|
|
|
|
Globally Harmonized System of Classification and Labelling of Chemicals (GHS)
Carol J. Robinson, CIH, CSP, Principal and Vice President, Oakland, CA
For the past 25 years, communication of chemical hazard in the United States has been performed in accordance with the requirements of the OSHA Hazard Communication standard (HCS). This standard requires that companies assess chemical hazards, label chemicals, provide Material Safety Data Sheets and perform employee training. Other countries established their own requirements, which resulted in compliance challenges for companies and regulatory agencies.
The goal of establishing "a globally harmonized classification and compatible labeling system, including material safety data sheets and easily understandable symbols by the year 2000" was set out in the report of the United Nations Conference on Environment and Development (UNCED) in 1992 (3-13 June 1992, Earth Summit, Rio de Janeiro, Brazil). In 2003, the United Nations (UN) adopted the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). OSHA published an advance notice of proposed rulemaking (ANPR) on September 12, 2006 and a proposed rulemaking on September 30, 2009 to align OSHA's Hazard Communication standard with the GHS. The primary benefit of the GHS is to increase the quality and consistency of information provided to workers, employers and chemical users by adopting a standardized approach to hazard classification, labels and safety data.
There are numerous differences between the current HSC and the GHS. Some of the key differences include the following:
Hazard Determination in the current HSC becomes Hazard Classification. While the GHS includes health, physical and environmental hazards, OSHA's proposed standard only addresses health and physical hazards. The proposed standard includes mandatory health and physical hazard criteria (Appendix A and B respectively). While the current and proposed criteria reference toxicity data, the criteria are different. For example, a chemical with an Oral LD50 less than 50 mg/kg would be considered Highly Toxic by the current standard. The proposed standard providing a rating grid, with categories ranging from Category 1 to Category 4. The Oral LD50 of Category 1 chemicals would be less than or equal to 5 mg/kg, and the Oral LD50 of Category 2 chemicals would be greater than 5 but less than 50 mg/kg. The proposed standard also provides detailed instructions for the hazard determination of mixtures, including "bridging" principles for the classification of mixtures where test data are not available for the complete mixture.
Additional information will be required on labels. The current HCS requires only that the chemical manufacturer include on the label the identity, manufacturer's name and address and appropriate hazard warnings, which provided flexibility in how to comply with these requirements. OSHA's proposed standard expands the information required on a chemical label to include the following:
- Product identifier;
- Signal word;
- Hazard statement(s);
- Pictogram(s);
- Precautionary statement(s); and,
- Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.
Appendix C of the standard includes mandatory labeling elements. One key difference is the use of mandatory pictograms, which are required to be in the shape of a square set at a point and shall include a black hazard symbol on a white background with a red frame sufficiently wide to be clearly visible. Precautionary statement text includes four types of precautionary statements presented, "prevention," "response," "storage," and "disposal." The core part of the precautionary statement is presented in bold print.
Instead of Material Safety Data Sheets (MSDS), chemical hazard information will be provided on Safety Data Sheets (SDS). The current HCS specifies certain content, but provides flexibility in the format of the MSDS. The proposed OSHA standard specifies the content and format of the SDS in the mandatory Appendix D. Certain sections included in the GHS are non-mandatory in the proposed OSHA standard, such as ecotoxicity, disposal considerations, transportation information and regulatory information.
US OSHA is accepting comments and may have another proposed regulation posted before finalizing and publishing a "Final Rule". A two-year transition period is proposed for training and a three-year period for full implementation. The proposed standard is already having an impact, however, as chemical manufacturers are incorporating GHS principals into their labels and MSDSs.
Extensive information on GHS and the HCS is presented at the OSHA website at http://www.osha.gov/dsg/hazcom/global.html. For more information about GHS and HCS and how STC provides compliance assistance, contact Carol Robinson at 510-495-6070 or crobinson@stcenv.com.
| |
|
