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What are some of the changes OSHA is proposing for the classification and labeling of chemicals?
Responding is Francis Trudeau, senior product manager, product stewardship solutions, and Mary Rudolph, senior manager, global content, IHS, Englewood, CO.
OSHA is in the final stage of its rulemaking process that would lead to adopting the Globally Harmonized System of Classification and Labeling of Chemicals as the national Hazard Communication Standard.
GHS – which represents the first major change to the hazcom standard in nearly 30 years – is designed to help workers identify the intrinsic hazards associated with chemicals and to convey detailed information about hazardous ingredients, first aid measures, and proper storage and handling techniques for chemical substances and mixtures.
OSHA’s adoption of GHS applies only to the classification and labeling of chemicals in the workplace. It is expected to include a three-year transition period for both substances and mixtures, which would coincide with the European Union’s implementation of GHS for mixtures in 2015.
We advise companies to treat GHS as a strategic operational concern, not just a regulatory matter, because of the potential impact on manufacturing processes. When fully implemented, GHS will require chemical manufacturers to classify chemical substances and mixtures based on the potential hazard that is associated with the product. For instance, some products or mixtures that are reclassified as hazardous could be difficult to obtain and may need to be replaced with a reformulated product or another substance.
In addition, businesses that must comply with GHS for the first time – primarily companies that operate solely within North America – will need to change their existing hazard communication processes. Chemical containers must display specified signal words, pictograms and hazard statements. Material Safety Data Sheet format and content must be completely revised to comply with the new legislation.
Previously, many businesses managed their hazard communication programs by using spreadsheets or delegating documentation to administrative staff. GHS, however, requires more complex and detailed management that far exceeds the capability of those legacy processes.
Here are other issues to consider when incorporating GHS into your company’s processes:
- Make sure you understand GHS and identify potential performance gaps – Become familiar with how GHS affects your operations.
- Develop a work-back schedule – Determine steps required to transition to GHS-mandated processes.
- Assess gaps versus MSDS authoring systems and processes – GHS will require revising MSDS format and content, which will affect authoring processes.
- Train your workforce – Employees need to understand how to implement GHS-compliant processes in their daily tasks. It is complicated, so begin early.
- Inform your customers – Your customers may need GHS training, too.
- Collect missing product data – Although neither GHS nor the hazcom standard requires testing to classify a product, it is difficult to classify a product without data on the product or the product’s components.
Now that OSHA is on the brink of adopting GHS, we encourage companies to prepare to implement the new chemical management processes that will eventually help you strengthen your company’s brand image, and reduce workplace safety risks and incident-related operational costs.
Editor’s Note: This article represents the independent views of the author and should not be construed as National Safety Council endorsements.