All Eyes on the Prize

Despite some implementation issues, GHS is generally progressing toward a better global framework for classifying chemicals.

Some of the nation’s leading experts on all of the facets of Hazard Communication— the regulations, classification schemes, warning labels, material safety data sheets, and authoring systems used for chemicals and mixtures around the world—will be meeting in Arlington, Va., this month. Members of the Society for Chemical Hazard Communication gathered for its 2008 Fall Meeting, they’ll listen intently Sept. 23 as GHS implementation leaders from OSHA, EPA, and DOT discuss the status of those agencies’ rulemakings.Whether or not OSHA’s rule is published next month as promised, this community of professionals believes the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) is progressing as intended toward a better global framework.

“As hazard communication professionals, we’re trying to figure out how to support our business units globally,” said Mark S. Cohen, director of labeling for Irving, Texas-based NCH Corp. and 2008-09 president of the society (www.schc.org). “There have been fast starts in various countries, and then as they find difficulties with implementation—infrastructure issues, quite frankly—they’re backing off in certain ways. Some say, ‘Well, we’ll do it only for new products and not existing products.’ Some say, ‘We’ll do it only for labels and not for material safety data sheets.’ So there are various stages, and those that have been first out of the gate are finding implementation challenges and are modifying and adjusting accordingly.

“At this point, trying to author material safety data sheets here and make those material safety data sheets useable for those international regions is very difficult,” Cohen said. “It’s not just that the formats are different, but the end points that they’re choosing are different. What we’re finding is that each region is having to do their best to adjust to that regulation in that country, as adopted.That’s by design: The UN put this together,and the GHS is a building-block approach. Countries can adopt—and not just countries, but different regulatory agencies within those countries—can adopt different subsets as long as they stay with the framework that was built by the UN. So we’re finding that it may or may not be as harmonized.”

SCHC FALL MEETING DETAILS

Dates: Sept. 20-24, 2008
Location: Marriott Hotel Crystal Gateway, Arlington, Va.
Highlights: Professional development courses; awards; a keynote speech on the differences between the UN Guideline and the EU GHS regulation from a top official of Belgium’s Scientific Institute of Public Health; expert presentations about authoring systems, GHS symbol comprehensibility, REACH, and other topics; updates on GHS implementation from OSHA, EPA, and DOT.

New Industrial & Consumer Labels by 2012?
Michele R. Sullivan, Ph.D., an SCHC board member and Arlington, Va., consultant who will present professional development courses during the conference, said the evolution of GHS was expected. Early adopters are taking stock of what other countries are doing to reform their classification systems, and they are also using interpretations of the GHS building blocks that are being issued by a subcommittee in Geneva, Switzerland, she said.

“In general, they’re picking up the concepts appropriately,” Sullivan said.However, she said, several countries have published lists of classified chemicals that are not in agreement. A United Nations Institute for Training and Research (UNITAR) paper about this issue has been referred to a GHS subgroup on which EPA and OSHA are represented, Sullivan said.

(UNITAR has been working jointly with the International Labour Organization since 2002 on training and building nations’ capacity to implement GHS. Its Web pages shed light on the worldwide scope of GHS. Visit www.unitar.org for information about events, reports, and guidance documents.)

Both Cohen and Sullivan said they foresee GHS will foster more agreement about chemical classification and a better labeling framework, with new labels and data sheets for industrial products and new consumer labels being seen by 2012, possibly.

“I think, in the end, the beauty of GHS is its classification. The classification of hazards is going to be harmonized,” he added.“So if I classify here in the States, it should be similarly classified in various other regions.”

Impacts on End Users, Authors, Transport Sector
Asked about the practical effect on end users, label and MSDS authors, the chemical transportation sector, he said chemical manufacturers will see a significant impact.

“It’s going to have probably less of an impact on the transportation sector because those folks have been working together through UN committees for quite a while. And I would propose that the transportation sector is probably the most harmonized of any of the sectors,”Cohen said.

“I think we can anticipate that every product will have to be classified, its material safety data sheet revised, and every product label revised. That’s going to be, obviously, a very big impact on chemical manufacturers. In addition, that dictates that there will be a lot more work for hazard communicators. Hazard communicators will need additional training.

“We’re also going to have to train formulators. We’re going to have to train material handling people.We’re going to have to train production personnel. Because, if you think about it, all of these products are going to come in with labels with new symbols, new signal words and phrases, as well as new material safety data sheets.New formats,because of course the GHS format will be standardized. And it will be—I assume, depending on OSHA’s position, required—whereas historically, it’s been performance-oriented: If you had a certain amount of content and the information was accurate and up to date, you were considered compliant.”

Industrial end users may be moving from today’s hazard-based labeling to risk-based labeling. Depending on what Consumer Product Safety Commission does, consumers also may have to learn a new labeling system.With this in mind,Cohen said America’s students should start learning hazard warning symbols in junior high schools. “These labeling systems are going to have to be integrated into youth education in public and private curricula,” he said.

SCHC has an ongoing alliance with OSHA to further hazard communication. OSHA links to GHS information sheets that were created by SCHC, which has created and internally reviewed an MSDS writer’s course that Cohen expects will soon be submitted to OSHA after testing taking place with course developers at OSHA Training Institutes. SCHC also conducts training. Cohen said his company, NCH, uses SCHC as a primary training ground for its hazard communicators.

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