OSHA to Adopt GHS

The revised classifications may have a significant effect on business operations.

• By Francis Trudeau, Mary Rudolph
• Jan 01, 2012

The Purple Wave for workplace hazard communication -- the popular metaphor representing growing worldwide interest in a global standard -- is about to come ashore to the United States, as OSHA approaches the final stage of its rulemaking process to adopt the Globally Harmonized System (GHS) of Classification and Labelling of Chemicals as the national Hazard Communication Standard (HCS).

The revised rule would be the first major change to the HCS in nearly 30 years. The new GHS rule 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.

GHS is designed to help workers identify the intrinsic hazards associated with chemicals and convey detailed information about hazardous ingredients, first aid measures, and proper storage and handling techniques for chemical substances and mixtures. The regulation also calls for a revised formatting and content of container labels and Material Safety Data Sheets (MSDSs).

OSHA's adoption of GHS only applies to the classification and labeling of chemicals in the workplace. The U.S. Department of Transportation has already adopted provisions for chemicals that are transported via commercial carriers. EPA and the Consumer Product Safety Commission also have jurisdiction over designated provisions of GHS.

Since its adoption in several key markets, including the European Union, Japan, Brazil, and South Korea, the regulation has helped businesses enhance workplace safety and reduce risk exposure around incidents by ensuring that employees and customers fully understand how to handle and store hazardous chemicals. We advise companies to treat GHS as a strategic operational concern, not just a regulatory matter, because of the potential impact to your 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.

For years, many businesses have managed their hazard communication programs with spreadsheets or manual processes, typically delegating tasks to administrative staff. However, GHS requires more complex and detailed management of classification of chemicals, which far exceeds the capability of manual processes, legacy systems, or spreadsheets to effectively manage hazard communications programs. This is one reason why industry leaders are increasingly implementing more robust information solutions that enable corporate managers and executives to address hazard communication throughout the organization as part of a comprehensive strategy for enterprise sustainability management. These powerful, integrated solutions reduce risks and costs by ensuring data quality and streamlining critical work processes across the organization. They also make it easier for companies to adapt to new standards such as GHS by providing a central point of leverage for change management.

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. For instance, chemical containers must display specified signal words, pictograms, and hazard statements that clearly indicate their contents. GHS also requires a detailed 16-section format for MSDSs.

Take These Steps When Incorporating GHS
Here are other issues to consider when incorporating GHS into your company’s processes:

1. Make sure you understand GHS and identify potential performance gaps. GHS represents a substantial change from OSHA’s existing HCS. Businesses will need to become familiar with how GHS affects their operations and identify gaps that could result in non-compliance.

2. Develop a work back schedule. Companies will need to determine necessary steps to transition from their existing hazard communication procedures to GHS-mandated processes. Starting from the final outcome, determine how long it may take to comply with GHS, or else you may find that you are out of compliance when the regulation takes effect.

3. Assess gaps versus MSDS authoring systems and processes. Most companies developed semi-automated processes and systems assisting them in the creation of compliant safety documents. The change to GHS will require a revision of the format, content, and therefore processes in place to produce documents.

4. Train your workforce. In many cases, GHS will require companies to implement extensive change management processes, including company-wide training. Employees need to understand how to implement GHS-compliant processes in their daily tasks. GHS regulations are complicated, so start early.

5. Collect missing product data. Although neither GHS nor the HCS requires testing to classify a product, it is difficult to classify without data on the product or the components of the product. Having a product properly classified increases the marketability of the product.

6. Inform your customers. Your customers may need GHS training to ensure they understand the regulation’s requirements for handling and storing regulated chemicals.

For years, OSHA's existing HCS has been part of a patchwork of country-based regulations that widely vary from one jurisdiction to another. This creates complexity for companies that need to maintain compliance across multiple jurisdictions. GHS provides a regulatory scheme that is expected to reduce compliance-related risks and complexities because it provides a uniform regulatory framework. Companies will also benefit from a scheme that provides employees and customers with clear, easy-to-read instructions for proper handling, transportation, and storage of chemicals.

GHS eventually will be a catalyst for organizations to incorporate hazard communication and chemical management processes in general, as part of a broader enterprise sustainability management strategy. This trend is gaining favor with investors, regulators, and consumers, all of whom are closely watching every company's overall environmental, health, and safety performance.

By catching the Purple Wave, you embrace the opportunity to enhance chemical management processes that will strengthen your corporate brand and reduce workplace safety risks and incident-related operational costs.