1. GLOBALLY HARMONIZED
SYSTEM for HAZARD
COMMUNICATION
David Wallace, CIH
Sr. Lecturer, Utah State University
Nevada Local Section, AIHA
March 9, 2011

2. Outline
• GHS overview
• OSHA’s GHS activity
• Proposed changes to the Hazard
Communication Standard
• Current status of the proposed standard
• Impact on Safety professionals
2

3. Introduction
• In 1985, one of my jobs as a “young”
industrial hygiene professional was
helping my employer comply with
OSHA’s new Hazard Communication
standard, 1910.1200.
• Now, it looks like we will need to do it
again!
3

4. Introduction
• AIHA
online
GHS
course,
if you
want to
learn
more!
4

5. GHS Overview
• “Globally Harmonized System Of
Classification And Labeling Of Chemicals”
– United Nations guidance for a uniform
(harmonized) hazard communication system
• Initiated at the 1992 United Nations Conference on
Environment and Development (UNCED)
– Based on ”major” existing systems
• USA and Canadian systems for the workplace,
workplace, consumers and pesticides
• European Union directives for classification and labeling
of substances and preparations
• United Nations Recommendations on the Transport of
Dangerous Goods.
5

6. GHS Overview
• Elements
GHS “Purple Book”
– Harmonized criteria for
classifying substances and
mixtures according to their
health, environmental and
physical hazards
– Harmonized hazard
communication elements,
including requirements for
labeling and safety data sheets.
– Guide to the GHS (OSHA)
6

7. GHS Overview
• Justification
– Label requirements differ, requiring multiple
labels for the same product
– Hazard definitions are not consistent
• Toxicity, Flammability
– Globally over 100 diverse hazard
communication regulations for their products
globally
• Regulatory compliance is complex and costly
• Barrier to international trade in chemicals
7

8. 8

9. 9

10. Flammability example
10

12. Flammability Example
• OSHA letter of interpretation, July 14, 2010
– Re: The definitions of combustible and flammable liquids
under 29 CFR 1926 and 29 CFR 1910.
– Question: Why are the definitions for combustible liquids
and flammable liquids different under OSHA's construction
and general industry standards?
– Answer: The definitions in the two standards are different
because the definitions were adopted from different sources.
OSHA is currently addressing these definitions in the Hazard
Communication rulemaking. [GHS}
– http://www.osha.gov/pls/oshaweb/owadisp.show_document?
p_table=INTERPRETATIONS&p_id=27488
12

13. GHS Overview
• Key Guiding Principles of the Harmonization
Process
– Protection will not be reduced
– Will be based on intrinsic properties (hazards) of
chemicals
– All types of chemicals will be covered
– All systems will have to be changed
– Involvement of all stakeholders should be ensured
– Comprehensibility must be addressed
13

14. GHS Hazard
Classification
• Defined criteria are used to assign a hazard
classification
– Physical Hazards
• 16 categories
– Health Hazards
• 10 categories
– Environmental Hazards
• Mixtures
– GHS classification guidance for when chemicals
are mixed
14

15. GHS Hazard
Classification
• Physical Hazards (16)
–
–
–
–
–
–
–
–
Explosives
Flammable Gases
Flammable Aerosols
Oxidizing Gases
Gases Under Pressure
Flammable Liquids
Flammable Solids
Self-Reactive
Substances
–
–
–
–
–
–
–
–
Pyrophoric Liquids
Pyrophoric Solids
Self-Heating Substances
Substances which, in
contact with water, emit
flammable gases
Oxidizing Liquids
Oxidizing Solids
Organic Peroxides
Corrosive to Metals

16. GHS Hazard
Classification
• Health Hazards (10)
– Acute Toxicity
– Skin Corrosion/Irritation
– Serous Eye
Damage/Eye Irritation
– Respiratory or Skin
Sensitization
– Germ Cell Mutagenicity
– Carcinogenicity
– Reproductive Toxicology
– Target Organ Systemic
Toxicity – Single
Exposure
– Target Organ Systemic
Toxicity – Repeated
Exposure
– Aspiration Toxicity
16

17. GHS Hazard
Classification
• Hazardous to the Aquatic Environment
– Acute aquatic toxicity
– Chronic aquatic toxicity
• Bioaccumulation potential
• Rapid degradability
17

18. • Labels
GHS Hazard
Communication
– Symbols (hazard pictograms) with red border
• Examples:
18

19. GHS Hazard
Communication
• Labels (cont.)
– Nine symbols
• Includes
“Environment”
19

20. GHS Hazard
Communication
• Labels (cont.)
– Signal Words
• “Danger” or “Warning”
– Hazard Statements
• Example: “Toxic if swallowed”
– Other
• Precautions, identification, supplier, supplemental
20

