GHS Timeline in USA

The Globally Harmonized System (GHS) of Classification and Labeling of Chemicals is a worldwide initiative to promote standard criteria for classifying chemicals according to their health, physical and environmental hazards.

GHS is a universal pictograph language. So that a worker in Asia, or in the Americas —or in Africa or Europe or Antarctica — can all read and render the same hazard insignias at a glance. GHS makes sense.

A lot changes with the new system. Most readers of this blog are familiar with the new system’s use of pictograms, hazard statements, and signal words “Danger” and “Warning” to communicate hazard information on product labels and safety data sheets.

So what are the GHS deadlines for US companies?  At the right you’ll see a graphical timeline showing dates for US implementation of GHS.

For help with GHS compliance, contact your favorite consultancy or check with a neutral, platform-agnostic software provider. On the software note, the GHS challenge is formidable enough to have spawned newbie GHS solutions. Do basic Google searches and research. Talk to a few software vendors. Actio Corporation is a good example of a veteran, proven software company that can help with GHS conversion. Whether you decide to use software or not is up to you. Just know that a software company might really help with your GHS challenge.

GHS: A Refresher

As the first major US deadline for the Globally Harmonized System of Classification and Labelling approaches, people are starting to ask the basic questions all over again. And fair enough. Top question?

“Remind me, what’s the difference between OSHA’s previous HazCom standard and the new one (for GHS)?

The new HazCom Standard is written as a modification to the existing standard. The parts of the standard that do not relate to the GHS, or that are already consistent with it, are unchanged. Accordingly, some terms have also been updated. We are no longer going to “assess” so much as we are going to “classify” (see image below). And “material safety data sheet” has been changed to the simpler, “safety data sheet.”

Changes in purpose of the HCS, this is also interesting:

For more, see a comparison of the entire document online, line by line. But this primer should remind you. And key deadlines for the new GHS?  Coming soon in a separate blog post. For 2013 what we need to pay attention to is this one:

And what does “training” mean, exactly?

The GHS states in Chapter 1.4, Section1.4.9, the importance of training all target audiences to recognize and interpret label and/or SDS information — and to take appropriate action in response to chemical hazards. Training requirements should be “appropriate for and commensurate with the nature of the work or exposure.”

Key target audiences include workers, emergency responders and also those responsible for developing labels and SDSs. To varying degrees, the training needs of additional target audiences have to be addressed. These should include training for persons involved in transport and strategies required for educating consumers in interpreting label information on products that they use.

Here is a helpful brochure summarizing what your employees need to know/be competent in by November 30, 2013: http://www.osha.gov/Publications/OSHA3642.pdf

If you’re curious about technology that can help you comply, consider the award-winning SDS Vault program. (Award information is rolled into a dynamic case study with the manufacturer of Behr paints.)

GHS: Gobs in the details

I recently attended a Environmental themed conference.  Nearly 5000 professionals in Environmental, Health and Safety were there.  I saw many things at the show, but nothing surprised me more than seeing standing room only — and a line out the door — for one event.

What was it?  It was a talk on GHS, the Globally Harmonised System of Classification and labeling of chemicals.  I mean — it was a general talk.  Just a lay-of-the-land kind of talk.

Now, call me crazy, but I had to pull a high-level EHS association official aside and ask, “Really — are people really that confused about GHS?  You add a couple of sections onto the MSDS and use slightly different pictograms. Why all the commotion?”

The official nodded slightly as if she understood the question. She said it was true that most companies may have a GHS solution built in with their current MSDS management system. But then she explained why there were lines out the door for general GHS information.  So for those who — like me — are puzzled by the fuss over GHS, this one’s for you.

Understanding the new GHS.  To help understand the fuss about the US Occupational Safety and Health Administration’s (OSHA) newly final Hazard Communication Standard (HCS), it’s important to realize that this rule is OSHA’s most comprehensive rulemaking in a decade.  Of this I was reminded.

The updated HCS impact affects over five million businesses.  These are manufacturers, and to some extent distributors, that use or store chemicals. Plus, the new HCS affects almost 100,000 chemical manufacturers, importers, and distributors.

Because the new rule is a major revision of the HCS, OSHA is requiring employers to train all employees on the new rules. Training is expected to impose the bulk of the cost burdens on US businesses.

Software for GHS won’t be much different from the current MSDS vault type programs companies use today.  So training there should not be required, except for label making differences. Outsourced and SaaS solutions pose few training challenges — because these can be adjusted anytime, in real time. (SaaS is like the cloud — but believed to be more secure.)

But if you don’t outsource MSDS and GHS already — now is a good time to start.  Rather than accrue costs while piece-mealing SDS responsibilities under REACH, OSHA and now, effectively, GHS — some companies have found value in investing in a centralized, comprehensive, outsourced solution.

Billions of dollars at stake.  While the big-picture changes aren’t so scary, the details of it will get cumbersome. Largely the folks lining up at conferences to learn more are the consultants. They have to know everything, in theory.  There’s a lot of money at stake.

The new GHS introduces a set of criteria for classifying human health and physical hazards while identifying OSHA-defined hazards. It requires that companies classify substances and/or products to ensure the appropriate classifications are assigned. Chemical data and labels will often need revision — perhaps significantly — to conform to new document requirements as they emerge.

Achieving and maintaining compliance will be a complex and time-consuming undertaking for many companies. I’ve heard OSHA officials use the word “billions” when discussing total costs. (As soon as I can lock down a quotable source, you’ll hear about it here.)

Who’s attending “about GHS” forums?  Attending is anyone who has an eye on the money, basically.  No, that’s not fair.  Also attending are folks really trying to learn as much as they can. Groups and their motivations include:

  1. Industry professionals seeking to understand / react to implications of the new HCS rule, so they can competently and strategically manage resources, budget, training, and compliance
  2. Leading regulatory compliance experts and industry representatives who provide strategic advice to a broad spectrum of industry clients relative to regulatory standards, rule-making, and compliance.
  3. Journalists trying to distill key insights and analysis of the OSHA HCS adopting GHS
  4. Folks seeking discussions the multiple impacts, risk factors and estimated costs to be incurred by employers and manufacturers
  5. Individuals looking to refine and discuss definitions for “substance,” “mixture,” and hazard “classification,” among other critically important new terms
  6. Executives analysing strategic planning considerations and potential compliance/risk exposures

Audience by professional role?  Well, look out, here comes everybody:

  1. Environmental, Health, and Safety (EHS) Managers
  2. Product Marketing/Safety/Packaging & Labeling Professionals
  3. Human Resource Managers
  4. Fire Services Professionals
  5. International Marketing Professionals
  6. Compliance and Training Staff
  7. Environmental and Process Engineers
  8. Engineering and Plant Services Professionals
  9. Facility/Energy Planning Professionals
  10. Environmental Compliance and Reporting Management
  11. Monitoring/Environmental Resource Managers
  12. Environmental Health and Safety Management
  13. Production/Operations/Engineering/Environmental Management
  14. Environmental Consultants and Attorneys
  15. Environmental Risk Management Professionals
  16. Environmental/Corporate Counsel SVP/VP/Director
  17. SVP Finance/Engineering/Operations Management
  18. Power Plant Chief/Supervisor/Managers
  19. Physical Plant/Facility Management

If the question you ask yourself is, “Is this much ado about nothing?” then you’re probably all set.  If you really do have questions about GHS solutions, sign up for a seminar or webinar soon, before it’s too late! I say that and am not even promoting such a thing.  Just don’t get left out in the corridor like I did:  people are hot on this trail right now and it’s standing room only.

Cheers, and, as always, happy compliance.