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Globally Harmonized System (GHS)

Quick Tips #374

The much-anticipated revision to the Occupational Safety and Health Administration’s (OSHA’s) Hazard Communication Standard (29 Code of Federal Regulations (CFR) 1910.1200) was published in the Federal Register on March 26, 2012 (with an effective date of 60 days thereafter). One of the most significant changes in this revision was OSHA’s adoption of portions of the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

The revised standard, HazCom 2012, is expected to affect every U.S. workplace with exposure to hazardous chemicals. These changes will ultimately impact more than five million facilities and over 40 million workers. OSHA anticipates the revised standard will prevent 43 fatalities and 521 injuries and illnesses annually, with a net annualized savings of over $507 million.

History

Since 1985, the Hazard Communication Standard (HCS) has been the primary tool for providing employers and employees with information about the chemical hazards in their workplaces. The performance-orientated standard has allowed chemical manufacturers and importers to convey information on labels and material safety data sheets (MSDSs) in whatever format they desire. While the information has been helpful, a more standardized approach to classifying the hazards and conveying the information will more effectively protect workers.

Born out of the United Nations’ Earth Summit of 1992, GHS is an international approach to the classification of hazardous chemicals and the communication of hazards to workers via labels and safety data sheets (SDSs). It is not a law; rather it is a system with components that countries can adopt into their own systems. GHS affects everyone in the chemical lifecycle, with special responsibilities for chemical manufacturers and employers that handle, use and store hazardous materials.

Unchanged Provisions

The parts of the HCS not related to the GHS—basic framework, scope and exemptions—have remained largely unchanged.

There have been some minor terminology modifications to align the revised HCS language with that used in the GHS. For example, the term “hazard determination” has been changed to “hazard classification” and “material safety data sheet” (MSDS) has changed to “safety data sheet” (SDS).

Major Changes

The three major areas of change are hazard classification, shipped container labels and safety data sheets (SDSs).

The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards and for the classification of mixtures. These will help ensure that evaluations of hazardous effects are consistent across the board and shipped container labels and safety data sheets (SDSs) are therefore more accurate.

Chemical manufacturers and importers must provide a harmonized shipped container label that has six standardized elements for classified hazards:

  • Product Identifier – Must match product identifier on safety data sheet (SDS).
  • Manufacturer Contact Information – Including name, phone number and address.
  • Hazard Pictograms – There are nine pictograms used to convey the health, physical and environmental hazards. HazCom 2012 requires eight of these pictograms; the exception being the environmental pictogram as environmental hazards are not within OSHA’s jurisdiction. These pictograms will have a black symbol on a white background with a red diamond frame (see illustrations below):

  • Signal Word – Either DANGER or WARNING depending upon hazard severity.
  • Hazard Statements – Standardized sentences that describe the level of the hazards.
  • Precautionary Statements – Steps employees can take to protect themselves.

The signal word, hazard statement(s) and pictogram(s) must be located together on the label (29 CFR 1910.1200(f)(3).

With this revision OSHA is continuing to give employers the flexibility to determine what types of workplace labels they will use. Employers have the ability to choose to label workplace containers either with the same label information that the chemical manufacturer or importer used on the shipped containers or with alternate labels that meet the requirements of the standard.

Safety data sheets (SDSs) remain the backbone of HCS. With this revision, there is a name and formatting change. The M is dropped from MSDS and more importantly a standardized 16-section format with a required ordering of sections is mandatory. The sections, in order, are:

  1. Identification
  2. Hazard(s) Identification
  3. Composition/Ingredient Information
  4. First Aid Measures
  5. Fire-Fighting Measures
  6. Accidental Release Measures
  7. Handling and Storage
  8. Exposure Control/Personal Protection
  9. Physical & Chemical Properties
  10. Stability & Reactivity
  11. Toxicological Information
  12. Ecological Information
  13. Disposal Considerations
  14. Transport Information
  15. Regulatory Information
  16. Other Information

To be compliant, a safety data sheet (SDS) needs all 16 sections; however, OSHA will not be enforcing sections 12 to 15, which fall outside the agency’s jurisdiction.

