Many people are asking “What is GHS and what does it mean for me?” GHS is an acronym for Globally Harmonized System of Classification and Labelling of Chemicals. The concept of GHS is to have a globally harmonized system in place for the classification of chemicals, the content of labels and safety data sheets (SDS). This concept is not new as the transportation sector has in place a global system for the transport of dangerous goods that covers classification of chemicals, packaging, labels, placards and shipping documents. The transport sector is governed by the United Nations Committee of Experts on the Safe Transport of Dangerous Goods (UNCETDG). As there was no harmonization in the workplace or consumer sectors, the UN expanded the UNCETDG and created the UNSCEGHS – United Nations Sub-Committee of Experts on GHS. The UNCETDG was re-named UNSCETDG and both committees report to the Committee of Experts on the Transport of Dangerous Goods and Globally Harmonized System of Classification and Labelling of Chemicals (CETDGGHS).

The first edition of GHS appeared in December 2002. The first revised edition was available in 2005 and contained amendments for items such as: aspiration hazards, guidance on pictograms, precautionary statements and preparation of SDSs. The second revised edition came out in 2007 containing amendments for: explosives, toxic by inhalation, skin sensitizers, respiratory sensitizers, building block approach and codification of precautionary and hazard statements. The third revised edition (2009) contained amendments for: labelling of small packages, chronic toxicity for aquatic environments and new provisions for the allocation of hazard statements. The fourth revised edition (2011) contains amendments for: new hazard categories for unstable gases and non-flammable aerosols, clarification of precautionary statements and further clarification of some of the criteria.

Some of the countries that have implemented GHS are: European Union, Japan, Korea, Brazil, Mexico, New Zealand, Taiwan, Indonesia and China. And coming to your workplace in the United States, under OSHA (Occupational Safety and Health Administration). OSHA promulgated a final rule affecting 29 CFR Parts 1910, 1915 and 1926.
OSHA is modifying the Hazard Communication Standard (HCS) to meet GHS (3rd revised edition). These modifications will improve the HCS (or Hazcom 2012) by ensuring that employees (or workers) will be better informed of the chemical hazards that they will be exposed to in the workplace, and reducing the incidents of chemical related illnesses and injuries.

And how will all this be done? This will be accomplished by three things – training, labels, and safety data sheets.

First issue is training. Employers must train their employees on the new requirements by December 1, 2013. This training will involve the changes regarding classification, labels, MSDSs, pictograms, hazard and precautionary statements and signal words. Employers may comply with the HCS, Hazcom 2012 or use both. There is no requirement to keep two sets of labels or MSDSs. The effective date for full compliance of the new Hazcom 2012 is June 1, 2015. Distributors will have until December 1, 2015 to ensure that all containers are in compliance before shipping.
The second issue under Hazcom 2012 is the label which will be standardized. There will be two labels – the container label and a workplace label. The container label will consist of:

• Product identifier
• Signal word
• Hazard statement
• Pictogram(s)
• Precautionary statement
• Name, address, telephone number of manufacturer/importer/distributor

The workplace label can have the above elements displayed on it or a label that has the product identifier on it with words, pictures, symbols or a combination, which will provide employees with specific information on the hazards of the chemicals.

Container labels	Workplace Labels

The third issue is the current material safety data sheet (MSDS) becomes the safety data sheet (SDS). The SDS will be 16 sections in a standard format:

1. Product identification
2. Hazard identification
3. Composition/ingredients
4. First aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological data
13. Disposal information
14. Transportation information
15. Regulatory information
16. Other information including date of last revision

Sections 12, 13, 14 and 15 are not mandatory to OSHA, but are necessary to have a compliant SDS. Enforcement for compliance for these four sections will not be done by OSHA, as they are outside the jurisdiction of OSHA.

The result of Hazcom 2012 is improved safety, global harmonization of standards and annual savings of millions of dollars. Through GHS, chemicals that are imported will have the same standards for labels and SDSs resulting in less confusion in the workplace.

And where is Canada on GHS? Recently Health Canada (HC) issued a working document outlining the changes that are intended for the Controlled Products Regulations under the Hazardous Products Act. The changes would implement GHS in the workplace under WHMIS. HC has indicated that they are not going to change the name of Canada’s chemical classification and hazard communication standard, also known as, WHMIS. They have indicated that it will continued to be called WHMIS and that the relevant sections will change to meet the GHS requirements. Expectation is that HC will introduce proposed regulations in Canada Gazette I at the end of the federal fiscal year – March 2013.

Stay tuned – there’s lots more to come.

It appears that the Globally Harmonized System in the US is still not quite ready.

The Office of Information and Regulatory Affairs (OIRA), under the Office of Management and Budget (OMB), began a review on October 25, 2011, of a Notice of Proposed Rulemaking, Docket No. OSHA–H022K–2006–0062, from the Occupational Safety and Health Administration (OSHA). This amendment would adapt the hazard communication requirements of Title 29 of the Code of Federal Regulations (29 CFR) to reflect the international standard known as the Globally Harmonized System, or GHS.

As its name implies, the OMB’s mission is to assist the President in overseeing the preparation of the federal budget, and review and oversee financial implications of new regulations. The office must review regulations before they can proceed to final publication.

The review of the proposed rulemaking was extended for a month in January, with the OMB issuing their completed report on February 21, 2012. The report indicates that the amendment is accepted “consistent with change”. This indicates that the agency, though accepting the amendment in general, will require some changes before being finalized. However, the report from the OMB does not indicate if these changes will be minor or much more substantial.

The phrase "consistent with change" can cover minor editorial corrections to something more far-reaching. According to the General Accounting Office (GAO), it "does not indicate whether the changes made to agencies’ rules during the formal review process had been suggested by OIRA or the agencies, or whether the changes were substantive or editorial in nature". The group OMB Watch adds, "[a]ll rules changed and then approved by OIRA are labeled ‘consistent with change.’ A change for clarity, such as the insertion of a comma, is reported in the same manner as a change in substance that affects the very nature of the regulation."

It has not yet been announced how long the changes may take to complete. Concerns have already been raised by industry regarding the costs versus benefits of OSHA’s proposed rule. The category of “unclassified hazards” has been particularly contentious, since it is not part of the international GHS classification system.

For more information, go to the OMB website at http://www.reginfo.gov/public/jsp/EO/eoDashboard.jsp, and search for the amendment by its RIN number, 1218–AC20.