All Eyes on the Prize
Despite some implementation issues, GHS is generally progressing toward a better global framework for classifying chemicals.
- By Jerry Laws
- Sep 08, 2008
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