Effective Dates

Employers were required to train their workers on the new shipped container label elements and safety data sheet (SDS) format by Dec. 1, 2013. Chemical manufacturers, importers, distributors, and employers were required to comply with all modified provisions of the final rule by June 1, 2015. However, distributors may ship products labeled by manufacturers under the old HCS until Dec. 1, 2015. By June 1, 2016, employers must update alternative workplace labeling and hazard communication programs as necessary, and provide additional worker training for new identified physical and health hazards.

The table below summarizes the phase-in dates required under HazCom 2012:

Effective Completion Date

Requirement(s)

Who

December 1, 2013

Train employees on the new label elements and safety data sheet (SDS) format.

Employers

June 1, 2015 December 1, 2015

Compliance with all modified provisions of this final section, except after Dec. 1, 2015 distributors must not ship containers labeled by the chemical manufacturer or importer unless it is the modified GHS label

Chemical manufacturers, importers, distributors and employers

June 1, 2016

Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

Employers

Transition Period to the effective completion dates noted above

May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both

Chemical manufacturers, importers, distributors, and employers

During the transition period, all chemical manufacturers, importers, distributors, and employers may comply with either the current, revised or both 29 CFR 1910.1200 standards.

Effective Dates Update

On Feb. 9, 2015, OSHA issued an internal memorandum describing the agency's enforcement position on the HazCom 2012 June 1st and Dec. 1st, 2015 effective dates. The memorandum is directed at chemical mixture manufacturers and importers only. Extensions of up to six months may be given on an inspection-by-inspection basis to those who have exercised reasonable diligence and good faith to obtain the required classification and safety data sheet (SDS) information from their raw material suppliers.

When a chemical mixture manufacturer or importer cannot comply with the June 1, 2015 effective date, there may be distributors that are consequently unable to comply with the Dec. 1, 2015 compliance date. In the limited situations described in the memorandum, distributors will be allowed to ship chemicals labeled with old HCS compliant labels until Dec. 1, 2017.

Summary

When HCS first took effect in 1985, employees got the right to know what their potential exposure to hazards might be. With this revision, employees not only know about the potential hazards, they also have a better understanding of what the warnings mean, what to do if exposed and how to protect themselves. All employees will be provided with the same information in the same format.

Commonly Asked Questions
 
Q. Are employers required to maintain two sets of labels and safety data sheets (SDSs) during the transition period?
A: No. During the transition period, all chemical manufacturers, importers, distributors and employers may comply with either the existing HCS or the revised HazCom 2012, or both. During this time, hazard communication programs will go through a period where labels and safety data sheets (SDSs) under both standards will be present. OSHA considers this acceptable. Two sets of labels and safety data sheets (SDSs) are not required.
 
Q: Why must training be conducted prior to the compliance effective date?
A: Many countries are in the process of implementing GHS. Therefore, it is possible that workplaces may begin to receive GHS-compliant labels and safety data sheets (SDSs) long before Dec. 1, 2015. When employees begin to see the new labels and safety data sheets (SDSs), they must understand the information that is being provided.
 
Sources

OSHA Website – HazCom 2012 https://www.osha.gov/dsg/hazcom/index.html
Harmonized System of Classification and Labeling of Chemicals (GHS)–The Purple Book
Enforcement Guidance for the Hazard Communication Standard’s (HCS) June 1, 2015 Effective Date

(Rev. 6/2015)


Find even more information you can use to help make informed decisions about the regulatory issues you face in your workplace every day. View all Quick Tips Technical Resources at www.grainger.com/quicktips.

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Please Note:
The content in this newsletter is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific compliance questions should refer to the cited regulation or consult with an attorney.


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