Hazard communication updates as they relate to the upcoming GHS changes:

In 1992 an international mandate prompted the United Nations Conference on Environment and Development (UNCED) to adopt an agenda for the development of a worldwide, harmonized system for the classification and labeling of chemicals. This agenda called for ‘A globally harmonized hazard classification and compatible labeling system, including national safety data sheets and easily understandable symbols…”

The work was coordinated and managed by the Interorganization Programme for the Sound Management of Chemicals (IOMC) Coordinating Group for the Harmonization of Chemical Classification Systems (CG/HCCS). After nearly a decade of work, the IOMC transmitted the work to the named UN Committee of Experts on the Transport of Dangerous Goods and the program was officially named The Globally Harmonized System of Classification and Labelling of Chemicals (GHS). There were many individuals involved from a multitude of countries, national and international organizations, and stakeholder organizations. Their work spanned a wide range of expertise, from toxicology to fire protection, and ultimately required extensive goodwill and the willingness to compromise in order to achieve this system.

The purpose of the GHS is to provide a common, consistent criteria for classifying chemicals and developing compatible labeling and safety data sheets. The GHS is intended to enhance public health and environmental protection, as well as reduce barriers to trade. Countries lacking systems for hazard classification and labeling are to adopt the GHS as the fundamental basis for national policies for the sound management of chemicals; countries that already have systems will align them with GHS. A goal of the GHS is to encourage the use of compatible hazard labels, material safety data sheets for workers, and other hazard communication information based on the resulting classifications. This harmonized system for all regulatory purposes will lead to greater regulatory consistency among countries and thereby promote safer transportation, handling, and use of chemicals. Harmonized criteria, symbols, and warnings will promote improved understanding of hazards and thus help to protect workers, consumers, and other potentially exposed populations. A more uniform, "harmonized" system will enhance safety, improve the level of compliance, and reduce costs for companies involved in developing, manufacturing, distributing, and transporting chemicals both internationally and domestically since it is envisioned that international and domestic regulations will be harmonized on the basis of the GHS in the future. Other GHS goals are to reduce animal testing now needed for compliance with divergent national systems and to conserve scientific resources.

GHS hazard classification criteria were adopted by consensus for physical hazards and key health and environmental classes, such as acute toxicity, carcinogenicity, and developmental toxicity. For each of these hazard classes, standardized label elements, including symbols, signal words, and hazard statements, was developed and agreed on, along with a standard format and approach to how GHS information appears on safety data sheets. The GHS document includes guidance on other issues relevant to implementation of the system, including product identifiers, confidential business information, and precedence of hazards.

The hoped for worldwide implementation date for the GHS is January 1, 2008. The GHS is a voluntary system and does not impose binding treaty obligations on countries; however, when countries adopt the GHS into national regulatory requirements, it will be binding on the regulated community. Within the United States, key federal agencies with responsibility for regulatory and international affairs have formed an interagency committee coordinated by the Department of State. Besides the DOT's Pipeline and Hazardous Materials Safety Administration (PHMSA), other agencies that participate in the effort include the Consumer Product Safety Commission (CPSC), Department of Commerce, FDA, EPA, OSHA, Office of the US Trade Representative, USDA, and National Institute of Environmental Health Sciences (NIEHS). The interagency committee and individual agencies have also solicited the participation of key private sector groups, companies and trade associations, worker representatives, health and safety professionals, and environmental and public interest groups.

Currently, a worldwide equivalent to the US Hazard Communication Standard (CFR 49 1910.120) is being proposed in the US for possible adoption. The advanced notice of public rulemaking is expected by the end of 2006.

A 2005 draft of the GHS has been published and includes:

Introduction, with chapters on:

Physical Hazards

Health Hazards

Environmental Hazards

Annexes:

These sections give information on elements of the GHS, including

Allocation of Label Elements
Classification and Labeling Summary Tables
Precautionary Statements
Consumer Product Labeling Based on Likelihood of Injury
Comprehensibility testing methodology
Examples of Arrangements of the GHS Label Elements
Examples of Classification in the GHS
Guidance on Hazards to the Aquatic Environment
Guidance on Transformation/Dissolution of Metals and Metal Compounds in Aqueous Media

The HSE Group is closely following the implementation of the GHS within the US and worldwide. We will be prepared to provide our clients with training and policy information that will be compliant with the GHS.

If you want more information on how GHS might affect your company, please contact us.