GHS

Jim Shelton, CAS, HNAO

Updated by Jorge Delucca, OKCAO Version 2, June 2012

GHS

• On March 26, 2012 OSHA published the final rule to align the OSHA Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

• The final rule becomes effective on May 25, 2012

GHS

• The change will help ensure improved quality and more consistency in the classification and labeling of all chemicals

• AIHA summed up the support from commenters and testifiers by declaring that the GHS modifications will improve quality and consistency of hazard communication information (Document ID #0496 Tr. 415). Source: Federal Register, March 26, 2012

GHS

• The benefits include enhanced worker comprehension resulting in appropriate handling and use of chemicals. The harmonized format of the safety data sheets will enable workers to access the information more efficiently

• Also currently multiple labels and safety data sheets must often be developed by chemical manufacturers for the same product when shipped overseas. This creates a major compliance burden increasing costs

GHS

• GHS provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards

• Specifies hazard communication elements for labeling and safety data sheets.

• Labels will include signal words, pictograms, and hazard and precautionary statements and safety data sheets would have a standardized format

GHS

• The major proposed changes to the HCS:– Hazard Classification (changed from hazard

determination)

– Labels

– Safety Data Sheets (changed from materials safety data sheets)

– Information and Training

• Will affect nearly 40 million workers and 5 million workplaces

TLVs, PELs, & other exposure llimits

• TLVs, PELs, and “any other exposure limit recommended by the chemical manufacturer, importer or employer are required”

Carcinogenicity

• If a chemical is listed as carcinogen by IARC or NTP, it must be noted on the SDS

• If OSHA finds a chemical to be a carcinogen, it must be noted on the SDS

GHS

• The GHS may prevent 43 fatalities and 585 injuries and illnesses annually

• DOT has already modified their requirements for classification and labeling to be consistent with UN transport requirements and the GHS

Phase-In dates

Effective Completion date

Requirements Who

Dec 1, 2013 Train employees on new labels and Safety Data Sheet format

Employers

June 1, 2015

December 1, 2015

June 1, 2016

Compliance with modified provisions of final rule except:

Distributors shall not ship containers labeled unless it is a GHS label

Update workplace labeling and HAZCOM program. Additional employee training on newly found physical or health hazards

Chemical manufacturers, importers, distributors & employers

Employers

Transition period May comply with final HAZCOM std. or current std., or both

Chemical manufacturers, importers, distributors & employers

GHS Hazard Classification

• The list of chemicals presenting a ‘Health’ hazard was deleted from the current HCS and the proposed HCS has identified a new listing

• A ‘Health Hazard’ means a chemical which is classified as posing one of the following hazardous effects:

GHS Hazard Classification

– Acute Toxicity (any route of exposure)

– Skin Corrosion or Irritation

– Serious Eye Damage or Eye Irritation

– Respiratory or Skin Sensitization

– Germ Cell Mutagenicity

– Carcinogenicity

– Reproductive Toxicity

– Specific Target Organ Toxicity (single or repeated exposure)

– Aspiration Hazard

GHS Hazard Classification

• The list of chemicals presenting a ‘Physical’ hazard was deleted from the current HCS and the proposed HCS has identified a new listing

• A ‘Physical Hazard’ means a chemical that is classified as posing one of the following hazardous effects:

GHS Hazard Classification

– Explosive

– Flammable (gases, aerosols, liquids, or solids)

– Oxidizer (liquid, solid, or gas)

– Self-Reactive

– Pyrophoric (liquid or solid)

– Self-Heating

– Organic Peroxide

– Corrosive To Metal

– Gas Under Pressure

– Contact With Water Emits Flammable Gas

OSHA Hazard Classification

• In OSHA’s proposed rule there was a hazard category called ‘Unclassified’ which is not in the UN GHS system– … a chemical for which there is scientific evidence

identified during the classification process that may pose an adverse physical or health effect when present in a workplace under normal conditions of use…

