A Guide to OSHA's New GHS Chemical Labeling Requirements

March 29, 2012
How and when will OSHA's updated Hazard Communication Standard (HCS), which will now be aligned with the Globally Harmonized System of Chemical Labeling (GHS), impact chemical labeling? Read on for a guide to the new labeling requirements.

OSHA estimates over 5 million workplaces in the United States will be affected by the revised HCS, including approximately 90,000 establishments that create hazardous chemicals. Combined, these chemical producers employ nearly 3 million workers. OSHA expects to make updates to its own HCS every 2 years in order to keep up with the U.N.'s anticipated changes.

OSHA's new labeling requirements are expected to have the greatest impact on U.S.-based chemical manufacturers and chemical importers, with few mandatory changes slated for other general chemical storage. HCS targets chemical manufacturers and importers to ensure their chemical containers will display a label similar to those now used in Europe and many other GHS adopters beginning June 1, 2015.

The GHS-inspired standards will require chemical manufacturers and importers to label chemical containers with 1) a harmonized signal word 2) GHS pictogram(s) 3) a hazard statement for each hazard class and category and 4) a precautionary statement. These elements are discussed in greater detail below:

· A harmonized signal word is used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words are "danger," used for the more severe hazards, and "warning," which is used for less severe hazards.

· The GHS pictogram is a symbol plus other graphic elements, such as a border, background pattern or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e., a red diamond).

· A hazard statement isassigned to a hazard class and category to describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.

· A precautionary statement is a phrase that describes recommended measures to minimize or prevent adverse effects resulting from exposure to or improper storage or handling of a hazardous chemical.

Employers who only store chemicals have the flexibility to use OSHA's new labeling system or choose to continue using the old NFPA 704 Hazard Rating System or Hazardous Material Information System (HMIS). However, the information supplied on these labels must be consistent with the newly revised HCS, e.g., no conflicting hazard warnings or pictograms.

Keep in mind that OSHA plans to update the old, "alternative" labeling system requirements June 1, 2016. Since alternative labeling requirements may change in fewer than 4 years and employers must train employees to understand new label elements and the new Safety Data Sheet (SDS) format by Dec. 13, 2013, voluntarily switching to the revised HCS labeling now likely will reduce costs over the long run and reduce confusion in the workplace.

The newly revised HCS outlines eight specific GHS pictograms for use on labels. Each is surrounded by a red border and designed to convey the health and physical hazards of chemicals. A ninth, environmental pictogram may be required by other agencies, but not by OSHA. Environmental hazards are not within OSHA's jurisdiction.

In addition to the new labeling requirements, chemical manufacturers now must supply customers with a GHS-standardized, 16-section SDS. The new format provides customers implement the new HCS standards an easy-to-understand reference for labeling.

A Coherent Approach

OSHA officials say the new changes provide "… a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets." Once implemented, OSHA leaders believe the revised standard will improve the quality and consistency of hazard information in the workplace, making it safer for workers by providing easily understandable information on appropriate handling and safe use of hazardous chemicals.

This latest update, officials add, also will help reduce trade barriers and result in productivity improvements for American businesses that regularly handle, store and use hazardous chemicals. Cost savings are also anticipated for American businesses that periodically update safety data sheets and labels for chemicals covered under the hazard communication standard.

For more information on these changes, visit http://osha.gov/dsg/hazcom.

Jack Rubinger of Portland, Ore., is an industrial copywriter for Graphic Products Inc. and DuraLabel.com. He has more than 20 years of experience writing for safety, industrial and trade media. DuraLabel will present a May 9 webinar on the GHS changes.

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