21. GHS Hazard
Communication
• Labels (cont.)
– GHS Label Elements for Flammable Liquids
21

22. GHS label example
22

23. GHS Hazard
Communication
•
GHS Safety Data Sheet (SDS)
–
–
16 headings
Similar to ISO, EU, and ANSI MSDS/SDS
requirements
23

24. OSHA MSDS format (old)
•
OSHA-174 (1989), 8 sections (nonmandatory)
1.
2.
3.
4.
5.
6.
7.
8.
Manufacturer information
Hazard Ingredients/Identity Information
Physical/chemical properties
Fire and Explosion Hazard Data
Reactivity Data
Health Hazard Data
Precautions for Safe Handling and Use
Control Measures
24

25. ANSI MSDS format
•
ANSI Z400.1-2004
1. Product and Company
Identification
2. Hazard Identification
3. Composition /
Information On
Ingredients
4. First Aid Measures
5. Fire Fighting
Measures
6. Accidental Release
Measures
7. Handling and Storage
8. Exposure Control /
Personal Protection
9. Physical and Chemical
Properties
10. Stability and Reactivity
11. Toxicological Information
12. Ecological Information
13. Disposal Considerations
14. Transport Information
15. Regulatory Information
16. Other Information
25

26. OSHA and the GHS
• Rulemaking Steps
– Advance Notice of Proposed Rulemaking,
ANPR
• Sept. 12, 2006
– Notice of Proposed Rulemaking
• Sept. 30, 2009
• Public Comment Period ended Dec. 29, 2009
• Public Hearings
– Washington, Pittsburgh and Los Angeles
– March and April, 2010
• Post-hearing Comment Period ended June 1, 2010
– Final Standard
• Probably by late 2011, according to OSHA staff
– Phase-in Period for Compliance
26

27. Proposed OSHA rule
•
Major changes to the Hazard Communication
Standards
–
–
–
–
–
–
Changed “hazard determination” to “hazard
classification”
Changed “MSDS” to “SDS”
Changed definitions to comply with GHS
Labels for shipped containers must have GHS
information
• Workplace labels may be GHS labels, or other
labels that identify the material and hazard
Safety Data Sheets with 16 sections
• May include guidance for transportation
information and environmental hazards
27
Side-by-side comparison (OSHA)

28. Proposed OSHA rule
•
Major changes to the Hazard Communication
Standards (cont.)
– Other OSHA standards are changed where
applicable
•
•
New wording on warning signs for asbestos
and other health hazards
Changes to standards for HAZWOPER,
Combustible and Flammable Liquids, Welding
Cutting and Brazing, etc.
28

29. Proposed OSHA rule
• Effective dates
– Two years after final rule
• Employee training on new labels and safety
data sheets
– Three years after final rule
• Chemical manufacturers, importers,
distributors, and employers in compliance with
all modified provisions
29

30. Proposed OSHA rule
• Costs and benefits
– $97 million annual cost
• training, SDSs & labels, management
– $851 million annual benefit
• reduced injuries/illnesses/fatalities, improved
productivity and cost reduction
– $754 million net annual benefit
30

31. OSHA interpretation
• GHS labels comply with current OSHA
requirements
– Standard Interpretation 10/06/2009 - Using
the Globally Harmonized System (GHS) to
Comply with OSHA's Hazard
Communication Standard
– http://www.osha.gov/pls/oshaweb/owadisp.show_
31

32. Comments on the proposed
rule
• OSHA specifically solicited comments about:
–
–
–
–
–
–
–
Costs and benefits
Effect on “small entities”
GHS classification system
Combustible dusts and simple asphyxiants
Color labels vs. B&W
PELs on data sheets
Etc.
• Public Hearings ended April 13, 2010
• Record closed June 1, 2010 (877 items)
32

33. Comments on the proposed
rule
• Maureen Ruskin, director of OSHA's Office of
Chemical Hazards, at GHS Round Table, 5/24/2010,
AIHCE, Denver, Co
–
–
–
–
–
–
–
–
–
Vast majority of comments support OSHA
OSHA should adopt EU reporting limits for chronic hazards
Create “hazards not otherwise classified” category
Support and criticism of proposal to drop TLVs
Updating labels within 30 days may not be feasible
OSHA may have underestimated cost of red border
Mixed support for adoption of GHS hazard statements
Disagreement about implementation dates
OSHA should provide more information for training
33

34. Comments on the proposed
rule
• OSHA’s update (cont.)
– Some believe OSHA will create confusion with changes to
flammable/combustible liquid classification, yet others
agreed with OSHA
– OSHA should review safety standards to avoid conflicts
– Concerns over carcinogen notation changes in the health
standards
– Concerns about conflict or confusion regarding
EPA/DOT/NFPA
– OSHA underestimated costs
– Very little support for OSHA’s proposed alternatives
– How will OSHA respond after UN updates GHS?
34

35. ASSE’s comment
• “ASSE applauds OSHA for its
leadership in undertaking this
rulemaking and urges that every
possible step be taken to achieve a
final rule as soon as practicable.”
• However, ASSE has some concerns:
–
–
–
–
–
–
–
–
–
OSHA should include “control banding”
OSHA underestimated the impact on small business
Some hazard classifications should be modified
OSHA should require red borders on labels
Labels should have more required information
TLV and REL exposure limits should be listed on data sheets
The new standard should have a shorter deadline for training
There may be a shortage of SH&E professional on staff
35
Etc.

