GHS and HCS 2012 - AN INTRODUCTION

GHS, the 'Globally Harmonized System for Classification and Labelling of Chemicals', was introduced in 1992 at the United Nations Conference on Environment and Development (UNCED). GHS is in the process of implementation in many countries around the world, including Canada, Australia, Japan, China, New Zealand and the European Union (EU).

Revising OSHA's Hazard Communication Standard (HCS) to align with GHS is part of the implementation process currently taking place in the United States. Aligning HCS with GHS will affect hazard classification, labeling, material safety data sheets (MSDS), and employee training for companies

throughout the United States. OSHA is anticipating the safety and health of millions of workers throughout the United States will be improved as a result of the alignment of HCS with GHS.

Under HCS 2012, new criteria have been established for the hazard classification of chemicals and chemical mixtures. Chemical manufacturers will be required to classify hazards related to the chemicals they import or manufacture using the new HCS 2012 classification criteria, and will be required to update their labels and safety data sheets (SDS) accordingly.

Aligning HCS with the GHS labeling standards requires information about chemical hazards to be communicated in a labeling format that uses specific signal words, pictograms, hazard statements and precautionary statements for each of the individual hazard classes and categories. By aligning with the format used in GHS, HCS 2012 will require Material Safety Data Sheets (MSDS) to be renamed Safety Data Sheets (SDS), and a specific 16-section format for the SDS must be followed.

HCS 2012 will require employers to keep their safety data sheets updated, offer training that will cover the new labeling requirements, and update their Hazard Communication Programs, if new hazards are identified. In addition, HCS 2012 requires employers to complete training for all employees on the new labeling elements and the new Safety Data Sheets no later than December 1, 2013.

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GHS AND HCS 2012 – THE "RIGHT TO UNDERSTAND"

"Right to Know" vs "Right to Understand" Under HCS, employees have had the "right to know" about the chemical hazards in their workplace for almost 30 years. But it is not enough to "know" information. What is needed is the "understanding" of information. Albert Einstein once said, "Any fool can know. The point is to understand." When it comes to hazard information, understanding is critical. 'Understanding' enables workers to effectively apply the knowledge they have gained, and use what they 'know' in practical and important ways.

HCS aligns with GHS In an effort to improve 'understanding', OSHA's has aligned their Hazard Communication Standard (HCS 2012) with criteria from GHS, the Globally Harmonized System of Classification and Labeling of Chemicals developed by the United Nations. By aligning with GHS, HCS 2012 more effectively brings employees the "right to understand" the information they receive about hazards in the workplace. Implementing GHS into OSHA's Hazard Communication Standard further helps align the United States with the standard that is being used in other countries around the globe such as the European Union (EU), Japan, Canada, Australia, New Zealand, and China. Participation in the global implementation of GHS helps to increase understanding of hazard information for workers worldwide.

Quality and Consistency Improve Understanding

Aligning with GHS standardizes chemical hazard information in ways that improve the quality and consistency of information to help increase understanding of hazard information by those who come in contact with chemical hazards in the workplace. Previously, labels and Material Safety Data Sheets (MSDS) were allowed to have varied formatting, often leading to inconsistent and hard to read hazard information that was difficult to understand. Under HCS 2012, chemical hazard labeling and safety data sheets are consistent and easy to read through the use of standardized pictograms, signal works, hazard and precautions statements. Improving hazard communication by increasing understanding results in better handling, transportation, use, cleanup and disposal of chemicals, leading to increased health and safety for everyone.

Changes to HCS

Revisions to OSHA's Hazard Communication Standard for the 2012 edition of HCS include:

  • Revising the criteria for the classification of health and physical hazards of chemicals and chemical mixtures.
  • Revising chemical labeling requirements to include the use of specific harmonized labeling elements such as signal works, pictograms, hazard statements and precautionary statements.
  • Revising the Material Safety Data Sheets (MSDS) by changing the name to Safety Data Sheets (SDS) and requiring the SDS to follow a standardized format using 16 sections in a specific order.
  • These changes to HCS 2012 help to improve understanding of chemical hazards. These changes also provide for faster, more effective access to information during emergencies or in daily workplace use.

Training

HCS 2012 requires employers to train their employees on the new labeling elements and Safety Data Sheets to ensure the workers are able to recognize and actually understand the chemical hazards in their workplace. Training on the new HCS labeling elements will be more effective due to consistency in the new labels and safety data sheets.

Benefits

OSHA expects the revised HCS 2012 to improve communication of chemical hazard information and their associated protective measures, and prevent over 500 injuries and illnesses in the workplace, saving 43 lives each year. Productivity benefits are also expected. Effective hazard communication helps increase understanding by both workers and emergency responders, and increased understanding reduces the occurrence of accidents, injuries, illness and fatalities in the workplace. OSHA estimates the revised HCS 2012 will provide savings and benefits valued at $757 million for businesses throughout the United States.

