Harmonization Across the Globe: Is it Possible?

Here's a look at how the GHS is shaping international safety.

HARMONIZATION. It's not a word we often hear in discussions of global policy or international relations these days. But when faced with the safety of millions of people worldwide, the idea of having a system in place that defines a single, effective way of communicating hazard classification on a global level is invaluable.

The Globally Harmonized System (GHS) was an idea brought forth out of the Earth Day Summit in 1992. It is supported by the United Nations and many worldwide organizations. A standardized approach to hazard communication, the GHS enhances public health and environmental protection, in addition to reducing trade barriers. It ensures the safe transport, handling, disposal, and use of hazardous materials without lowering the level of health and environmental protection that already exists.

A select group of individuals from around the world has been working diligently to set this system in motion for more than 14 years. This group is lobbying nations and working with the United Nations and other organizations to make GHS a reality--changing the world, as we know it today. The three main reasons for this system are to:

  1. Standardize hazard definitions
  2. Standardize hazard warnings and symbols on labels
  3. Standardize MSDS format and information

While the GHS is voluntary, we don't believe countries and agencies will abandon their own regulations and adopt only the GHS; rather, they will keep their own practices and implement the parts of the GHS that enhance their own systems.

Standardizing American Safety
The agencies most affected in the United States include the Department of Transportation (DOT), the Environmental Protection Agency (EPA), the Consumer Product Safety Commission (CPSC), and the Occupational Safety & Health Administration (OSHA). According to the United Nations Economic Commission for Europe (www.UNECE.org), DOT is currently working to implement the GHS into its program and could be finished as early as 2007. EPA has outlined initial thinking on the application of the GHS to pesticide labels in a white paper and solicited public comment on its plans through a notice published in the Federal Register (with the comment period ending in December 2004). The CPSC has taken initial steps in looking at the GHS requirements and how they compare to its own.

Most affected by the GHS is OSHA, which covers all acute and chronic hazards and has requirements for labels and Material Safety Data Sheets (MSDSs). This agency covers more than 7 million workplaces and 945,000 hazardous chemical products across the nation. From our conversations with experts in the field, OSHA isn't taking the GHS implementation lightly. It has recently completed a situational analysis comparing its HazCom requirements to the GHS (this is available at www.osha.gov) and continues to participate in interagency discussions about how the system will be implemented.

OSHA worked with Health Canada and the European Commission on global implementation and released on Sept. 12 an advance notice of proposed rulemaking, a document in the Federal Register that describes what the agency is working on and gives the public an opportunity to provide input in the form of written comments. We have learned there are significant differences between HazCom standards now and what the GHS is requiring.

The Impact on OSH Professionals
In looking at what this means to occupational health and safety professionals, we spoke with Michele Sullivan, Ph.D, principal of MRS Consulting, a longtime GHS supporter and expert. Sullivan has been working on the GHS since its inception. She has spent the last 14 years of her career working with the United Nations and other agencies on the implementation of the GHS.

She explained that OSHA's Hazard Communication standard is currently a performance-oriented standard. The GHS is strictly a specification standard. The United States will be affected in many ways by this new way of standardization, one being that we currently don't use pictograms in our labeling and will have to implement that for the GHS. Sullivan further explained that the HazCom standard allows producers of labels to determine the language. With the GHS, certain core information will need to be specific by category and class. For instance, pictograms will have to be used and need to be specified. The GHS is not reinventing the wheel on pictograms, though; those that have been chosen for the standard are currently being used by other countries, with only two new graphics.

Signal words will also be required, and hazard statements will be harmonized. Chemical producers will no longer have to determine their own language to convey hazards because translation of phrases will be done, in effect making it easier for producers to determine the appropriate label for other countries--thus making one specific, harmonized standard for all.

Although training and training methods are not spelled out in the GHS, there will be a strong endorsement for training as part of the system. We know training is an integral part of safety for workers and support for it in the GHS is imperative.

Docs Across Docks
When it comes to MSDSs, OSHA currently allows any format to be used. The GHS states that only a 16-part MSDS format can be used, basing the requirement off the American National Standards Institute format but switching the order of sections 2 (Composition/Information on Ingredients) and 3 (Hazards Identification).

The benefits of a 16-part MSDS are easily seen. It addresses comprehensibility issues with information order and is consistent with most industry-standard approaches. We find most businesses that are trading on a global level are using 16-part MSDSs. Although not all 16-parts fall under OSHA's guidelines (a few address environmental standards and transportation issues), Sullivan concurs with our belief that OSHA will recommend the use of 16-part MSDSs with the implementation of the GHS into its HazCom standards.

Even when the GHS is implemented in the United States, MSDS management practices will not be affected. Safety professionals across the nation will continue to use electronic or paper-based management systems for compliance. The fundamentals of the OSHA and HazCom regulations will not change, with companies still updating their MSDSs the way they always have. According to Sullivan, a major benefit would be improved safety for workers through consistent and simplified communications on chemical hazards and practices to follow for safe handling and use.

The Clock is Ticking?
Talk of the GHS implementation is buzzing worldwide, and a goal for full integration has been set for 2008. However, the date is nearing, and most countries are still just laying the groundwork.

