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Facts About OSHA’s New Hazard Communication Standards and GHS November 1, 2014 |
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NOTE: This paper is intended as an overview of the new labeling standards. It is not intended for any kind of
certification or compliance training.
Background
As the world continues to get smaller, and millions of pounds of chemical products are shipped between countries daily, a Global Harmonized System (GHS) is being implemented to aid in the communication of hazards and risks. The UN Conference on the Environment and Development (UNCED) met in 1992 and decided that global standards for chemical classification and labeling were needed. Every country had different requirements, causing confusion and increasing risk of serious accidents.
In 2005, the first revised edition of GHS was published, and has since been updated every two years. GHS established a standard system for classifying and labeling chemicals with the intent to have it fully implemented by 2008. It also impacts the content and organization of Material Safety Data Sheets (MSDS), which will be called Safety Data Sheets (SDS) moving forward.
Of course, getting every country in the world to agree on something is easier said than done. While the pictograms and signal words identifying particular hazards on labels are largely accepted, specific chemical classifications and the timing of GHS implementation varies widely from country-to-country. Europe is leading the charge, with adoption of well underway with the Europe on the 5th edition of the UN Purple Book. For Europe and many other countries, GHS is viewed as a living document with changes adopted every two years. The purpose of this paper is to explain how GHS impacts the North American region of US, Mexico, and Canada.
GHS Hazard Pictograms
The most noticeable and potentially alarming change for GHS is the pictograms, standardized symbols that represent the hazards of a chemical. Europe has long used standard pictograms, and the GHS pictograms are largely based on those designs. Canada has used two different sets of pictograms, one for workplace products governed by Workplace Hazardous Materials Information System (WHMIS), and one for consumer products from Consumer Chemicals and Containers Regulations (CCCR). The US has used different sets of pictograms depending upon regulatory agency jurisdiction, one for workplace products governed by Occupational Safety and Health Organization (OSHA), one for environmentally regulated products enforced by the Environmental Protection Agency (EPA), and one for consumer products by Consumer Product Safety Commission (CPSC). The CPSC has jurisdiction over certain chemical labeling under the Federal Hazardous Substance Act (FHSA). Consumer products will still be regulated under the CPSC while industrial products in the workplace will be regulated by OSHA. What is the difference between a consumer product and an industrial product? For example, a glass cleaner is used to clean glass surfaces in the home and the workplace. The difference comes down to use patterns, if the product is used in workplace as a consumer would use it then it is labelled in accordance with the CPSC. If the product is use in a work process where the employee will be exposed to greater concentration than a normal consumer would be exposed to then the product falls under OSHA jurisdiction and GHS labeling.
Previously the US, OSHA had not required standard symbols for workplace product packaging. That’s not to be confused with Department of Transportation (DOT) required labeling, which requires standard pictograms. DOT pictograms are commonly found on trucks and shipping containers. The DOT has already adopted some elements of GHS. This also should not be confused with National Fire Protection Association (NFPA) and Hazardous Materials Identification System (HMIS) markings that are commonly found on US packaging, but have never been a requirement.
The following are GHS pictograms and how they compare to previous requirements. Not every symbol will be required for every country. For example, the US will not require the symbol for environmental toxicity, because aquatic toxicity is not within OSHA’s jurisdiction; it falls under the EPA’s jurisdiction.
US: How Does This Affect Me?
The old requirements, as set by OSHA’s Hazard Communication Standard, are acceptable through the transition, but chemical manufacturers can change to the new GHS standards at any time. This opens the possibility of confusion and alarm in the workplace as new symbols pop-up in seemingly arbitrary ways during the transition. To eliminate confusion and ensure understanding among employees, OSHA required that all employees be trained on the new label elements and SDS format by December 1, 2013. By June 1, 2015, manufacturers will need to be shipping products with GHS labeling, and by December 1, 2015, distributors need to have their old inventory flushed out and be shipping only GHS labeled product. By June 1, 2016, users of these products need to have their inventories converted to GHS labeled products. At that point, the transition is over, and the US will have fully implemented the GHS standard based on the UN 2009 Purple Book classifications.
See the transition summary below, provided by OSHA:
| Effective Completion Date |
Requirement(s) | Who |
| December 1, 2013 | Train employees on the new label elements and SDS format. |
Employers |
| June 1, 2015 | Comply with all modified provisions of this final rule, except: |
Chemical manufacturers, importers, distributors and employers |
| December 1, 2015 | Distributors may ship products labeled by manufacturers under the old system until December 1, 2015. Distributors send only updated SDS’s and labels. |
Distributors |
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 |
Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both. |
All chemical manufacturers, importers, distributors and employers |
Source: OSHA Fact Sheet
Mexico: First North America Country to Adopt GHS
While Mexico was the first North American country to adopt GHS, implementation of the GHS standard has been voluntary in Mexico. With the US implementation of GHS, it is an appropriate time to align Mexican and US workplace product labels.
Canada: Wait and See
Health Canada, Canada’s government body responsible for the work place labelling requirements, has not finalized the timing nor how the current WHMIS related requirements would change. Draft regulations have been proposed, and a final document is not expected until December 2014. In the meantime, the standard WHMIS markings in the hashed border are still required. It is expected that this will be replaced by GHS standard markings and a target “in force” date has been proposed for June 2015 through June 2016. Canada is proposing a phase-in of June 2015 to June 2016 for the Canadian label to either WHMIS or WHMIS after GHS compliant. The phase-in could last until June 2017 before WHMIS after GHS through Canada as Federal, Provincial and Territorial laws have to be changed to adopt GHS. For products being shipped to both US and Canada, which is commonly done, both GHS (US and Mexico) and WHMIS (Canada) markings are allowed. Canada will not accept a GHS only label while WHMIS before GHS is in effect. Canada is adopting the UN 2013 Purple Book and aligning with the US OSHA HCS 2012 classifications so as not to create confusion in the North American marketplace.
Making it simple
Timing will be staged as products work their way from manufacturers through distributors and to end-users. Our goal is to implement GHS labeling changes for US products by the end of 2014, allowing plenty of time for distributors to flush out inventories and users to deplete stocks. If any questions or concerns come up along the way, please contact us at 800-645-5244 x 266 or e-mail us at [email protected]. The most current product information, including MSDS / SDS is available at www.chemtronics.com.
Works Cited
Canadian Centre for Occupational Health and Safety. WHMIS – Labelling Requirements. By Canadian Centre for Occupational Health and Safety. Retrieved November 14, 2013:
http://www.ccohs.ca/oshanswers/legisl/msds_lab.html
United Nations Economic Commission for Europe. Globally Harmonized System of Classification and Labelling of Chemicals (GHS): Historical background and implementation Status. By United Nations Economic Commission for Europe (UNECE). Retrieved November 20, 2013:
http://www.unece.org/fileadmin/DAM/trans/danger/publi/ghs/GHS_presentations/English/ghs_intro_e.pdf
United States Department of Labor. OSHA Fact Sheet. Retrieved November 14, 2013:
https://www.osha.gov/dsg/hazcom/HCSFactsheet.html
United States Department of Labor. Hazard Communication Pictograms. Retrieved November 14, 2013:
https://www.osha.gov/dsg/hazcom/pictograms/
WHMIS and Hazardous Materials. By Western Convenience Stores Association. Retrieved November 19, 2013:
http://www.retailsafety.ca/training/whmis-hazardous-materials
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