Last-Minute Globally Harmonized System (GHS) Breakdown
Let’s clearly explain the relationship between the Globally Harmonized System (GHS) and OSHA’s Hazard Communication Standard (HCS): each are policies related to chemical and material safety, written to protect workers from the hazards of inherently dangerous substances.
What’s happening is that OSHA has amended its Hazard Communication Standard (HCS) to incorporate elements of the Globally Harmonized System (GHS), a relatively new policy developed by the UN to standardize international hazard communication.
The GHS was written to solve a serious problem—an inconsistent, patchwork regulatory system of different chemical safety laws for different countries, that exposed workers to risk—by providing clarity to chemical manufacturers, importers, and consumers.
OSHA’s Hazard Communication Standard has been in place since 1994—it’s federal law (1910.1200). And so now the HCS is changing to reflect the GHS, and this means that the federal law is also changing and that businesses in the U.S. will have to make adjustments to chemical safety management plans to remain compliant.
Another way to look at it is that the GHS is replacing major parts of the HCS. While the HCS has changed, it will remain the governing law for chemical companies doing business in and with the U.S.
Keep in mind that Hazard Communication (HCS) was OSHA’s second most frequently cited violation in 2014. This is important because June 1st is the compliance deadline for OSHA’s revised HCS, which includes those substantial changes pulled in from the GHS standard.
So, the law has changed significantly and on June 1st, U.S. companies are responsible for compliance with “HCS-2012”.
This ‘last minute GHS breakdown’ will bring you up to speed with this big change in federal chemical safety regulation by exploring how the GHS is being incorporated into the HCS, answer some of the biggest questions out there for private enterprise, and demonstrate how businesses will be directly impacted.
Q: What is the Globally Harmonized System?
A: The Globally Harmonized System (GHS) is an international approach to hazard communication, providing agreed criteria for classification of chemical hazards, and a standardized approach to label elements and safety data sheets. It is based on major existing systems around the world, including OSHA's Hazard Communication Standard and the chemical classification and labeling systems of other U.S. agencies.
The result of this negotiation process is the United Nations' document entitled "Globally Harmonized System of Classification and Labeling of Chemicals," commonly referred to as The Purple Book. This document provides harmonized classification criteria for health, physical and environmental hazards of chemicals. It also includes standardized label elements that are assigned to these hazard classes and categories and provide the appropriate signal words, pictograms, and hazard and precautionary statements to convey the hazards to users. A standardized order of information for safety data sheets is also provided.
Q: How many businesses and workers would be affected by the revised Hazard Communication Standard?
A: OSHA estimates that over 5 million workplaces in the United States would be affected by the revised Hazard Communication Standard (HCS). These are all those workplaces where employees—a total of approximately 43 million of them—could be exposed to hazardous chemicals. Included among these 5 million workplaces are an estimated 90,000 establishments that create hazardous chemicals; these chemical producers employ almost 3 million workers.
Q: What are the estimated overall costs for industry to comply with the revised Hazard Communication Standard?
A: The revised Hazard Communications Standard's (HCS) total cost, an estimated $201 million a year on an annualized basis for the entire United States, is the sum of four major cost elements.
(1) OSHA estimates that the cost of classifying chemical hazards in accordance with the GHS criteria and revising safety data sheets and labels to meet new format and content requirements would be $22.5 million a year on an annualized basis.
(2) OSHA estimates that training for employees to become familiar with new warning symbols and the revised safety data sheet format under GHS would cost $95.4 million a year on an annualized basis.
(3) OSHA estimated annualized costs of $59 million a year for management to become familiar with the new GHS system and to engage in other management-related activities as may be necessary for industry's adoption of GHS.
(4) OSHA estimated annualized costs of $24.1 million for printing packaging and labels for hazardous chemicals in color.
Q: What are the estimated benefits attributable to the revised Hazard Communication Standard (with adoption of GHS standards)?
A: OSHA expects that the modifications to the Hazard Communication Standard (HCS) will result in increased safety and health for the affected employees and reduce the numbers of accidents, fatalities, injuries, and illnesses associated with exposures to hazardous chemicals. The GHS revisions to the HCS standard for labeling and safety data sheets would enable employees exposed to workplace chemicals to more quickly obtain and to more easily understand information about the hazards associated with those chemicals. In addition, the revisions to HCS are expected to improve the use of appropriate exposure controls and work practices that can reduce the safety and health risks associated with exposure to hazardous chemicals.
OSHA estimates that the revised HCS will result in the prevention of 43 fatalities and 585 injuries and illnesses (318 non-lost-workday injuries and illnesses, 203 lost-workday injuries and illnesses, and 64 chronic illnesses) annually. The monetized value of this reduction in occupational risks is an estimated $250 million a year on an annualized basis.
