Saturday, November 22, 2008

Changes To Hazard Communication Requirements Under Globally Harmonized Standard (GHS)

In 1992, the United Nations Conference on the Environment and Development (UNCED) adopted a mandate that a standardized system be developed to classify, label and communicate the hazard of materials. Several countries, including the US and Canada, had developed their own systems; however, inconsistencies between the individual requirements of these countries made international trade more challenging. While similar, the regulations of each country are different enough to require multiple labels and safety data sheets for the same product in international trade. A multinational work group, including representatives from U.S. Occupational Safety & Health Administration (OSHA), began developing the standard, now termed the Globally Harmonized System (GHS).

The GHS was adopted by the United Nations (UN) in 2003 and there is an international goal for as many countries as possible to implement the GHS by 2008. OSHA intends to revise the Hazard Communication Standard to align with the GHS and published an Advanced Notice of Proposed Rulemaking in 2006. The current Hazard Communication Standard affects many, if not most, industrial and commercial employers in the US. Most will have developed Hazard Communication programs to meet the current OSHA requirements. Changes to the requirements will impact most of these companies.

The revision to the Hazard Communication Standard will also directly affect manufacturers and distributors of chemicals. These companies may need to review and revise existing Material Safety Data Sheets (MSDS) to meet new requirements.

This article highlights some of the key changes reflected in the GHS compared to the current OSHA Hazard Communication Standard.

Labeling requirements. The GHS will expand the information required for labeling. Under the current OSHA requirements, labels need to identify: 1) chemical or common name, and 2) nature of hazard.

Hazard Classification. One of the most significant changes compared to the current OSHA requirement is the classification of hazards. Although the current standard does include a system of hazard classification, the GHS revises this classification system and the criteria used to assign hazards to chemicals. The GHS also incorporates a standard list of potential health effects to be considered.

Training. The training requirements under the GHS are less prescriptive compared the current OSHA Hazard Communication Standard.

Material Safety Data Sheets. The basic information required in an MSDS will be similar to what is currently familiar to most employees and employers. However, several sections will become mandatory; these include Ecological Information, Transportation Information, Disposal Information & Regulatory Information. Although these sections are often voluntarily included in MSDS, the GHS will require they be included in all MSDSs.

Transportation Placarding. The GHS provides for standard pictograms to be used to mark dangerous goods in transport.

For further information contact Caltha LLP at
Caltha LLP Website

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