So far, in part 1 we looked at what the GHS was and why OSHA adopted it. Then, in part 2 we looked at the timeline for implementation as well as what the major changes involved are. Today, in our final post on the GHS we are going to look at a few miscellaneous issues involved with the GHS as well as talk about one or two major ommissions.
What the GHS IS NOT changing
A couple of things that are not changing (This is a good thing), is the fact that TLVs (Threshold Limit Values) and PELs (Permissible Exposure Levels) will remain on all documentation. The reason I believe this to be a good thing is because these are numbers that we’ve grown very used to in the safety industry and users and manufacturers alike look for them to decide how safe they are based on exposure to the said chemical.
In addition to the TLV and PEL, OSHA is keeping the IARC (International Agency for Research on Cancer) as well as the NTP (National Toxicology Program) classifications. This should make it clear whether or not the chemical is a known carcinogent and allow users to make educated choices about the level of exposure to chemicals that are known or suspected of causing cancer.
What GHS does not cover
Unfortunately, OSHA still hasn’t dealt with issue of combustible dust. We’ve talked before about this inexplicable inactivity on the part of OSHA and apparently it continues with GHS. This from the OSHA website on this matter:
OSHA has not provided a definition for combustible dust to the final HCS given ongoing activities in the specific rulemaking, as well as in the United Nations Sub-Committee of Experts on the GHS (UN/SCEGHS). However, guidance is being provided through existing documents, including the Combustible Dust National Emphasis Program Directive CPL 03-00-008, which includes an operative definition, as well as provides information about current responsibilities in this area. In addition, there are a number of voluntary industry consensus standards (particularly those of the NFPA) that address combustible dust.
In the final HCS, combustible dust hazards must be addressed on labels and SDSs. Label elements are provided for combustible dust in the final HCS and include the signal word “warning” and the hazard statement “May form combustible dust concentrations in the air”.
For chemicals in a solid form that do not present a combustible dust hazard, but may form combustible dusts while being processed in normal downstream uses, paragraph (f)(4) of the HCS allows the chemical manufacturer some flexibility in labeling requirements. The manufacturer or importer to may transmit the label to the customer at the time of the initial shipment, but the label does not need to be included with subsequent shipments unless it changes. This provides the needed information to the downstream users on the potential hazards in the workplace, while acknowledging that the solid metal or other materials do not present the same hazards that are produced when these materials are processed under normal conditions of use.
While any effort is welcome, this does not seem to go far enough and until it is properly addressed, further deaths and injuries will be inevitable.
The bottom line on the GHS is that an estimated 5 million places of business and some 46 million workers in the US will have a clear, more manageable way to track, catalog and understand the health and environmental hazards associated with the chemicals that they are using. While the initial cost of implementing GHS runs into the hundreds of millions, ultimately the saving of lives, health care expenses, trying to “interpret” and “translate” the different standards from different countries will make the cost worth it. It is an issue that has needed to be addressed for too long. OSHA estimates that this change will prevent 43 and almost 600 injuries each year. That’s substantial. While the issue of combustible dust remains a disappointment, the implementation of the GHS is monumental in helping promote better safety regarding the use of various chemicals in the workplace.