GHS, or Globally Harmonized System, is a world regulation for classifying and communicating chemical hazards. Hazard communication experts around the world worked to create this new global standard based on major existing systems including the OSHA Hazard Communication Standard (HCS). By implementing GHS guidelines into the revised HCS, OSHA has expanded the "right to know" into the "right to understand.” Adoption of GHS brings the U.S. into alignment with an international standard. If you are a manufacturer, supplier, or a user of chemicals, you are required to comply with GHS. (OSHA 29 CFR 1910.1200 Hazard Communication Standard)
The goal of this new system is to more effectively communicate chemical hazards to improve the safety and health of our workers. GHS is expected to prevent more than 500 workplace injuries and illnesses and 45 fatalities every year. It will also improve international trade conditions for chemical manufacturers, enhance worker comprehension of hazards (especially with low and limited literacy workers), reduce confusion, facilitate safety training, and result in safer handling and use of chemicals. GHS provides quicker, more efficient access to SDS information, cost savings through productivity improvements, fewer SDS and label updates, and simpler hazcom training.
There are three main areas in the existing HCS which have changed with the adoption of GHS: hazard classification, labels, and safety data sheets.
Hazard classification (formerly hazard determination) is one of the major areas of change. Definitions of hazard now provide specific criteria for classification of health, physical, and environmental chemical hazards along with the classification of mixtures. The current Hazard Communication Standard (HCS) provides parameters for evaluation, but doesn't give specific, detailed criteria. The revised HCS, on the other hand, has specific criteria for each health and physical hazard, plus detailed instructions for evaluation. This new method of evaluation is covered in the required GHS training. The revised HCS also establishes hazard classes and categories. A class describes the different hazards. For example, "Gases under Pressure" is an example of a class in the physical hazards group. Categories are used to describe the sub-sections of classes. For example, "Self-Reactive Chemicals" has seven categories. Each category has rules or criteria to determine which chemicals are assigned to that category.
Standardized labels for hazard classes and categories will now be required. Previously, label preparation could be done in a variety of ways with the method being left to the preparer. Under the revised HCS, once classification has been done, the standard will specify what should go on the label. According to the revised HCS, labels will now require the following:
Information on the safety data sheet (SDS) will be about the same as what we currently have (MSDS). The current standard indicates what should be included, but doesn't specify a format for presentation or order of information. The revised HCS has sixteen sections and uses consistent headings in a designated sequence.
There are nine pictograms used in GHS to convey health, physical, and environmental hazards. The revised Hazard Communication Standard (HCS) requires the use of eight of them, with the exception being the environmental pictogram.
According to the revised HCS, all pictograms must have red borders. The purpose of keeping the color consistent is to increase recognition and make them easily comprehensible. Although some businesses might prefer to use a black border for domestic shipping, red is required for both domestic and international shipping. In addition, all red borders printed on a label must have a symbol printed inside. This is meant to limit confusion from workers who might be faced with blank labels. So, for maximum recognition and impact of warning labels, and to ensure that users don't get desensitized to these warnings, a symbol must always be used with the red border.
With the revised Hazard Communication Standard (HCS), it's now okay to update labels when new information on hazards becomes available. In fact, chemical manufacturers, importers, distributors, or employers who become "newly aware" of any significant information on the hazards of a chemical need to revise the labels within six months. Labels on any containers shipped after that time must have labels with the new information.
Quickly identify chemical risks using nine new GHS pictograms. Comply with GHS classification guidelines.
OSHA requires that all employees be trained on the new GHS label elements and the safety data sheet (SDS) format. If your employees missed the original December 2013 training deadline or if you hired new employees after that date, start training them now. Employees must be familiar with the labels and know how to understand and use them as soon as possible.
OSHA has outlined a phase-in period for adoption of the revised Hazard Communication Standard (HCS). During the phase-in process, employers need to be in compliance with either the existing HCS, the revised HCS, or both. Employers must ensure all employees are trained on the new label elements and safety data sheet (SDS) format. The following timeline gives a list of the remaining compliance deadlines and requirements:
Chemical manufacturers, importers and distributors reclassify chemicals, send SDS & labels in GHS format
Distributors send only updated SDS & Labels
Employer full compliance deadline