Globally Harmonized System For Hazard Communication

The Globally Harmonized System (GHS) for Hazard Communication was first introduced to our membership at the GAWDA University Compliance Training in Indianapolis in spring 2006. Since then, additional measures have been taken toward the development of a worldwide system for hazard communication. Since this system will impact you, let’s take a look at what’s going on in this international arena.

Background
In 1992, an international mandate to develop a globally harmonized system for hazard classification and labeling was adopted at the United Nations Conference on Environment and Development, commonly referred to as the Earth Summit. In 2003, the United Nations adopted the GHS. Countries are now considering adoption of the GHS into their national regulatory systems. There is an international goal to have as many countries as possible implement the GHS by 2008.

The U.S. was an early and active supporter of a globally harmonized approach to hazard communication. OSHA sent its Advance Notice of Proposed Rulemaking regarding the hazard communication standard and the GHS to the Office of Management and Budget for review. Since then, OSHA has published the Advance Notice of Proposed Rulemaking in the September 12, 2006, Federal Register, seeking public comments on the implementation of the GHS. The Compressed Gas Association (CGA), along with input from GAWDA, will be submitting position(s) on the GHS. These steps follow prescribed principles in rulemaking that will allow for consideration of alternatives and analysis of benefits and costs. The advance notice details how OSHA expects implementation of the GHS to affect the current requirements for hazard communication.

What Is the GHS?
The GHS is a common and coherent approach to defining and classifying hazards and communicating information on labels and Material Safety Data Sheets (MSDSs). The target audience includes workers, consumers, transport workers and emergency responders. It will provide the underlying infrastructure for the establishment of a national, comprehensive chemical safety program.

Why Is the GHS Needed?
Internationally, there are a number of countries that have developed similar laws to the hazard communication standard of the United States. However, the laws are different with regard to the scope of chemicals covered, classification of hazards chemicals, labeling requirements, safety information and the use of symbols and pictograms. These differences create confusion, putting the targeted audience at risk. In addition, the GHS should simplify labeling requirements and information provided in MSDSs for those who work in the global market.

How Will the GHS Impact You?
  1. The GHS should standardize the classification of chemicals around the world. For example, a product may be considered flammable or toxic in one country, but not in another to which it is being shipped.
  2. The GHS should standardize labeling, symbols and pictograms for all chemicals. Development of multiple sets of information is a major compliance burden for those involved in international trade, and it is confusing for the intended audience.
  3. The GHS should standardize MSDSs where the basic content and format will be recognized by all nations.
  4. The GHS will require that our Hazard Communication Standard be revised to reflect the GHS.

As with all new proposed OSHA standards that can impact our industry, GAWDA will track the rulemaking process of the GHS. As new and meaningful information becomes available, it will be communicated to our membership.



Gases and Welding Distributors Association
Meet the Author
GAWDA OSHA & EPA Consultant Thomas W. Eynon is senior associate at B&R Compliance Associates LLC, based in Merritt, North Carolina. Members can reach him at (252) 745-7391 and at tom.eynon@brcompliance.com.