Understanding GHS (Part 3)



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.

Bottom Line
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.

Understanding GHS (Part 2)

Yesterday we defined the GHS and explained why OSHA decided to adopt it in Understanding GHS (Part 1). Today we are going to look at the timeline for phasing in GHS as well as understanding what the major changes are going to be.

GHS phase-in timeline
December 1, 2013 – employees need to have completed the training on the new labels and MSDS.
June 1, 2015 – Compliance with all modified provisions for anything being produced by manufacturers, importers and distributors of chemicals.
December 1, 2015 – Nothing is shipped without the new GHS labels and MSDS (the period between June 1 and December 1 is intended to allow for the clearing out of old stock that might not yet have the new GHS data).
June 1, 2016 – Every place of business that uses chemicals should be compliant with GHS.

Major Changes
Hazard Classification – This is perhaps the big change. The GHS establishes specific criteria for the classification of health hazards. It gives clear hazard classes and categories that clearly outline the severity of the effect.
Labels – The labels will have signal words, pictograms and hazard statements for each hazard class and category. There are nine pictograms and hazards. The following table from the OSHA website that outlines the new GHS breaks it down best:

HCS Pictograms and Hazards

Health Hazard
Exclamation Mark
Reproductive Toxicity
Respiratory Sensitizer
Target Organ Toxicity
Aspiration Toxicity
Emits Flammable Gas
Organic Peroxides
Irritant (skin and eye)
Skin Sensitizer
Acute Toxicity (harmful)
Narcotic Effects
Respiratory Tract Irritant
Hazardous to Ozone Layer
(Non Mandatory)
Gas Cylinder
Exploding Bomb
Gases under Pressure Skin Corrosion/ burns
Eye Damage
Corrosive to Metals
Organic Peroxides
Flame over Circle
(Non Mandatory)
Skull and Crossbones
Oxidizers Aquatic Toxicity Acute Toxicity (fatal or toxic)

Safety Data Sheets – Finally, the safety data sheet will have 16 specific sections to it. These are:

Section 1. Identification
Section 2. Hazard(s) identification
Section 3. Composition/information on ingredients
Section 4. First-Aid measures
Section 5. Fire-fighting measures
Section 6. Accidental release measures
Section 7. Handling and storage
Section 8. Exposure controls/personal protection
Section 9. Physical and chemical properties
Section 10. Stability and reactivity
Section 11. Toxicological information
Section 12. Ecological information
Section 13. Disposal considerations
Section 14. Transport information
Section 15. Regulatory information
Section 16. Other information, including date of preparation or last revision

Check back on Monday when we’ll continue looking at the GHS.

Understanding GHS (Part 1)

Whether you’re aware of it or not, the way we categorize and label our chemicals is changing. By June 1, 2015 all labels and material safety data sheets (SDS) will have been updated to reflect this change. This change is known as the GHS and we are going to spend the next few days breaking it down for you and hopefully making it simple enough to understand and comply with.

What is the GHS?
GHS stands for Globally Harmonized System (GHS) and it seeks to classify and label of chemical. As its name implies, it is first of all an international effort. It is intended to standardize the labelling and data sheets according to health, physical and environmental hazards. After all, the physical properties of chemicals and how they interact with the body, how they effect our health and how they effect the environment doesn’t change just because that particular chemical crosses a border. If it’s dangerous in France, it’s dangerous in Norway too. Because chemicals are being shipped all over the world a standardized system is going to greatly reduce the amount of work involved in the present system which requires relabelling each and every chemical the comes in the country so that it matches the American standard which isn’t necessarily the same as the country from which it is imported.
The GHS is a combination of OSHA’s Hazard Communication Standard, the chemical labeling and classification systems of other US agencies as well as the systems utilized in many countries and international organizations around the world. Much like the European road signs, it is going to use symbols and pictograms as much as possible to bridge the language barrier. We will look at these shortly.

Why did OSHA adopt the GHS?
While the Hazard Communication Standard (HCS) was put into effect in 1983, it has never required chemical manufacturers to communicate the information about the hazards in any specific format. Every manufacturer was free to design the label with the information in whatever format they decide upon. The result has been a complex variety that often makes locating the specific information difficult and time consuming. Additionally, because standards, ways of measuring, units of measure, etc… vary from country to country, there is often a considerable amount of work involved in trying to “translate” and convert the information into something that makes sense according to the HCS. Symbols and hazard statements from one country may be totally unfamiliar in another, causing confusion and potentially increasing the danger when that chemical is used.
Although initially, the GHS is going to require a considerable amount of work seing as essentially every label and every MSDS sheet is going to have to be rewritten for each and every chemical in use any where in the world, it will ultimately save hundreds of thousands of man hours each year because of the number of new chemicals being manufactured and exported each year.

Tomorrow we will continue with this topic with Understanding GHS (Part 2)

GHS is going to mean a whole lot of work

In case you aren’t familiar with it GHS stands for Global Harmonized System of Classification and Labeling of Chemicals. What we are essentially talking about here is a standardization of all MSDS sheets, not only nationally (within the US) but internationally as well. This means that if I produce anything that has an MSDS sheet associated with it I’m going to have to redo that MSDS sheet (as well as the labels that go on all the products) to conform to the new GHS standard.

Because different countries have different safety standards and requirements, the old MSDSs will have to be updated to give the type of information that each country requires. In the words of the United States Department of Labor “OSHA’s proposal to adopt the GHS will not change the framework and scope of the current HCS but will help ensure improved quality and more consistency in the classification and labeling of all chemicals. This will enhance worker comprehension, resulting in appropriate handling and use of chemicals.” In other words, not necessarily new information, just better information and consistency across the board for all chemicals.

What does this mean?

  • 40 million workers are going to be affected by this change in the US alone
  • It will impact some 5 million workplaces
  • It will require changes and rewriting of some 1 million documents
  • It will cost $11 million a year to update all the MSDS sheet (for a total of 3 years)
  • It will cost $42 million a year to retrain workers on the new standard

While this may sound like a lot of money, OSHA estimates that the new standard will save 43 lives and prevent 585 injuries and illness a year for an annual savings of $754 million a year.

Take heart if you are in one of these categories, this isn’t going to happen overnight. The proposed time frame at this point in time is 3 years to complete compliance. That should give you a little time to get things straightened out.

You can view “Facts on Aligning the Hazard Communication Standard to the GHS” on the OSHA website.