Special GHS Announcement
OSHA Hazard Communication Standard and the Globally Harmonized System of Classification and Labeling of Chemicals
In 2012, the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS 2012) was updated to fully align with the United Nations’ Globally Harmonized System (GHS). GHS is intended to improve the quality and consistency of hazard information in the workplace by incorporating more globally recognized classification criteria.
CRL is committed to providing comprehensive and thorough hazard communication and product safety guidelines in order to provide a higher degree of responsible care. Please be assured that we have been working hard to meet all requirements of GHS.
The most recognizable label from GHS will be pictograms on labels to convey specific hazard information, as well as statements reflecting the potential for carcinogenicity and/or organ toxicity. The components of the label will remain but may differ in location and content. GHS pictograms and the carcinogenicity/toxicity statements will be added. The pictograms represent the different hazard classifications associated with a product.
Implementation of GHS in the United States is June 1, 2015. However, OSHA has provided an extension in cases where required data has not yet been obtained. For this reason, some CRL products will continue to enter into commerce past June 1 that do not display the GHS format. The reason for the delay is that HCS 2012 has the same implementation date for both chemical manufacturers and raw material formulators.
This means that like many suppliers, CRL did not receive all of the necessary information to fully develop all of the required label elements for HCS 2012 conversion by the June 1, 2015 deadline. This also impacts all Material Safety Data Sheets (MSDS) which are converting over to a Safety Data Sheet (SDS) with some content changes.
To support suppliers through this transition, OSHA has allowed for a 6 month transition period from the time of receipt of the necessary information to produce a compliant SDS, and an additional 6 months from that date to produce a compliant label. OSHA has also extended this relief to distributors who are still awaiting receipt of products with the required revised GHS labels/SDS. Distributors can continue to offer non GHS formatted products during the transition period.
We are working with our suppliers to expedite the flow of information to bring as many products into compliance with HCS 2012. We will continue our internal compliance efforts, and are working to minimize the anticipated timeframe to clear existing stock from the distribution chain. We anticipate that within the upcoming months, all products will have GHS compliant labeling.
What does GHS stand for and what is it?
GHS stands for the United Nations Economic Commission for Europe’s (UNEC) “Globally Harmonized System of Classification and Labeling of Chemicals”. It is a system for evaluating and communicating the hazards posed by chemical substances by standardizing the content and format of the documentation (i.e. labels and MSDS). The intent of the system is to improve the quality and consistency of hazard information in the workplace.
Why does GHS apply to you?
The Occupational Safety and Health Administration (OSHA) has amended their Hazard Communication Standard (often referred to as HazCom or HCS 2012) to reflect GHS requirements. The HCS 2012 standard changes are primarily confined to the sections concerning Safety Data Sheets and labels, while the rest of the standard has remained basically unchanged. The amended HCS 2012 standard requires us to modify all of our existing MSDSs and product labels.
What changes will you be seeing?
• The most recognizable change are in the graphics and content on the product labels. There will now be pictograms to convey specific hazard information and statements reflecting the potential for carcinogenicity and/or organ toxicity.
• The “Material Safety Data Sheet” (MSDS) will also change to a “Safety Data Sheet” (SDS), but the same 16 section format that we currently utilize will remain. The data in each section of the SDS may differ slightly in content or layout.
• The product labels will continue to be compliant with Canadian WHMIS (Workplace Hazard Management Information System) in combination with the new HCS 2012 elements. Canada has recently adopted the GHS model and we will begin phasing in these changes as GHS is adopted in Canada.
Are you able to return product that has passed the June 1, 2015 deadline?
Product currently in the channels of trade is not subject to GHS remediation and therefore can continue to be distributed. The product remains compliant under the current hazard communication standard.