What we know is that DOT in the United States will more than likely be fully integrated by 2008, but many other agencies and countries will be cutting it close or extending past 2008. Regardless, the wheels of progress will continue as countries and agencies alike understand the importance and long-term effects of such a comprehensive system.

Who Else is On Board?
According to UNECE, there are close to 100 countries working toward implementation, some of them still in the beginning stages of examining the workload involved in the GHS system. We've learned that others, such as Japan, are already creating and changing laws in order to comply with the system's standards. Europe is in the process of deciding how to phase in the GHS, probably starting with substances and then moving on to mixtures. Countries in the European Union are among those working toward 2008, as are Canada, Australia, and many others.

Harmonization = A Safer World
In a time of global trade and exchange of not only chemicals, but also numerous resources, the GHS is putting safety first for all people. By providing a common hazard communication model, we are all benefiting from a standardized and an overall higher-quality way of managing the safety of workers and the general public.

All countries that adopt the system are promoting a safer, more efficient way of managing chemicals worldwide. The task at hand is not an easy one. Implementing the requirements of the GHS is a huge undertaking for all countries and agencies involved, but the basic principles and end results will continue the overall improvement of way we all deal with hazard communication on a global level.

This article appeared in the October 2006 issue of Occupational Health & Safety.

GHS Guiding Principles

  • Level of protection offered to workers, consumers, and the environment should not be reduced.
  • The hazard classification process refers principally to the hazards arising from chemicals, whether natural or synthetic.
  • Harmonization means establishing a common and coherent basis for chemical hazard classification and communication, from which the appropriate elements relevant to means of transport, consumer, worker, and environment protection can be selected.
  • The scope of harmonization includes both hazard classification criteria and hazard communication tools.
  • Changes in all of these systems will be required to achieve a single globally harmonized system; transitional measures should be included in the process.
  • Involve concerned international organizations of employers, workers, consumers, and other relevant organizations in the process of harmonization.
  • Enable comprehension of chemical hazard information by the target audience.
  • Validated data already generated for the classification of chemicals under the existing systems should be accepted when reclassifying these chemicals.
  • A new harmonized classification system may require adaptation of existing methods for testing of chemicals.
  • In relation to chemical hazard communication, the safety and health of workers, consumers, and the public in general, as well as the protection of the environment, should be ensured while protecting confidential business information, as prescribed by the competent authorities.

Source: www.unece.org/trans/danger/publi/ghs/ghs_rev01/English/01e_part1.pdf

How MSDSs Will Change

OSHA asked for comments by Nov. 13 on 20 issues raised by its planned adoption of parts of the Globally Harmonized System of Classification and Labeling of Chemicals. The agency's Sept. 12 notice said 7 million workplaces, more than 100 million workers, and some 945,000 hazardous chemical products are covered by the Hazard Communication Standard it enacted in 1983 and will have to amend to adopt the 2005 version, Revision 1, of the GHS.

The notice discusses parts of GHS the agency won't adopt--environmental and transport elements--because other U.S. agencies oversee those areas. OSHA says chemical manufacturers will face the primary impact of the change because they will have to review classifications of their products. However, chemical products sold for transport and complying with DOT's regulations already are classified in a way that conforms, so the burden for those substances should be minimized, OSHA said.

International trade in chemicals should benefit, animal testing to establish toxicity should be reduced, and workers and the public should be better protected against chemical hazards once the GHS adoption is completed by OSHA and the 26 state plans in existence, the agency said. OSHA said it expects to retain the employee training element of its HazCom Standard, which is not matched in the GHS scheme, and may increase the training it requires to ensure understanding of the new approach to labels and MSDSs (called safety data sheets in GHS). Also, employees who are illiterate or speak and read English poorly may benefit from the GHS labeling approach, which uses a harmonized hazard statement, a signal word, and a pictogram.

The format for MSDSs that OSHA said it probably will adopt will list hazard information second, immediately after the substance's identity, rather than listing physical and chemical characteristics second as is common now. GHS data sheets will include information in this order:

Hazard identification
Composition/information on ingredients
First aid measures
Firefighting measures
Accidental release measures
Handling and storage
Exposure controls/personal protection
Physical and chemical properties
Stability and reactivity
Toxicological information
Ecological information
Disposal considerations
Transport information
Regulatory information
Other information

Occupational exposure controls would be addressed in the exposure controls section, OSHA said, adding that it expects to require that Permissible Exposure Limits be included there.

Among the questions on which OSHA asked for comments were these:

  1. How many hazardous chemicals as defined by the HazCom Standard do you produce, import, or distribute; how many do you export; and how many different labels or data sheets do you need to prepare for each chemical you export?
  2. How long does it take on average for each hazardous chemical to complete the review and prepare new labels and safety data sheets? How much does it cost for each chemical product?
  3. Would the time required to prepare a GHS safety data sheet be more, less, or about the same as currently required for preparing a safety data sheet?
  4. Describe the electronic tools, if any, you have to assist in this process. How long would it take to update those systems to make them GHS-consistent?
  5. What is the normal cycle for updating labels and safety data sheets?

--by Jerry Laws, OH&S Editor

This article originally appeared in the October 2006 issue of Occupational Health & Safety.

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