GHS pictogram used for carcinogens, respiratory sensitizers, and germ cell mutagens.

OSHA Finally Brings GHS to America

Calling it the first major health rulemaking of the Obama administration, OSHA yesterday announced it is proposing a rule to align the agency's Hazard Communication standard with provisions of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS). OSHA also said the proposal, published in today's Federal Register, is the first of many steps in the months to come that will demonstrate the agency's renewed commitment to an aggressive regulatory agenda.

OSHA's current HazCom standard requires chemical manufacturers and importers to evaluate the hazards of the chemicals they produce or import and provide information to subsequent users. The standard requires all employers to have a hazard communication program for workers exposed to hazardous chemicals, and for the program to include materials such as container labels, safety data sheets, and employee training.

A number of countries, including the United States, international organizations, and stakeholders participated in developing the GHS to address inconsistencies in hazard classification and communications. The GHS was developed to provide a single, harmonized system to classify chemicals, labels, and safety data sheets with the primary benefit of increasing the quality and consistency of information provided to workers, employers, and chemical users. Under the GHS, labels would include signal words, pictograms, and hazard and precautionary statements. Additionally, information on safety data sheets would be presented in a designated order--specifically in a standardized 16-section format. The idea is that such standardization will enhance worker comprehension, ensure appropriate handling and use of chemicals, and reduce chemically related fatalities, injuries, and illnesses.

"Having a standardized safety data sheet will also make it easier to locate important safety and health information, not only for workers but for emergency response personnel," said acting OSHA chief Jordan Barab, during a teleconference about the proposed rulemaking yesterday. "In addition to improving worker protection, uniform safety data sheets and harmonized labels will also make it easier for employers to train workers on how to safely handle the wide range of chemicals shipped from various chemical manufacturers and importers."

Barab, who formerly worked on workplace safety issues for the U.S. Chemical Safety and Hazard Investigation Board, noted that the European Union has already adopted GHS, as has Japan and China. Other countries, such as Canada, are, like the United States, working on the regulation. Following today's Federal Register publication of the proposal is a 90-day comment period that ends Dec. 29. OSHA plans to then hold public hearings on the rulemaking early in 2010. "We are seriously discussing having hearings in different parts of the country, but we'll figure that as we go along," Barab said. "Fairly soon we ought to have an announcement out, and it will be in the Federal Register, as well."

Part of what OSHA would like to receive comments on is the agency's proposed three-year phase-in period for the regulation. That phase-in period would begin with the publication of the Final Rule, with required training on the standard commencing within two years of the Final Rule. Asked to estimate when that Final Rule might happen, Barab said, "We'll be working on it as quickly as we can, but we've got a lot of different processes we go through. We feel like it's a pretty good proposal right now, so we're hoping to move it along with all due speed."

Barab said he does not foresee the forthcoming regulation as being a financial burden on manufacturers and small businesses that will have to train their workers on the new rules and alter the labels on their containers of chemicals. "The only thing that businesses will have to do is the same thing they're doing now, which is receive the material safety data sheets, make sure they're accessible to workers, do the training on material safety data sheets, and make sure that there are labels, which normally will come with the chemicals they have anyway," he said. "To some extent, [GHS] is actually making it easier for them. You're not going to have all these crazy material safety data sheets--a three-page one for one chemical and then a 30-page one for another chemical--and then be expected to do coherent training on that. This should make them all, more or less, look the same--all the sections will be consistent. It should make life actually a lot easier for employers. . . . And, of course, we will be issuing compliance assistance materials to help employers on this, and I'm sure there will be plenty of companies out there that will be selling those, as well."

In addition to the GHS classification system for specific hazards such as toxic chemicals, flammable materials, and carcinogens, OSHA's proposed rulemaking makes use of an "unclassified hazards" category, which Barab said could cover various issues not yet regulated, such as combustible dust. "GHS isn't quite as advanced as we are on some issues, including combustible dust, which we seem to have had a lot more experience with," he noted. "And you're probably aware the Chemical Safety Board also recommended that we recommend that GHS address combustible dust, which they haven't done yet. So, we're addressing it through this and using the unclassified hazards area to do that. It will require manufacturers to provide information on other known hazards, which would include combustible dust and, again, we have brought it up with the UN committee that's working on this issue."

Barab said the proposed changes necessary for aligning OSHA's HazCom standard with GHS will necessarily have an effect on other, related standards. "Right now, there are some inconsistencies between how different standards handle different definitions," he said. "If you read the proposed changes it will have in other standards […] everything will be harmonized--every time we say the word 'hazard' or 'flammable' or 'combustible' or whatever, it will mean the same thing within every standard."

He added that OSHA's proposal to adopt GHS would not change the framework and scope of the agency's current HazCom standard, "but it will improve the quality and consistency of how chemical hazards are classified, and how chemicals are labeled."

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