The Bounty of GHS
Enhanced safety and more efficiency are foreseen from the Globally Harmonized System's adoption in the United States, industrial hygienists say.
- By Jerry Laws
- Feb 01, 2007
INDUSTRIAL hygienists and the American Industrial Hygiene
Association reacted positively to OSHA's request for comments last
September on implementing the Globally Harmonized System of
Classification and Labeling of Chemicals. Although full implementation
of the system in the United States is expected to take at least three
years, it will be very beneficial to end users, manufacturers, and
safety and health professionals, hygienists say.
Greg Bronder, CIH, works in the Salt Lake City, Utah area as part of
the IH Services Department of Air Products & Chemicals, Inc., a
multinational provider of gases and materials that has its headquarters
in Allentown, Pa. Bronder has worked for the company for five years and
is a member of AIHA's Respiratory Protection Committee. He said he is
enthusiastic about GHS and its value for the industrial hygiene
community and others.
"I think some [chemical manufacturers] might oppose it based on the
cost associated with making the changes to their Hazard Communication
programs, their MSDSs, the way they do things. I think some companies
that only do business in the United States might oppose that. For most
global companies, I think it will be a real benefit," Bronder said.
"Half the plants I support are in Asia. And when I go there and have to
deal with the systems over there for their Material Safety Data Sheets
and their Hazard Communication programs, I find a lot of
inconsistencies and problems. I think this is going to be a great
program. I know it's going to help me a lot in my job."
GHS is a voluntary system for standardizing the classification and
labeling of chemicals and defining their health, physical, and
environmental hazards. It has been adopted by the United Nations with a
goal of broad international adoption by 2008--just one year from now.
"GHS is expected to bring more consistency and clarity, both from a
national and international perspective, to hazardous chemical
regulations in the workplace," OSHA chief Ed Foulke Jr. said in the
agency's comment request. "The diverse and sometimes conflicting
national and international requirements can create confusion among
employers who seek to use hazard information to effectively protect
their employees. One of the many benefits of adopting GHS is that it
would provide a consistent format for labels and safety data sheets,
making the information easier to comprehend and access when making
"The initial impact on manufacturers will be an increased workload
as SDSs and labels are revised to align with GHS adoption, and perhaps
the need for a more disciplined approach to hazard classification as we
move away from a performance-oriented standard," said Kathy Thompson,
CIH, product stewardship specialist for 3M's Industrial Adhesives and
Tapes Division in St. Paul, Minn. "As those processes are implemented,
the workload should eventually decrease with a standardized global
approach. End users will benefit from the consistency in documents that
will result from GHS adoption, though there will be education required
on the new format and approach to hazard classification in the
AIHA recommended a phase-in period of three to five years as a
reasonable timeline for manufacturers, said Thompson, who is a member
of the AIHA Stewardship and Sustainability Committee, which formulated
AIHA's comments on the OSHA proposal. (Members of the AIHA Management,
Communications, and Training Methods Committee; the Occupational
Epidemiology Committee; and the Respiratory Protection Committee also
responded, AIHA said Nov. 22, 2006.)
"GHS adoption will facilitate international trade as it becomes more
global, so companies will realize long-term economic benefit. It also
will enhance employee protection benefits, not only for the hazardous
materials a company produces but also for the raw materials they use,
so there should be a resultant benefit in safety improvement for U.S.
companies," Thompson added.
GHS is anticipated to be adopted as part of REACH, the proposed new
European Union chemical classification system, so the two work in
harmony, she added.
Yearning for Fresh Data
Safety Data Sheets are central to GHS, just as Material Safety Data
Sheets are central to OSHA's Hazard Communication Standard. The guiding
principles contained in GHS for SDSs are that information should be
conveyed in more than one way (text and symbols, for example);
comprehension level should take account of existing studies,
literature, and any evidence gained from testing; and phrases used to
indicate hazard severity should be consistent across the health,
physical, and environmental hazards. GHS uses standardized label
elements that include pictograms, signal words such as "Danger" and
"Warning," and hazard statements.
