The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) is a voluntary system designed to replace the variety of differing classification and labeling standards used by different countries. So much of our lives are expanding to global proportions, it only makes sense to standardize how chemical hazards and safety information are communicated so that all can clearly and easily understand the risks associated with the chemicals used in the workplace and at home. The United States Occupational Safety and Health Administration (OSHA) is currently considering restructuring the way it addresses hazard communication to fit into the GHS.
What is GHS?
The GHS is an internationally agreed upon system that globalizes the criteria for classifying and labeling chemicals. It was developed in response to a mandate at the 1992 Rio Conference on Environment and Development stating that, "A globally harmonized hazard classification and compatible labeling system, including Material Safety Data Sheets (MSDS) and easily understandable symbols, should be available if feasible, by the year 2000." The goals of the GHS are to enhance protection of people and the environment by:
- providing an internationally comprehensible system for hazard communication;
- providing a recognized framework for countries without an existing system;
- facilitating international trade in chemicals whose hazards have been properly assessed and identified on an international basis;
- reducing the need for animal testing and evaluation of chemicals.
GHS is essentially an international system of hazard classification. It is a voluntary approach intended to provide a common and consistent method of classifying hazards and communicating hazard information on container labels and MSDS. All hazardous chemicals, including substances, products, mixtures and preparations, etc., will be covered by the GHS.
Manufacturing employees, consumers, transportation employees and emergency responders all benefit from the GHS program. Chemicals to which these people are exposed will be classified according to their physical, health and environmental hazards.
Don’t mistake the GHS for a standard or regulation. Participation is a voluntary option for countries, but in some cases, food companies in countries that do not adopt the GHS may be at a competitive disadvantage in the international marketplace. The "Purple Book" is a guidance document that establishes criteria and methods for hazard classification and communication. It gives the regulatory framework to establish or adjust existing regulations and programs.
The need to standardize chemical hazard information becomes clear when one company considers a chemical to be toxic and another does not. This and other inconsistencies impact safety on a variety of levels. Many countries have their own standards for chemical hazard classification, but several underdeveloped countries have few, if any, standards. The differences in these standards may be significant enough to require several different classifications, labels and MSDS for the same chemical when sold in different countries. The GHS was created to improve safety, but it is also expected to improve knowledge of health hazards and risks and to promote the elimination of hazardous chemicals and replace them with less hazardous products.
To help review the major changes expected by the GHS, we should consider how it will affect the common methods of communicating hazards for chemicals that we use today. The two main sources for hazard information are the container label and the MSDS.
Communicating Chemical Hazards
When the GHS criteria are used to classify substances or mixtures, the hazards will then need to be communicated. The common methods of communication will be incorporated in GHS and include labels and MSDS. One of the main objectives of the GHS is to standardize communication of chemical hazards so that individuals and companies can better understand the hazards of the chemicals they use.
The following guiding principles have been implemented:
- Non-disclosure of confidential business information should not compromise the health and safety of users.
- Hazard communication should be available in more than one form (commonly used examples are placards, labels or MSDS).
- Hazard communication should include hazard statements and precautionary statements.
- Hazard communication information should be easy to understand and standardized.
- Hazard communication phrases should be consistent with each other to reduce confusion.
- Hazard communication should take into account all existing research and any new evidence.
Safety Data Sheets
Safety Data Sheets (SDS) are specifically targeted for use in the workplace. They should provide employers and workers with clear, accurate, concise and relevant information that can provide practical help regarding the hazards, proper uses and risks of the chemical product in the workplace. The globalized SDS, according to the GHS, contains 16 sections:
- Identification
- Hazard(s) identification
- Composition/information on ingredients
- First aid measures
- Firefighting measures
- Accidental release measures
- Handling and storage
- Exposure control/personal protection
- Physical and chemical properties
- Stability and reactivity
- Toxicological information
- Ecological information
- Disposal considerations
- Transport information
- Regulatory information
- Other information
The SDS should provide a clear description of the data used to identify the hazards. A table in the OSHA GHS guidance document (Appendix A) compares the content and format of a Material Safety Data Sheet with the GHS SDS example. It is available at: http://www.osha.gov/dsg/hazcom/ghs.html#3.0.
