs for discontinued products, so employers will be responsible for determining GHS labels for older products.
• SDS: Safety Data Sheets will have a 16-section format. Communicating hazard information in a prescribed and uniform way on labels and safety data sheets. One of the key challenges will be an employer working with their chemical product vendors to produce the SDSs in a timely manner.
• Information and Training: Employees will need to be educated on the label and MSDS changes to SDS due to the updated product classifications, pictograms, signal words and precautionary statements. Written programs will need updated to include changes to labeling, SDS communication and employee training.  Training employees and updating the written program may require significant resources and should occur as soon as the organization begins its GHS transition.

OSHA is only modifying those requirements of the HCS that must be changed to align with the GHS. The main agenda will remain the same. Chemical manufacturers and importers will continue to be responsible for providing information about the identities and hazards of the chemicals they produce or import. All employers with chemicals in their workplaces will continue to be responsible to have a hazard communication program and provide information to their employees about their hazards and protective measures.

Under HCS, variations between national and international laws create a regulatory and compliance disaster that disrupts commerce and compromises safety. The discrepancies burden manufacturers, importers, distributors and employers. By standardizing the components of various systems, the GHS will protect workers, consumers, emergency responders and the public by creating a comprehensive system through which chemical hazards are identified and communicated to all who are potentially exposed. Furthermore, global adoption of GHS is expected to reduce costs and inefficiencies associated with the international trade of chemicals.

The biggest costs to businesses will be to:

• Re-classify all chemicals using GHS criteria
• Re-author all Safety Data Sheets in GHS formats and produce GHS formatted labels
• Employers training workers on how to read new label and SDS elements, and newly identified hazards

The benefits to business include:

•  OSHA anticipates the revised standard will prevent 43 fatalities and 585 injuries annually, with a net annualized savings of over $500 million a year.
•  A safer work environment and improved relations with employees,
• An increase in efficiency and reduced costs from compliance with hazard communication regulations,
•  Improved corporate image and credibility.

The benefits to workers and the public include:

• Improved safety for workers and others through consistent and simplified communications on chemical hazards and practices to follow for safe handling and use,
• Greater awareness of hazards, resulting in safer use of chemicals in the workplace and in the home.

GCG Risk Management Clients receive webinars, tool box talks and PPTs on this subject. For further assistance or comments clients may contact Elsie Tai at Elsie.tai@gcgriskmanagement.com, 212-431-3000, ext. 8456 and Rudolph Lu at rudolph.lu@gcgriskmanagement.com, 518-370-3303 ext. 8816.

If you are interested in receiving this type of assistance as part of your Workers Compensation Program request a quote.  If you are interested in obtaining Health and Safety Consulting Services request a quote.