OSHA estimates that the revised HCS will result in savings of $475.2 million from productivity improvements for health and safety managers and logistics personnel, $32.2 million during periodic updating of SDSs and labels, and $285.3 million from simplified hazard communication training.
OSHA anticipates that, in addition to safety and health benefits, the revised HCS will result in four types of productivity benefits: (1) for chemical manufacturers, because they will need to produce fewer SDSs in future years; (2) for employers, in providing training to new employees as required by the existing OSHA HCS through the improved consistency of the labels and SDSs. (3) for firms engaging in, or considering engaging in, international trade.
Q: Why did OSHA decide to modify the Hazard Communication Standard to adopt the GHS?
A: Since it was first promulgated in 1983, the HCS has provided employers and employees extensive information about the chemicals in their workplaces. The original standard is performance-oriented, allowing chemical manufacturers and importers to convey information on labels and material safety data sheets in whatever format they choose. While the available information has been helpful in improving employee safety and health, a more standardized approach to classifying the hazards and conveying the information will be more effective and provide further improvements in American workplaces. The GHS provides such a standardized approach, including detailed criteria for determining what hazardous effects a chemical poses, as well as standardized label elements assigned by hazard class and category. This will enhance both employer and worker comprehension of the hazards, which will help to ensure appropriate handling and safe use of workplace chemicals. In addition, the safety data sheet requirements establish an order of information that is standardized. The harmonized format of the safety data sheets will enable employers, workers, health professionals and emergency responders to access the information more efficiently and effectively, thus increasing their utility.
Adoption of the GHS in the United States and around the world will also help to improve information received from other countries—since the United States is both a major importer and exporter of chemicals, American workers often see labels and safety data sheets from other countries. The diverse and sometimes conflicting national and international requirements can create confusion among those who seek to use hazard information effectively. For example, labels and safety data sheets may include symbols and hazard statements that are unfamiliar to readers or not well understood. Containers may be labeled with such a large volume of information that important statements are not easily recognized. Given the differences in hazard classification criteria, labels may also be incorrect when used in other countries. If countries around the world adopt the GHS, these problems will be minimized, and chemicals crossing borders will have consistent information, thus improving communication globally.
Q: What are the major changes to the Hazard Communication Standard?
A: The three major areas of change are in hazard classification, labels and safety data sheets…
Hazard classification: The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers and that labels and safety data sheets are more accurate as a result.
Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram and hazard statement for each hazard class and category. Precautionary statements must also be provided.
Safety Data Sheets: Will now have a specified 16-section format.
The GHS does not include harmonized training provisions, but recognizes that training is essential to an effective hazard communication approach. The revised Hazard Communication Standard (HCS) requires that workers be re-trained within two years of the publication of the final rule to facilitate recognition and understanding of the new labels and safety data sheets.
Q: What pictograms are required in the revised Hazard Communication Standard? What hazard does each identify?
A: There are nine pictograms under the Globally Harmonized System (GHS) to convey the health, physical and environmental hazards. The final Hazard Communication Standard (HCS) requires eight of these pictograms, the exception being the environmental pictogram, as environmental hazards are not within OSHA's jurisdiction.
Q: How will labels change under the revised Hazard Communication Standard?
A: Under the current Hazard Communication Standard (HCS), the label preparer must provide the identity of the chemical and the appropriate hazard warnings. This may be done in a variety of ways, and the method to convey the information is left to the preparer. Under the revised HCS, once the hazard classification is completed, the standard specifies what information is to be provided for each hazard class and category. Labels will require the following elements:
Pictogram: a symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond). There are nine pictograms under the GHS. However, only eight pictograms are required under the HCS.
Signal words: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for less severe hazards.
Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling of a hazardous chemical.
Q: How will chemical hazard evaluation change under the revised Hazard Communication Standard?
A: Under both the current Hazard Communication Standard (HCS) and the revised HCS, an evaluation of chemical hazards must be performed considering the available scientific evidence concerning such hazards. Under the current HCS, the hazard determination provisions have definitions of hazard and the evaluator determines whether or not the data on a chemical meet those definitions. It is a performance-oriented approach that provides parameters for the evaluation, but not specific, detailed criteria. The hazard classification approach in the revised HCS is quite different.
The revised HCS has specific criteria for each health and physical hazard, along with detailed instructions for hazard evaluation and determinations as to whether mixtures or substances are covered. It also establishes both hazard classes and hazard categories—for most of the effects; the classes are divided into categories that reflect the relative severity of the effect. The current HCS does not include categories for most of the health hazards covered, so this new approach provides additional information that can be related to the appropriate response to address the hazard. OSHA has included the general provisions for hazard classification in paragraph (d) of the revised rule, and added extensive appendixes (Appendixes A and B) that address the criteria for each health or physical effect.