|Understand your MSDS with the MS-Demystifier||Search ALL our MSDS info|
|Globally Harmonized System of Classification and Labeling of Chemicals|
In the US, OSHA can not adopt GHS principles without an act of Congress to authorize the changes. After years of discussion, the first step in this regulatory process was intiated with OSHA's publication of an Advanced Notice of Proposed Rulemaking (ANPR) on September 12, 2006. A 60 day comment period received over 100 written and electronic comments (select HAZARD COMMUNICATION (H022K) from the browse list). The responses generally supported adoption and highlighted the need for harmonization.|
On September 30, 2009, OSHA published its proposed rulemaking to incorporate changes per the GHS (US Federal Register 74:50279-50549). You can view this document in HTML on OSHA's web site or download it as PDF file from the US Government Printing Office. The Public Comment period ended December 29, 2009 and gathered several hundred written comments that are available here.
In understanding how the GHS will ultimately affect Hazard Communication in the US, it is important to remember that the GHS is a model standard and is not meant to be approved and implemented as written. For example, OSHA's HCS currently covers acute toxicity with respect to MSDSs. The GHS's coverage of acute toxicity is quite broad, covering consumer protection in addition to occupational concerns. As OSHA has no regulatory authority for consumer issues/products, the HCS will not be able to incorporate all the changes to acute toxicity that the GHS suggests.
Now that the rulemaking process had been set in motion, it appears that US adoption of (parts of) the GHS is inevitable. There is no fixed timetable for this process, and it will likely be phased in over a period of years. As these changes are enacted, they will result in the first significant changes to MSDS's and labeling in the US since the OSHA Hazard Communication Standard's last update which took effect in March of 1994. A detailed comparison between the GHS and OSHA HCS systems is available on OSHA's web site. The major effects on MSDS's are discussed in the next section.
Be up to date with Federal regulations with searchable hypertext PDF CD-ROMs from Safety Emporium.
Note: OSHA is not the only US federal agency involved in implementing GHS. For additional agency GHS web sites see:
Some GHS resources for other countries include:
GHS adds some additional required content for Safety Data Sheets (SDS) and changes the way that some information is currently reported on MSDS's. For example, the GHS calls for including the recommended use of the chemical and restrictions on its use. GHS classifications of the substance/mixture and any regional information must be included. GHS labeling elements must be reproduced, either graphically or in text. For the first time, sheets will be required to list the CAS number of the hazardous components. Hazardous impurities must also be disclosed.
Additional differences include accidental release measures for containment and cleanup as well as concise but complete toxicological and ecological information (such as ecotoxicity, bioaccumulation potential), mobility in soil, persistence, and degradability). Note, however, that OSHA has no authority over environmental issues, the domain of the EPA, so these parts will likely be recommended but not mandatory in the US. Likewise, the GHS requires transportation information such as the UN Number, proper shipping name, packing group, and more, but, again, OSHA has no authority over such matters (which fall under DOT). In short, some of the GHS changes will be mandatory when the HCS is revised, but some will not be!|
The criteria for MSDS component disclosure also differs between the two systems. The level of hazardous components can be given as ranges or concentrations under GHS, whereas the HCS specifies percentages.
Under the current HCS, MSDS's are only updated when changes are made to the material or new hazards are discovered. The GHS recommends setting a specific time period (3-5 years) for review of the information, something that Canada already requires under WHMIS.
Many of the health and physical hazard definitions differ between the HCS and GHS. Again, see the detailed comparison between the GHS and OSHA HCS systems for more information. Remember, the GHS is a model standard, so it is not simply approved and implemented as written, so not all of its clauses will become part of US (or other countries') law.
These handy MSDS binder training inserts and other Right To Know compliance materials are available at Safety Emporium.
Disclaimer: The information contained herein is believed to be true and accurate, however ILPI makes no guarantees concerning the veracity of any statement. Use of any information on this page is at the reader's own risk. ILPI strongly encourages the reader to consult the appropriate local, state and federal agencies concerning the matters discussed herein.