Compliance

OSHA expects timely compliance with HCS 2012. The phase-in dates for compliance with HCS 2012 requires employers to complete training on the new labeling elements and SDS for their employees by Dec 1, 2013. Manufacturers, importers, distributors and employers must comply with all of the modified provisions of HCS 2012 by June 1, 2015, with the exception of shipping container labeling, which has until Dec 1, 2015 for compliance with the shipping labeling requirements.

Alternative labeling systems, such as the use of NFPA 704, or HMIS labeling, are still permitted for workplace containers, under HCS 2012, as long as the labels used are consistent with HCS 2012. By June 1, 2016, all employers must have updated their written hazard programs and alternative workplace labeling as necessary and have provided more training for employees if there are newly identified physical or health hazards.

There will be a period of time where labeling and safety data sheets under both the previous HCS and HCS 2012 will be in the workplace, and this is considered by OSHA to be acceptable during this phase in period. Therefore, employers are allowed to be in compliance with either the existing HCS or HCS 2012, or both during the phase-in time. However, the compliance time is short, so time is of the essence when it comes to completing your HCS 2012 compliance.

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HAZCOM 2012 – OSHA'S HAZARD COMMUNICATION STANDARD ALIGNS WITH GHS

What is GHS?

The Globally Harmonized System of Classification and Labelling of Chemicals is also known as GHS. Developed by the United Nations, GHS is a global approach to hazard communication and provides:

  • Harmonized criteria for the classification for the health, physical and environmental hazards of chemicals.
  • Harmonized label elements assigned to each of the hazard categories, which include pictograms, signal words, hazard statements and precautionary statements to communicate the hazards to users.
  • Harmonized information on Safety Data Sheets (SDS).

GHS was based on existing hazard communication systems around the globe, including OSHA's Hazard Communication Standard along with input from many different countries. This collaborative effort resulted in the United Nations GHS document commonly referred to as 'The Purple Book'. GHS has been implemented, or is in the processing implementation, in many countries around the world.

OSHA's Decision to Align HazCom with GHS The United States is a major importer and exporter of chemical products; therefore, workers in the US commonly see labels and Safety Data Sheets (SDS) from many other countries. Different countries have different viewpoints on hazard classification, so chemical labeling may have insufficient information according US standards, or conflicting and difficult to understand information, creating confusion and preventing the effective communication of important information. Ineffective hazard communication leads to accidents, illness, injuries and fatalities in the workplace. OSHA's goal in aligning the Hazard Communication Standard with GHS was to improve the safety and health of workers in the United States by more effectively communicating chemical hazard information.

Since OSHA's 'HazCom' began, the standard required employees to be provided with information about chemicals in the workplace, but the original HazCom standard allowed chemical manufacturers and importers to provide chemical hazard information in whatever format they chose on labels and MSDS sheets, contributing to confusion over information. Aligning HazCom 2012 with GHS provides a more harmonized approach for labeling and safety data sheets (SDS) by requiring the use of standardized labeling elements and formats on the SDS, along with employee training on the labeling and SDS changes. This consistency for labels and SDS, with effective training efforts, help to improve health and safety in the workplace by providing workers and emergency responders with better understood hazard information, and quicker access to critical information. By implementing GHS in the United States, and in other countries around the globe, communication of hazard information will be improved and safety will be increased for workers everywhere.

Who's Affected by HazCom 2012?

It is expected that the revisions to OSHA's Hazard Communication Standard will affect over 5 million workplaces and 43 million employees in the United States.

HazCom 2012 Changes Chemical Hazard Evaluations

As previously required under HazCom 1994, an evaluation of chemical hazards must be performed. That requirement continues in HazCom 2012. However, the 'hazard determination' provisions previously were a performance-oriented approach that provided parameters for evaluation, but did not provide specific detailed criteria for evaluation. To ensure consistency and accuracy, HazCom 2012 provides specific criteria for each health and physical hazard, along with detailed instructions for classifying the hazards of chemicals or chemical mixtures. HazCom 2012 also establishes hazard classes and hazard categories for most of the hazard effects. The hazard classes are divided into categories that reflect the relative severity of the hazard effect.

HazCom 2012 changes labeling

Previously HazCom 1994 required labels to include identification of the chemical and appropriate hazard warnings, but the method of communicating that information could vary. HazCom 2012 is standardized and harmonizes with GHS by specifying the information that must be provided for each hazard class and category, and identifying specific labeling elements that are to be used on the labels.

The labeling elements required under HazCom 2012 include the following:

  • Pictograms - These are symbols along with other graphic elements such as borders, background patterns or color intended to convey specific information about the hazards of the chemical.
  • Signal words – These are single words used to indicate the relative level of a hazard's severity, and are used on labeling to communicate a potential hazard. HazCom 2012 uses the GHS signal word 'Danger' for severe hazards, and the signal word 'Warning' for less severe hazards.
  • Hazard Statements – Under HazCom 2012, specific statements are assigned to the hazard classes and categories describing the nature and degree of the hazards.
  • Precautionary Statements – These are phrases that describe recommended measures that should be taken for minimizing or preventing adverse effects that may result from exposure to the hazardous chemical, or from the improper storage or handling of the hazardous chemical.