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.

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."

OSHA agrees. 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 hazard assessments."

"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 beginning."

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 said.

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 globally:

  • 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.

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