GHS and The 2012 Hazcom Standard:

What You Need To Think About Now

June 27, 2012LabelmasterPaul Burgess, Regulatory Specialist

Objectives for this Presentation

• History of Hazard Communications• Introduction to the GHS• The Hazcom/GHS Link up• Timeline and Impact – What You

Need to Think About NOW

A Little History• Early 70s – OSHA (Occupational Safety and

Health Administration) Established in USA

• 1983 – Hazard Communication Rule (29 CFR 1910.1200) Initial Promulgation

• 1992 – Rio De Janeiro UN Conference Sets Goal of a “Globally Harmonized System” of Hazard Communication in Transportation and Workplace by the Year 2000

What is GHS?• GHS (Globally Harmonized System) Joint

Global Framework of Guidelines Classifying and Communicating Chemical Hazards

• UN Created GHS, Updates as Conditions and Knowledge Change

• Current Iteration: 4th Revision. OSHA Hazcom Based on 3rd Revision

“GHS” Itself is NOT:

• A Law

• A Regulation

• A Legal Standard

• An Industry Best Practice

GHS is an Agreed Framework which Countries, Groups and other Interested or Affected Bodies can use to Create Harmonized Versions of the Above

What is GHS (What it Isn’t)?

Let’s Talk Hazcom• “Hazcom” Accepted Term for the HCS, or

“Hazard Communication Standard”

• Legal Text Found Under US 29 CFR 1910.1200

• Provides for the Required Communication of Workplace Chemical Hazards to Employees Working in the United States

• Extant Since 1983

• Affects More Than 40 Million Employees

• Impacts 5 Million Workplaces

• Provides Hazard Communication Guidelines Related to Nearly 900,000 Chemicals

• “One Employee, One Chemical” Baseline

• Governed by OSHA (US Executive Branch)

Let’s Talk Hazcom

Who is AffectedChemical Manufacturers &

Distributors• Chemical Producers Must Classify Products and

Provide Appropriate Hazard Warning Labeling and Safety Data Sheets (SDS) for Each Substance

• Must be Provided to Downstream Shippers and/or Users

• Distributors/Importers Must Distribute the Same Information to Customers

Employers• Provide Written Hazard Communication Plan

• Provide Accurate, Up-to-Date Inventory of the Chemicals on Their Premises & In Use by Their Employees

Who is Affected

Employers• Appropriate Labeling Systems to Provide

Communication and Hazard Warning

• Provide Accurate Library/Database with SDS for Their Chemical Inventory

• Provide Access Under “Right to Know” Law

• Train Employees to Use and Understand the System

Who is Affected

The Impact of GHS

Divergence Leads to Confusion• Globally, Countries Used Divergent Hazard

Communication Methods

• Divergent Systems have Negative Impact on Global Trade

• Designed to Address Previous International Issues by Harmonizing Global Hazard Communications

• Improved Cross-border/International Communication Breaks Through Some Trade Barriers

The Impact of GHS

Benefits of GHS• Full Implementation will Make Hazcom

Understandable from “Tokyo to Timbuktu”

• Ease Burden of Hazard Communication for Global Trade/Remove “Technical Barrier” Some Countries Use

• Allow Workers to Change Jobs & Maintain Familiarity with the System

2009 – OSHA Tests the Water

• Proposed Rule Released in 2009

• Extensive Revisions

• Determine Best Policy Introduction of GHS to US Hazcom

• Avoid Undue Economic Impact to Present and Future Business Operations (i.e. the Regulatory Burden Issue)

March, 2012 – OSHA Acts

• The New Hazcomm Standard Promulgated as a Final Rule

• Effective Date: May 25th, 2012

• The Standard is Now in Place in the US

What Does it Do?• Keeps Most Basic Elements of old Hazcom

Standard in Place

• Changes the “How”

• Increases Worker Protection by Enhanced Requirements for Hazard Communication & Classification

• Uses the GHS Rev. 3 as Baseline

The Gorilla in the Room

• Biggest Change to HCS is Chemical Classification, Now Under Stringent Guidelines in the GHS Document

• Eliminates “Wiggle Room”

The Gorilla’s Buddy: SDS

• New Standard Converts Current Material Safety Data Sheets (MSDS) to Safety Data Sheets (SDS)

• Sections Harmonized with International Requirements

• Significantly More Information about Product, Use & Handling

SDS: The Good News• SDS Largely Based on MSDS Format

• SDS More Comprehensive, Largely “Apples to Apples”

• Many Companies Already Started Conversion

• Affects Chemical Manufacturers Mostly

The Last Gorilla: Labeling

• GHS Labeling Largely Reflects Usage by USDOT/ICAO/IMO Transport World

• Internationally Recognized Pictograms

• Designed to Limit Need for Language Conversion from Country to Country

Implementation Dates

Dec. 1, 2013

Employers must train employeeson the new label elements and safety data sheet (SDS) format

Chemical manufacturers,importers, distributors andemployers must comply with all modified provisions

June 1, 2015 Dec. 1, 2015

Distributors begin shippingcontainers labeled by thechemical manufacturer orimporter with a HCS label

June 1, 2016

Employers must updatealternative workplace labelingand hazard communicationprograms as necessary andprovide additional employeetraining for newly identifiedphysical or health hazards

GHS Hazard Classifications

Physical Hazards• Explosives• Flammable Gases,

Aerosols, Liquids, Solids• Oxidizers• Self-Reactives• Self-heaters• Pyrophorics• Organic Peroxides• Corrosives• Pressurized Gases• Dangerous When Wet

Health/Environmental• Acute Toxicity• Aspiration• Skin Corrosion and Irritation• Respiratory and/or Skin

Sensitization• Mutagenicity• Carcinogenicity• Reproductive Damage• Organ Toxicity, Single and

Multiple Doses• Danger to Aquatic

Environment

Severity of Danger

• Major Change, Evaluates DEGREE of Danger

• Strict Guidance for Setting Levels

• GHS Reverses “Lower is Better” Expectation in the US

Label Elements

• Strictly Constructed Pictographic and Textual Information for Use on Hazard Warning Labels

• Symbols Familiar to Users of Transport-based Labeling Systems

• Deliberate Goal of the GHS Alignment

Label Elements

What You Need To Think About Now

Train Your Employees• December 1, 2013 Establishes that ALL

Employees be Trained

• Most Employers Conduct “Right to Know” Training Yearly

• Now is Optimal Time to “Convert”

• This is a Large Change—Don’t Wait Until the Last Minute

How Can Labelmaster Help?

Full Line of GHS Compliant:• Training Program & Materials• SDS Binders• Software & Printer

How Can Labelmaster Help?• Pictograms & Mini Pictograms

• Custom Labels

• Drum Labels

Additional Assistance

• Regulatory Staff to Assist Planning

• Continual Monitoring & Updating of the Rules

Resources

• Labelmaster.com• GHS Liaison: Paul Burgess,

PBURGESS@labelmaster.com• Extensive information and assistance

available on Department of Labor/OSHA websites

• Information on the UN GHS Program Itself Can Be Found on the UN Website

• Many Local Governments also Offer Assistance

If We Do Not Get To Your Question Today, Please Email

PBURGESS@labelmaster.com

Q & A