– Example: Combustible Dust

Hazards Not otherwise Classified

• OSHA changed “unclassified hazards” to “hazards not otherwise classified” (HNOC)

• For issues that have not gone through a rulemaking

• Combustible dust is considered “hazardous chemical”

Hazardous Chemical

• OSHA classified as Hazardous Chemicals:– Pyrophoric gases, signal word “danger”,

“catches fire spontaneously if exposed to air”*– Simple asphyxiants, signal word “warning”, “may

displace oxygen and cause rapid suffocation”*– Combustible dust, signal word “warning”, “May

form combustible dust concentrations in the air”*

*Hazard Statements

Other Standards Affected

• Flammable and combustible liquids in general industry & construction (1910.106 and 1926.152)– Align with GHS hazard categories for

flammable liquids

Other Standards Affected

• Process Safety management of Highly Hazardous Chemicals (1910.119)– Modified to ensure scope is not changed

• Modifications made to most OSHA’s substance-specific health standards to ensure signs and labels are consistent with modified HCS

Change to warnings for carcinogens

• All warnings for carcinogens will be standardized to read:

“May Cause Cancer”

GHS Labels

• Three standardized GHS label elements:– Symbols (Hazard Pictograms) that convey health,

physical, and environmental hazard information assigned to a GHS hazard class and category

– Signal Words “Danger” or “Warning” used to emphasize hazards and relative level of severity of the hazard and assigned to a GHS hazard class and category

– Hazard Statements which are standard phrases assigned to a hazard class and category that describe the nature of the hazard

GHS Labels

Red border GHS------

Black border

Transport

GHS Labels

Hazard Classes may have ‘Categories’

GHS Labels

GHS Labels

Example of a Transportation and GHS label combined

Safety Data Sheets (SDS)

• The OSHA ‘Material Safety Data Sheet’ (MSDS) will be called a ‘Safety Data Sheet’ (SDS)

• The MSDS has 8 non-mandatory sections• The SDS would have 12 mandatory and 4 non-

mandatory sections and is essentially the ANSI Z400.1-2004 format– Sections 12-15 are not mandatory and cover

Ecological, Disposal, Transport, and Regulatory information

Safety Data Sheets (SDS)

HCS Appendices

• Appendix A: Health Hazard Criteria• Appendix B: Physical Hazard Criteria• Appendix C: Allocation of Label Elements• Appendix D: Safety Data Sheets• Appendix E: Definition of ‘Trade Secret’• Appendix F: Guidance for Hazard Classification

Regarding Carcinogenicity

GHS Changes in the Future

• The GHS is updated as needed to reflect new technology and scientific developments, or provide explanatory text. Changes to the HCS is anticipated through:– Technical Updates for minor terminology changes

– Direct Final Rules for text clarification

– Notice and Comment Rulemaking for more substantive or controversial updates such as additional or changes in health or safety hazard classes or categories

Industry Groups Challenge HAZCOM Aligned with GHS—Source: Bloomberg BNA

Industry groups petitioned a federal appeals court the week of May 21:

1.CropLife America: possible conflicts between HAZCOM and EPA’s Federal Insecticide Fungicide and Rodenticide Act (FIFRA) requirements for pesticide labeling

Industry Groups Challenge HAZCOM Aligned with GHS—Source: Bloomberg BNA

2. American Chemistry Council and 4 industry groups: OSHA should not address combustible dust in final rule; doing so would transform it into a de facto dust standard

Industry Groups Challenge HAZCOM Aligned with GHS—Source: Bloomberg BNA

3. American Petroleum Institute: criticized mandatory “arbitrary” 20 percent concentration threshold for the classification of chemical mixtures containing target organ toxicity hazards

OSHA should require categories “be based upon science and hazard determination”

Industry Groups Challenge HAZCOM Aligned with GHS—Source: Bloomberg BNA

• We need to wait until these challenges are settled to find out what changes, if any, will be done to the HAZCOM standard