36. AIHA’s comment
• “AIHA supports the proposed revision
of the HCS and believes it will result
in better hazard recognition and safer
use of chemicals in the workplace.”
• AIHA’s generally supports OSHA:
– Proposed hazard classifications are OK
– OSHA should require red borders on labels
– TLVs , WEELs and other exposure limits should be listed on
data sheets
– OSHA should include a hazard category for combustible dust
– Training should not be delayed
• AIHA also submitted a post-hearing comment, April 29, 2010
to answer OSHA questions
36

37. OSHA’s Schedule
• Record closed June 1
• Tasks:
– Analyze information in the record
– Prepare the final rule and update the analyses of
the record
– Submit rule for administrative review
– OSHA, DOL, OMB
• This is high priority for OSHA
– Expect final standard about 1 ½ years (?)
37

38. Recent GHS activity
• United Nations Subcommittee of Experts on
the Globally Harmonized System of
Classification and Labelling of Chemicals
(UNSCEGHS), Dec. 7-9, 2010, in Geneva
• OSHA hosted an open informal public
meeting of the U.S. Interagency GHS
Coordinating Group, Nov. 20, 2010.
– To provide interested parties with an update on
GHS issues in preparation for the UN meeting
– http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table
38

39. OSHA’s Schedule
• Dr. David Michaels, Assistant Secretary of
Labor for OSHA
– June 16, 2010 at the Baltimore ASSE conference:
the Global Harmonized System standard –a
“non-controversial rule” – has received good
comments and is moving along on target
• Source: Occupational Health and Safety online
magazine
39

40. • OSHA’s Fall 2010 Regulatory Agenda,
http://www.dol.gov/osha/regs/unifiedagenda/fall2010/1218-A
Timetable:
Action
Date
FR Cite
ANPRM
09/12/2006
71 FR 53617
ANPRM Comment Period End
11/13/2006
Complete Peer Review of Economic Analysis
11/19/2007
NPRM
09/30/2009
NPRM Comment Period End
12/29/2009
Hearing
03/02/2010
Hearing
03/31/2010
Post Hearing Comment Period End
06/01/2010
Final Action
08/00/2011
74 FR 50279
40

41. Commercial GHS services
• Commercial Hazard Communication and
MSDS/SDS authoring services should be
“ready” for GHS
– Required for international trade
– Preparing for domestic market
• Examples:
– http://3ecompany.com/solutions/ghs-solutions/
– http://www.sitehawk.com/ghs_home.html
41

42. GHS in the commercial
news
• Industry Week
– How to Convert to the Globally Harmonized System of Chemical Cla
• EHS Today
– GHS: The Power of One
• OH&S
– Major GHS Progress This Year
– OSHA's GHS Leader Sees Final Rule in 18 Months
– Global Harmonization — A Catalyst for Safety
– OSHA, GHS, and Your MSDSs and Labels
– A Picture is Worth a Thousand Words
– OSHA Finally Brings GHS to America
42

43. Impact on Safety and IH
Professionals
• Become familiar with the new system
– May want to wait until the OSHA rule is “final”
• Collect new SDSs as provided by suppliers
and incorporate them into the existing MSDS
system (or use a commercial service)
• Get new GHS labels for “shipped containers”
– Employers can use other systems for workplace
labeling
• Train employees about new labels and SDS
43

44. Impact on Chemical
Manufacturers and
Distributors
• Prepare and use new GHS compatible labels
• Prepare and distribute new GHS compatible
Safety Data Sheets
• Commercial “authoring” firms are ready and
willing to help
44

45. GHS Resources
• GHS Websites
– OSHA, http://www.osha.gov/dsg/hazcom/global.html
– EPA,
http://www.epa.gov/oppfead1/international/globalharmon.htm
– DOT http://www.phmsa.dot.gov/hazmat/regs/international
– CSPC, http://www.cpsc.gov/phth/GHSpolicy.html
– UN,
http://www.unece.org/trans/danger/publi/ghs/ghs_rev02/02file
s_e.html
• Government Printing Office
– http://www.gpoaccess.gov/ [this site will be replaced with the
Federal Digital System, http://www.gpo.gov/fdsys/]
• OSHA comments
– Docket No. OSHA-H022K- 2006-0062 at
http://www.regulations.gov
• Nearly 900 items!
45