GHS RULE CHANGES OSHA HAZARD COMMUNICATION PROGRAM (HAZCOM)
On March 26, 2012, the Federal Register published the final rule on Globally Harmonized System of Classification and Labeling of Chemicals (known as GHS). The effective date of the rule was May 25, 2012.
A. Changes to the 1984 HazCom Standards include hazard classifications, labels, safety data sheet format. An implementation schedule for compliance, Training (users), Label & SDS changes (Manufactures) was provided.
- Hazard classification: The definitions of hazard have been changed to provide manufactures specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria are to ensure that evaluations of hazardous effects are consistent across manufacturers internationally, and that labels and safety data sheets are more accurate as a result.
- Labels:Chemical manufacturers and importers are required to provide a label that has the chemical name and includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided. (see labels section below)
- Safety Data Sheets (SDS – no longer called MSDS): The current Hazard Communication Standard (HCS) indicates what information has to be included on an SDS but does not specify a format for presentation or order of information. The revised HCS requires that the information on the SDS is presented using consistent headings in a specified sequence. The SDS format is the same as the ANSI standard format which is widely used in the U.S. and is already familiar to many employees. The specified 16-section format is to include the following sections:
| 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 & chemical properties Section 10. Stability & 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, e.g. preparation date, last revision |
B. LABELS are to include: chemical name as well as a harmonized signal word, pictogram, and hazard statement for each hazard class and category.
- MANUFACTURE LABELS:
Signal word: a single word on the label 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.
Pictograms: There are nine pictograms under the 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. The hazard pictograms and their corresponding hazards are shown below.
HCS Pictograms and Hazards
| Health Hazard | Flame | Exclamation Mark |
|---|---|---|
 |
 |
 |
|
|
|
| Gas Cylinder | Corrosion | Exploding Bomb |
 |
 |
 |
|
|
|
| Flame over Circle | Environment | Skull and Crossbones |
 |
 |
 |
|
|
|
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 (shown with the pictograms above).
2. WORKPLACE LABELS(aka Secondary Container Labels)
The standard provides employers with flexibility regarding the type of system to be used in their workplaces and OSHA has retained that flexibility in the revised Hazard Communication Standard (HCS).
Employers may choose to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule, or with label alternative system that meet the requirements for the standard.
NMSU uses the NFPA labeling [alternate] system and provides training on its use in the EH&S HazCom Class.
OSHA has indicated that the labeling systems using the National Fire Protection Association (NFPA) 704 Hazard Rating is permitted for workplace containers.
C. IMPLEMENTATION
Schedule for implementation
The table below summarizes the phase-in dates required under the revised Hazard Communication Standard (HCS):
| Effective Completion Date | Requirement(s) | Who |
| December 1, 2013 | Train employees on the new label elements and safety data sheet (SDS) format. | Employers |
| a. June 1, 2015* b. December 1, 2015 |
a. Compliance with all modified provisions of this final rule, except: b. The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label |
Chemical manufacturers, importers, distributors and employers |
| June 1, 2016 | Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. | Employers |
| Transition Period to the effective completion dates noted above | May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both | Chemical manufacturers, importers, distributors, and employers |
D. OSHA AND EPA GUIDES
- OHSA guide on Hazcom under GHS is https://www.osha.gov/dsg/hazcom/
- NFPA vs GHS is at https://www.osha.gov/Publications/OSHA3678.pdf
- Comparison of GHS versus Environmental Protection Agency (EPA) requirements is at http://www.epa.gov/oppfead1/international/globalharmon.htm
- EPA guide Material Safety Data Sheets as Pesticide Labeling is at www2.epa.gov/sites/production/files/2014-04/documents/pr2012-1.pdf