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Are You Ready for OSHA's GHS Adoption

Posted on December 06, 2011 by James Griffin

Q. How will the Globally Harmonized System (GHS) affect my HazCom Standard communications?
A. The Hazard Communication (HazCom) Standard is a rule designed by the Occupational Safety and Health Administration (OSHA) to prevent or minimize employee exposure to hazardous chemicals. As part of that standard, applicable employers must create a HazCom program to keep their employees safe [29 CFR 1910.1200]. 
At a minimum, this program must include:
  • A hazard determination, 
  • A labeling system, 
  • A system for making Material Safety Data Sheets (MSDSs) available, and 
  • Training. [29 CFR 1910.1200(b)] 
Over the past several years, the Unied Nations has worked to create a Globally Harmonized System of Chemical Classification and Labeling (GHS). The GHS is a standardized international code for classifying hazardous chemicals, and communicating those hazards through labels, warning statements, and safety data sheets. OSHA and other agencies of the U.S. government have been working to harmonize American rules and regulations with these evolving international standards in order to facilitate safety and commerce on a global scale. On September 30, 2009 (74 FR 50280), OSHA published a proposal to amend the HazCom Standard with the GHS. 
The most significant changes that OSHA proposes would be to standardize the form and content of hazard labels and MSDSs.
Currently, under the HazCom Standard, there is no standardized labeling system. Employers can use any system of labels, as long as they train their employees to recognize and understand the labels in the workplace. Current labels need only to identify which materials are hazardous chemicals and give “appropriate” hazard warnings. [29 CFR 1910.1200(f)]
On the other hand, the Globally Harmonized System (GHS) includes a specific set of labels with a consistent format and standardized pictograms. This would apply equally to all employers subject to the standard. Many of these labels contain common pictograms used in other sets of regulations (like the DOT hazmat regulations). If you would like to see these labels, click here.
The GHS would also make changes to MSDSs. As noted above, employers must make an MSDS available to their employees for each hazardous chemical in the workplace. Currently, OSHA has no particular format requirements for MSDSs, as long as twelve specific pieces of information appear, including but not limited to: the identity of the chemical, the physical and health hazards associated with that chemical, and emergency and first aid procedures [29 CFR 1910.1200(g)].
Under the GHS, MSDSs would actually be called SDSs (Safety Data Sheets). SDSs require sixteen pieces of data, instead of twelve, and must be organized in a specific format. Some additional things that were not previously required, but would now be required, include sections on disposal considerations and transportation information. If you would like more information on SDSs, click here.
Additionally, any changes to your labeling or MSDS system would have to be updated in your written HazCom program and training plan. But there is no need to rush a rewrite today, although OSHA is expected to finalize these changes to the HazCom Standard within the next few months, they are also planning for a three year phase-in period before enforcing the new standards. If you’d like more information on classification of hazardous chemicals, click here.