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What is GHS?

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.

Surviving GHS Transition

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.

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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:

  • Product Identifier – Must match product identifier on safety data sheet
  • Manufacturer Contact Information – Including name, phone number, and address
  • Hazard Pictograms – New label elements that may require color printers
  • Signal Word – Either DANGER or WARNING depending upon hazard severity
  • Hazard Statements – Standardized sentences that describes the level of the hazards
  • Precautionary Statements – Steps employees can take to protect themselves

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:

  • Product or chemical identifier clearly indicated on the label that matches the product or chemical identifier on the SDS.
  • Contact information for the product supplier, including the company name, address and telephone number.
  • Hazard Pictograms. Pictograms have a black symbol on a white background with a red diamond frame. (See examples below)
  • Flame Explosive Health Hazard Corrosion Skull and Crossbones Exclamation Mark
    Note: GHS allows for a black frame to be used for shipments within a single country. OSHA, however, is proposing that a red frame be used regardless of whether the shipment is traveling inside or outside of the country.
  • The signal word should be clearly marked at the top of the label beneath the product identifier. GHS permits the use of only two signal words (and only one at a time) – DANGER or WARNING – to emphasize the hazard and distinguish between hazard levels.
  • A hazard statement that describes the level of hazard should appear under the signal word. Signal words, hazard statements and pictograms have all been harmonized and assigned to each hazard class and category in GHS. Once a chemical has been classified, the relevant harmonized information can be found in HCS under the new Appendix C.
  • Lastly, the label should include the appropriate precautionary information. Since OSHA does not currently require precautionary statements, this is a key change to HCS. As of now, precautionary statements in the GHS are not harmonized. The intent is to harmonize precautionary statements in the future; until that time, OSHA is expected to mandate the use of the GHS examples, which it anticipates will end up being the harmonized statement

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.

Workplace Labeling

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:

  1. Identification
  2. Hazard(s) Identification
  3. Composition/Ingredient Information
  4. First-Aid Measures
  5. Fire-Fighting Measures
  6. Accidental Release Measures
  7. Handling and Storage
  8. Exposure Control/Personal Protection
  9. Physical & Chemical Properties
  10. Stability & Reactivity
  11. Toxicological Information
  12. Ecological Information
  13. Disposal Considerations
  14. Transport Information
  15. Regulatory Information
  16. Other Information

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.