I recently had the opportunity to attend a two-day training session on GHS. I had some general knowledge about GHS going into the class, but had never really gotten into the nuts and bolts of it before. I was really looking forward to finally getting some in depth training (yes…I was looking forward to the training, I am a self-proclaimed hazmat nerd and quite proud of it!).
Within the first half hour I was fully engrossed and enjoying the learning process. Then I had a realization…I am probably the exception to the rule here. Most people who are going to have to adapt to the GHS system are going to do so with dread and difficulty. And then there are the people who have no idea what GHS is and how it is going to affect them. If you are one of those people, I strongly suggest that you start preparing now!
If you export products to the EU, you are probably already quite aware of GHS. The EU adopted GHS into their CLP and REACH regulations in 2008. Full implementation was delayed until 2010 for substances and 2015 for mixtures.
As for North America, OSHA published a proposed rulemaking in 2009 that would incorporate many of the GHS requirements into the current US Haz Com standard. In late 2010, OSHA indicated a target date for the final rule of August 2011. Canada has not had any rulemaking activities, but has been consistent in their intent to incorporate the GHS requirements into their current standards.
So what does that mean? Well, one major change will be in the classification of hazards. GHS is very specific about classification and has criteria for physical, health and environmental hazards. Sound simple enough? It’s not. Most hazard classifications will require physical, chemical, toxicological and environmental data on the product or the ingredients. That data will then have to be analyzed and in most cases, calculations must be done (yes, there WILL be math involved). It is unlikely that you will be able to classify your product by just looking at 2 or 3 pieces of information and making an educated guess.
So once you have this classification, what do you do with it? Labels and MSDS’s will be changing as well. GHS specifies symbols and phrases that must appear on the product label. The symbols and phrases will be prescribed based on the classification. For those of us in the US, using symbols on labels will be a huge change.
MSDS’s will be standardized as well. For one thing, the M will be dropped and they will be referred to as just Safety Data Sheets or SDS’s. The new SDS’s must be in a 16-section format, which won’t be too much of a change for those of you currently using the ANSI standard to prepare MSDS’s (whew, one thing that might be easy!). If you are not currently using a 16 section MSDS, this might be a good time to start.
This is just the tip of the iceberg for GHS. We still have to wait for a final rule from OSHA and a rulemaking in Canada to know for sure what is going to change. After 2 days immersed in the GHS requirements, I can see many people setting into a state of panic when that does happen. Do yourself a favor; start getting ready now!
ICC USA
ICC Canada