OSHA Global Harmonized System
Reviewing the Impact of OSHA’s GHS Adoption on the Industrial Market (April 2013)
On March 20th, 2012, Secretary of Labor Hilda L. Solis announced that OSHA was updating the Hazard Communication Standard (HCS) to be in line with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). GHS was developed by the United Nations and provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards. It also specifies hazard communication elements for labeling and safety data sheets (notice that they are no longer called material safety data sheets.) The goal of GHS is to make the international sale and transportation of hazardous chemicals easier as well as making workplace conditions safer.
GHS is not a regulation, but a set of recommendations that a competent authority can adopt. In the US, there are four main agencies responsible for GHS implementation: the Occupational Safety & Health Administration (OSHA), the Environmental Protection Agency (EPA), the Department of Transportation (DOT), and the Consumer Product Safety Commission (CPSC). The DOT was actually the first agency to implement GHS and OSHA’s adoption brings the regulations between the agencies into greater harmony. The EPA is expected to follow in the near future.
GHS is being implemented around the world and uses a building block approach which allows competent authorities some flexibility in developing or modifying existing programs. In some cases, this flexibility can lead to slight country-to-country variations. To comply with OSHA’s new standard, businesses will have to re-classify all chemicals using GHS criteria, re-author all Safety Data Sheets in GHS formats, produce GHS formatted labels, and train workers on how to read new labels and SDSs, including newly identified hazards. Adoption of GHS brings major changes to OSHA’s HCS, especially with regard to:
- Hazard classification
- Safety Data Sheets
Employers must train workers on the new label elements and SDS format by December 1, 2013. For most businesses, the deadline for complying with all provisions of the final rule is June 1, 2015. However, distributors may ship products labeled under the old system until December 1, 2015. By June 1, 2016, employers must update alternative workplace labeling (e.g. HMIS, NFPA) and hazard communication programs as necessary, and provide additional worker training for new identified physical and health hazards. During the transition period, all chemical manufacturers, importers, distributors, and employers may comply with either 29 CFR 1910.1200 (the new standard),or the old standard, or both.
Here at LPS, we have created a transition plan that will ensure all LPS products will be compliant with OSHA’s new requirements by the June 1, 2015 deadline. All products launched in 2013 will be labeled according to OSHA’s new (GHS) requirements and will be accompanied by a matching SDS. Our existing product line will be transitioned over the next two years.
It is recommended that each customer establish a transition plan as well. As part of that plan, you should carefully evaluate your hazardous chemicals inventory to ensure that all manufacturers have developed a transition plan and will be providing compliant labels and SDSs on or before the June 1, 2015 deadline. Given the relatively short six month sell-through period for distributors, stock rotation will be exceedingly important to ensure that older product is shipped prior to the December 1, 2015 deadline. In addition, employees need to be trained as outlined by OSHA inthe new standard.
OSHA has issued several educational resources to help industry with this transition. Anyone wishing to learn more about OSHA’s new rule may do so by visiting the OSHA’s Website.