GHS Label Compliance

Workers have a right to know what types of chemicals they handle throughout the course of their work, while employers have a responsibility to provide a safe workplace, free from serious recognized hazards and complying with standards, rules and regulations. Employers with hazardous chemicals in the workplace must develop and implement a written hazard communication program and train employees on the hazards they’re exposed to and proper precautions (with a copy of safety data sheets, or SDS, readily available).

In mid-February 2021, OSHA proposed an update to its Hazard Communication Standard (HCS). The updates aim to align provisions of the rule with the continually evolving Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The proposal could lead to changes in labeling and SDS. Continue reading for more information about hazcom rules and what to expect in the future, following OSHA’s recent announcement.

Understanding Chemical Safety, OSHA’s HCS and the GHS
Effective and compliant communication related to chemical hazards is a critical issue for workplace safety, evidenced by the violations related to it consistently ranking in the top three on OSHA’s annual list of most frequently cited safety violations, and ranking at number two in both 2018 and 2019.

OSHA’s HCS was initially developed to give workers the ‘right to know’ and subsequent updates have given them the ‘right to understand’ hazards and protection measures. To do this, better protecting workers from hazardous chemicals with a standard approach to SDS and labels, OSHA aligned its hazard communication standards with the GHS, a standard used worldwide. After a phased-in approach, GHS compliance requirements went into effect in June 2016. Since that time, labels and SDS must meet the chemical safety standards set forth by the GHS.

OSHA’s Recently Proposed HazCom Standard Changes
As the GHS continuously evolves, OSHA’s intention is to have better alignment with its HCS. The recent updates proposed by OSHA are meant to align with the seventh revision of GHS, which the U.N. published in 2017, as well as select provisions from the eighth revision of GHS, issued in 2019. OSHA last updated its HCS in 2012, aligning it with the third version of GHS.

OSHA hopes its recently proposed updates will increase worker protections and reduce the number of incidents of chemical-related workplace illnesses and injuries.

Some of the United States’ major global trading partners, including Canada, Australia, New Zealand and European countries, are all preparing to align with the updated version of GHS.

Key Areas of the Proposed Changes to OSHA’s HCS
This update is intended to increase worker protections and reduce the incidence of chemical-related occupational illnesses and injuries by improving the information on labels and SDS. As part of GHS, all hazardous chemicals must be properly labeled, and these labels must incorporate specific graphical symbols meant to convey the hazards related to each chemical. Nine GHS pictograms make up the GHS symbol vocabulary for defining specific types of chemical-related hazards. These pictograms – representing hazards and meanings like carcinogens, flammables, irritants, gases under pressure, explosives, skin corrosion/burns, oxidizers and aquatic toxicity – are used on labels appearing on chemical products and on their SDS. Each GHS pictogram consists of a distinctive black symbol appearing on a white background framed inside a red diamond-shaped border.

Key modifications in OSHA’s HCS included in the new proposed rule are:

1. Updated criteria for classification of particular health and physical safety hazards. These changes include: revised health hazard definitions, edits to the sections on skin and eye corrosion and irritation, changes to the Flammable Gases hazard class, expansion of the Flammable Aerosol hazard to include non-flammable aerosols and a new physical hazard class for desensitized explosives.
   
   
2. Revised/relaxed provisions for updating GHS labels. Recognizing that certain chemicals have a long distribution cycle, OSHA proposed to increase flexibility in labeling by not requiring labels for chemicals not immediately being shipped. OSHA proposed that all labels include an added data element, the date that the product is released for shipment.
   
   
3. More flexible labeling provisions for small containers. For containers with less than or equal to 100 ml of capacity, the label would require a product identifier, pictogram(s), a signal word, the chemical manufacturer’s name and phone number, and a statement that the full label information is provided on the outer package. For containers with less than or equal to 3 ml of capacity, no label would be required. Alternatively, the only information required on the container would be the product identifier.
   
   
4. Proposed edits related to the contents of SDS. They’ll now have a specified 16-section format.
   
   
5. Amendments to defining terms used in the standards. To help account for changes being made throughout the HCS, OSHA proposed changes to three existing definitions and added eight new terms and definitions. They include “exposure or exposed,” “hazardous chemicals,” and “physical hazard.” New terms to be defined would include “bulk shipment,” “combustible dust,” “gas,” “liquid,” “solid,” “immediate outer package,” “physician or other licensed health care professional (PLHCP)” and “released-for-shipment.” OSHA is also proposing that combustible dust be defined as “finely divided solid particles of a substance or mixture that are liable to catch fire or explode on ignition when dispersed in air or other oxidizing media.” Lastly, OSHA also proposed to edit the required hazard statement for combustible dust in Appendix B.

OSHA is currently accepting comments on its proposed rule until April 19.

Stay tuned for more developments and news – and in the meantime, here at Clarion Safety, we’re here to help with your GHS and chemical safety labeling and signage needs.

• Standards Insider