GHS Label Elements
Under the GHS, standardized label elements include:
- Symbols: Hazard pictograms to convey health, physical and environmental hazard information. Examples of the pictograms and downloadable files are available online at: http://www.unece.org/trans/danger/publi/ghs/pictograms.html.
- Signal Words: "Danger" or "Warning" used to emphasize hazards and indicate the relative level of severity of the hazard.
- Hazard Statements: Standard phrases assigned to a hazard class and category that describe the nature of the hazard.
Additional label elements are:
- Precautionary Statements,
- Product Identifier (ingredient disclosure or chemical identity),
- Supplier identification (Name, address and telephone number).
- Supplemental information.
Aligning OSHA communication
The Occupational Safety and Health Administration (OSHA) is proposing to modify its current Hazard Communication Standard (HCS) to align with the GHS provisions to increase the quality and consistency of information provided to workers, employers and chemical users by adopting a standardized approach to hazard classification, labels and safety data.The HCS requires chemical manufacturers to provide hazard information about the chemicals they produce or import and post them on container labels and safety data sheets.
Then, employers communicate those hazards to their exposed workers in a Hazard Communication Program that includes container labels, safety data sheets and employee training.
Adapting OSHA’s hazard communication to the GHS will improve the quality and consistency of the current classification and labeling of all chemicals. The harmonized format of the safety data sheets will enable workers to access the information more efficiently.
In the current program, multiple labels and safety data sheets are often developed for the same product when shipped to different countries. This creates a major compliance burden for chemical manufacturers and those involved in international trade, increasing the cost of providing hazard information. The adoption of GHS will minimize this burden.
Major Changes
There are four key changes to the current Hazard Communication Standard, particularly impacting the way hazards are classified, what is required on labels, how safety data sheets are to be formatted, and what training and information is provided to workers.
Health and physical hazards, as well as mixtures, will be classified to meet specific criteria requirements as part of the GHS. Regarding 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; and safety data sheets will have to meet the specified 16-section format, as previously detailed.
Finally, although the GHS does not address training, the proposed communication standard will require that workers are trained within two years of the publication of the final rule to facilitate recognition and understanding of the new labels and safety data sheets.
Impact of Changes
The proposed changes to OSHA’s HCS will impact numerous industries outside the food industry. It is estimated that more than five million workplaces and 40 million workers in the United States will be affected by the change.
There will be some costs incurred due to reclassifying all chemicals and training workers on the modified HCS standard. These costs will generally be one-time transition costs over the phase-in period of three years. Aside from the transition costs, the ongoing annual compliance costs are expected to be the same or lower than the existing standard.
Annual Costs of the Standard
According to OSHA’s estimates, it will cost approximately $97 million per year to comply with the proposed HCS standard. These are broken down into three main categories:
- Hazard Classification: 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 is estimated to be $11 million annually for an estimated 90,000 establishments.
- Worker Training: Training workers to become familiar with new warning symbols and the revised safety data sheet format under GHS is estimated to cost $44 million annually for all affected workplaces.
- Management Training: Although not a requirement in the proposed rule, OSHA estimates that $42 million a year will be spent to familiarize management with the new GHS system and to engage in other management-related activities, as may be necessary for adoption of the GHS.
Benefits of Change
Based on estimates, the revised standard is expected to prevent nearly 43 fatalities and 585 injuries and illnesses each year. The financial benefits associated with these accident reductions are an estimated $266 million per year. Further cost reductions and productivity improvements related to the proposed revisions are expected to produce an additional benefit of $585 million each year. In total, the proposed revisions are estimated to provide a net annual savings of $754 million.
Conclusion
If the proposed changes to OSHA’s Hazard Communication Standard are approved they will surely impact the food industry across the entire nation. It will take time for the changes to take effect, but once they do, the global system for standardizing chemical hazards and safety information will make it easier for all to clearly and easily understand the risks associated with chemicals used in the workplace and at home. AIB
The author is Head, OSHA Compliance & Educational Product Development, AIB International.