A Picture is Worth a Thousand Words
Material Safety Data Sheets are not the only element that will change with the pending GHS regulations.
The Globally Harmonized System, or GHS, was proposed by the United Nations in an effort to internationally standardize classification and labeling of chemicals through the use of pictograms, signal words, and hazard warnings. Benefits of the GHS include reduced time and costs involved in meeting multiple regulations for labels, improved comprehension and understanding of health and environmental hazards, facilitation of trade by removing barriers created by various health and safety requirements, and reduction of duplicate testing.
The adoption of the GHS is the hot topic of discussion, both domestically and internationally. While GHS has historically focused on the international community, with early adoption by the European Union and Japan, the GHS trend is moving west and is certain to affect U.S. companies in the future, if not already for those companies doing business internationally.
Most importantly, OSHA is considering modifying its Hazard Communication standard to make it consistent with the GHS. Th is would involve changing the criteria for classifying health and physical hazards, adopting standardized labeling requirements, and requiring a standardized order of information for safety data sheets. In OSHA's spring agenda meeting, of ficials stated that OSHA may be publishing the Notice of Proposed Rulemaking (NPRM) sometime soon, perhaps as early as October of this year. In this NPRM, we can expect to see OSHA's timeline for GHS transition, as well as the specific requirements for chemical labels.
How Chemical Labels Will Change
Today's OSHA Hazard Communication standard (HCS) imposes a performance-based requirement on chemical labels, so employers may choose how to convey the hazard information on the label. Essentially, current HCS requires what information should be displayed but allows liberties to the manufacturer, importer, or distributor on how it is displayed. As long as the label enables good performance to mitigate potential workplace incidents, the current standard is met.
However, moving forward, the regulations will adopt a standards-based approach to chemical labeling, such that certain label elements, including the hazard symbols (known as pictograms), signal words, and hazard statements will all be standardized and assigned to each of the hazard categories.
Practically speaking, what this means is that while employers previously had some latitude as to how hazard information was presented on labels as long as it met certain OSHA criteria, future standards will regulate the methods of presenting certain chemical label elements under the GHS. Ultimately, this is a good approach that one hopes will simplify and create consistency in the manner in which chemical data are presented. Additionally, this approach will highlight the potential dangers via pictures (pictograms) to create greater awareness and understanding.
Th e result is that the GHS label standardization will require a reprocessing of every label during transition. Standardized pictograms, signal words, hazard statements, and precautionary statements are specifi cally designed to enhance communication for all those handling chemicals. Th ese elements also will need to be placed on the label in specified locations.
As documented on the OSHA Web site, GHS defines the standardized elements as follows:
A signal word means a word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. Th e signal words used in the GHS are "Danger" and "Warning." "Danger" is used for the more severe hazard categories (i.e., in the main for hazard categories 1 and 2), while "Warning" is used for the less severe. Th e tables for each hazard class detail the signal words that have been assigned to each of the hazard categories of the GHS.
Hazard statements and precautionary statements
A hazard statement means a phrase assigned to a hazard class and category that describes the nature of the hazards of a hazardous product, including, where appropriate, the degree of hazard. Th e tables of label elements for each hazard class detail the hazard statements that have been assigned to each of the hazard categories of the GHS. Precautionary statements were added as a required element in the latest 2007 version of the GHS. A precautionary statement means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous product or improper storage or handling of a hazardous product.
A pictogram means a graphical composition that includes a symbol plus other graphical elements, such as a border, background pattern, or color that is intended to convey specific information. Th ere are nine symbols used in the pictograms: flame, flame over circle, exploding bomb, corrosion, gas cylinder, skull and crossbones, exclamation point, environment, and new health hazard. All hazard pictograms used in the GHS should be in the shape of a square set at a point.
The labels may, and of ten times should, continue to contain supplemental or nonstandardized information. Obviously, judgment will come into play, and the new standard will offer guidance on how to present supplemental information. Most importantly, the supplemental information should be used only when it meets at least one of the following conditions:
(a) the supplementary information provides further detail and does not contradict or cast doubt on the validity of the standardized hazard information; or,
(b) the supplementary information provides information about hazards not yet incorporated into the GHS.
In any case, the supplementary information should not lower standards of protection. One additional item of note is that the current HCS allows for alternative communication methods for workplace labels or labels placed on secondary containers. The GHS guidance allows for this approach, as well. OSHA guidance recommends maintaining the GHS label on the supplied container in the workplace but recognizes the fact that other formats may be more appropriate in the workplace.
For example, signs, placards, operating procedures, or other written materials may be available directly in the work area. Ifthis is the case, however, the same information and standardized elements must be present in these alternative forms of communication.
In the figure shown on this page, a label complying with the pending GHS guidance illustrates the key changes to the label. Notice the following key elements:
- The clear signal word "Danger,"
- Pictograms highlight the flammable and toxicity warnings, and
- Standardized hazard statements indicate the nature of the hazards.
- Precautionary statements describe recommended measures to minimize hazards.
Steps to Take Now
As noted above, it is no longer a question of "if" GHS will affect U.S. companies in the future, but rather a question of "when." In fact, for companies doing business internationally today, a transition phase to GHS labeling requirements may already be in place to meet the needs of their customers. Consider these tips for an effective and effi cient transition to the GHS:
1. Stay informed. Learn all you can about the GHS and how it may affect your organization, as well as the timeframes for adoption. OSHA's Web site and the GHS Information Web site are both excellent sources of information.
2. Don't go it alone. Make sure your product and service providers have a transition plan in place and are able to support you as you make the necessary changes. The right MSDS service partner should have a chemical information management system that will aid in the administration of documents classified under existing and future regulations, as well as an integrated product/ workplace labeling module.
3. Train the workplace. Training will be a key component of your overall GHS approach, especially with the nuances of the pictograms on new chemical labels.
This article originally appeared in the October 2009 issue of Occupational Health & Safety.