AIHA's stance on GHS mentions the need for training to enhance the
competency of MSDS authors, and the association suggests certification
might be advisable for those authors. Bronder and Thompson noted there
is a wide variety among those who handle the writing responsibility.
"MSDS authors can vary across companies, from many highly trained
individuals being involved to one person being responsible," Thompson
said. "Because there can be various levels of competency, a GHS
adoption should result in improvements because of the training that
will be needed for the more standardized approach to MSDS authoring."
Bronder said Air Products & Chemicals has a team writing its
MSDSs with a professional toxicologist involved. Asked how many authors
there may be in U.S. industry and how numerous they are, he said those
are big unknowns. "You bring up a good point: Who are all these people?
You could have someone for a smaller company, [just] out of college,
told, 'Hey, write these MSDSs. Here's the format you need to write them
in.' I don't think there is a lot of consistency now. In my experience,
they [MSDSs] certainly run the gamut in terms of quality."
AIHA supports including a mechanism to ensure MSDS data are
refreshed regularly, possibly following Canada's practice of requiring
suppliers to provide data sheets that are no more than three years old.
OSHA asked for information on the cycle for updating SDSs and labels in
its September advance notice, and the concept of appropriate and timely
updates is part of GHS. Both Bronder and Thompson said periodic review
of safety data sheets will increase employee protections overall.
It's not uncommon to run into MSDSs that are a decade old or more,
said Bronder. "A lot of times, people just don't look because they're
too busy in their other tasks and they just don't look to see if there
are new MSDSs. You know, most manufacturers don't really have a good
system of notifying people that they do have new MSDSs or there's new
data," he said.
They predicted GHS will have a profoundly positive impact on overall
safety--and not just for chemical manufacturers. An efficient,
standardized system that delivers more meaningful and uniform data
serves the real purpose of industrial hygiene, and that's good, Bronder
This article appeared in the February 2007 issue of Occupational Health & Safety.
OSHA's Guide to GHS
OSHA offers an extensive guidance document summarizing GHS requirements to help anyone unfamiliar with the system. Available at www.osha.gov/dsg/hazcom/ghs.html,
this guide explains in detail what GHS is, how labels and hazard
information would be displayed, and how harmonization can benefit
chemical shippers by solving nations' conflicting classifications. The
worldwide chemical business is valued at more than $1.7 trillion
annually, with the U.S. portion valued at $450 billion per year and
accounting for $80 billion in exports, according to the guide.
GHS "has maximum value if it is accepted in all major regulatory
systems for chemical hazard communication," the guide notes in a
section laying out these potential benefits if GHS is implemented
- Enhance the protection of human health and the environment by providing an internationally comprehensible system
- Provide a recognized framework to develop regulations for those countries without existing systems
- Facilitate international trade in chemicals whose hazards have been identified on an international basis
- Reduce the need for testing and evaluation against multiple classification systems.
Tangible benefits to governments are listed as:
- Fewer chemical accidents and incidents
- Lower health care costs
- Improved protection of workers and the public from chemical hazards
- Avoiding duplication of effort in creating national systems
- Reduction in the costs of enforcement
- Improved reputation on chemical issues, both domestically and internationally.
Potential benefits to companies would include:
- A safer work environment and improved relations with employees
- An increase in efficiency and reduced costs from compliance with hazard communication regulations
- Application of expert systems resulting in maximizing expert resources and minimizing labor and costs
- Facilitation of electronic transmission systems with international scope
- Expanded use of training programs on health and safety
- Reduced costs due to fewer accidents and illnesses
- Improved corporate image and credibility.
Potential benefits to workers and members of the public include:
- Improved safety for workers and others through consistent and
simplified communications on chemical hazards and practices to follow
for safe handling and use
- Greater awareness of hazards, resulting in safer use of chemicals in the workplace and in the home.
This article originally appeared in the February 2007 issue of Occupational Health & Safety.