Looking for a chemical management system that allows you to print GHS compliant labels and manage the large influx of GHS formatted safety data sheets coming soon to your MSDS library? We can help! Contact one of our compliance experts today.
GHS stands for the Globally Harmonized System of Classification and Labelling of Chemicals. GHS was developed by the United Nations as a way to bring into agreement the chemical regulations and standards of different countries. In short, it is an international attempt to get all countries on the same page.
Born out of the United Nations ‘Earth Summit’ of 1992, over 65 countries have already adopted, or are in the process of adopting, GHS, including the United States and Canada. GHS is primarily concerned with the classification of chemicals and the communication of hazards related to those chemicals to users of the products downstream via warning labels and safety data sheets.
GHS is not a law unto itself; rather it is a system with components countries can adopt into their own systems. In other words, HCS remains the law in the U.S., and WHMIS will continue to be the law in Canada; however, alignment with GHS changes both HCS and WHMIS in ways that have significant consequences for chemical manufacturers and employers in both countrie
GHS adoption affects everyone in the chemical lifecycle, with special responsibilities for chemical manufacturers and employers that handle, use and store hazardous materials. Chemical manufacturers must reclassify their chemicals using GHSs standardized classification criteria as well as produce GHS compliant labels and safety data sheets (SDSs). Employers must train employees on GHS (how to understand new labels and data sheets), manage the influx of new SDSs which will include replacing their entire MSDS library, and be ready to produce GHS compliant workplace labels. Also, be sure to check out our GHS / HazCom 2012 Adoption Timeline Checklist. Print it out and hang it up to track compliance your progress.
Learn more at the GHS Answer Center.
Existing fines and penalties for non-compliance with HCS and WHMIS extend to GHS alignment with these same standards. In the United States, that means that HCS violations, which already rank #3 on OSHA’s Top Ten Violations List, could see even more action. And WHMIS penalties of up to $1 million in fines and two years in prison will remain a serious consideration for anyone with obligations under Canada’s hazard communication standard.
Unfortunately, complying with GHS in both the United States and Canada is not a straightforward affair. For instance, in the U.S., OSHA is allowing two years for employee training on GHS, and three years for full compliance, during which the agency has signaled it will accept adherence to either the old HCS or the revised HCS. Yet, if circumstances arise from GHS adoption in a particular workplace that affects employee safety, (e.g. trouble reading GHS labels or understanding pictograms) the employer would be expected to deal with it in the moment, regardless of how much time they had left to train and be in full compliance of GHS according to the standard
Ultimately, employers have a responsibility to keep their employees safe. For that reason, and to ensure full compliance, MSDSonline recommends companies stay in front of GHS adoption by aligning their policies and health and safety management with GHS principles at the earliest opportunity. If you are looking for an MSDS or a newly formatted GHS SDS, try our MSDS Search tool.
Avoid Compliance & Certification Issues
Revision of the Hazard Communication Standard to align with GHS affects over 40 million workers in 5 million workplaces. Interestingly, the impetus for developing and adopting GHS was written into the preamble of the original HCS in 1983. It recommended seeking the creation of a global approach to hazard communication to reduce risks from confusing differences in international standards as well as ease the cost and hassle of international trade.
Revisions to OSHA’s HCS to align with GHS result in two major changes. First, unlike HCS, which stops at simply classifying hazards, GHS hazard classes are subdivided into “hazard categories” so that chemical manufacturers must identify both the hazardous effects of their chemicals as well as their degrees of severity. The second key area of change under GHS is to labels and safety data sheets.
GHS safety labels have six standardized elements:
MSDSs Get a New Look
Under GHS alignment, safety data sheets remain the backbone of HCS compliance. They do, however, get a name and formatting change. GHS drops the M from MSDS and calls them SDSs. More importantly, SDSs have a standardized 16 section format with a required ordering of sections. It is essentially the ANSI Standard for MSDSs with a few adjustments.
Learn more about GHS and OSHA’s revision of HCS to align with GHS by visiting the GHS Answer Center on MSDSonline’s Environmental, Health and Safety Blog.
With GHS alignment, each container of a classified hazardous chemical is to be labeled, tagged, or marked with the following elements:
Keep in mind these requirements are for classified hazards. For unclassified hazards, the shipping label should include the product name, supplier contact information, and as supplemental information, a description of the hazards and appropriate precautionary measures. WHMIS has additional label elements that may need to be included, such as an on label reference to the corresponding SDS.
GHS allows authorities like OSHA to determine what types of workplace labels will be required, and OSHA has signaled it will continue to give employers flexibility in this area by allowing them to choose “to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule, or with label alternatives that meet the requirements for the standard.”
OSHA will also continue to give employers alternatives to affixing labels to stationary containers and portable containers used to transfer materials from other labeled containers, so long as the portable containers remain under the control of the employee who performs the transfer and are used within a workshift.
Remember, labels must not be defaced or removed unless immediately replaced with new labels.
MSDSs, as was mentioned earlier, are redefined as SDSs under GHS and remain the backbone of HCS and WHMIS compliance. Under GHS, SDSs are presented in a 16 section format with a required ordering of sections. It is essentially the ANSI Standard for SDSs, with a few minor tweaks. The sections, in order, are as follows:
To be GHS-compliant, an SDS needs all 16 sections; however, OSHA will not be enforcing information contained in sections 12-15, which fall outside the Agency’s jurisdiction. With GHS alignment, employers should prepare for a large influx of new SDSs to occur within a short time frame.
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