Updates To The GHS Language

OSHA’s “Right to Know” laws are evolving into the “Right to Understand” regulations. But, that isn’t the only change to occur to the GHS's terminology. OSHA has discarded the term “hazard determination” and has replaced it with “hazard classification” to better reflect the language used in the global program. It has also dropped the word “material” from the MSDS, so that the document is now referred to as a “safety data sheet” or SDS.

In addition to changes in terminology, OSHA has adopted the United Nation’s system of pictograms — a series of nine images depicting various hazard warnings that are required to be displayed on chemical labels. The images include symbols such as a “flame” and an “exploding bomb” to express hazards relating to fire and combustion, respectively.

Among the chief changes to the GHS standard are the agency’s strict new chemical evaluation and labeling rules.

Under current OSHA laws, an evaluation of chemical hazards is performed using the available scientific evidence regarding such hazards. Using the data, an evaluator then determines what hazards a chemical presents to its users.

This process isn’t changing. But, whereas that method was conducted on a performance-oriented basis — OSHA provided guidelines for chemical evaluation, but not explicit, detailed instructions — the revised standard spells out specific criteria for each health and physical hazard, as well as meticulous directions for carrying out the hazard evaluations. It also draws a distinction between hazard classes (describing the nature of the physical or health hazards, e.g. flammable solid, carcinogen, oral acute toxicity) and hazard categories, which includes the division of criteria within each hazard class. Once the hazard classification is complete, the new standard requires all of the information to appear on the chemical’s label.

Under GHS, each label will now require:

• Pictogram: a symbol plus other graphic elements that is intended to convey specific information about the hazards of a chemical. Pictograms must retain the given format, i.e. red borders with GHS symbols.

• Signal Words: a single word used to indicate the level of severity of the hazard and alert the reader to the potential danger. “Danger” is used for more severe hazards, while “warning” is used for less severe hazards.

• Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazards of a chemical, including the degree of the hazard.

• Precautionary Statement: a phrase that describes the recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical.

OSHA has lifted a stay on enforcement regarding the provision to update labels when new hazard information about a particular chemical is available. Chemical manufacturers, importers, distributors or employers have six months to revise the labels after the information is received. All chemical labeling must be in compliance with the GHS standard by June 2016, but up until that date employers may comply with the old hazard communication standard, the new GHS standard, or both.

Perhaps the party under the most pressure with the changes then is the chemical manufacturers, who are required to replace their existing product labels with ones that embrace the new format.

“Manufacturers have a lot of latitude in how they make [chemical label] descriptions, but with the new standard it is much more prescriptive,” says Bill Balek, director of legislative affairs at the ISSA. “Before they re-label, they have to reclassify their products. We’re using a different scheme of stratifying the products and they are very detailed.”

Besides changing labels, the revised safety data sheets require information to be presented in a 16-section sequence. Before GHS, OSHA allowed either its eight-section format or ANSI’s 16-section format to be used. Now, the SDS will be similar to ANSI’s version with the requirement that the sections be presented in a strict order. Formerly, the document’s format was left up to manufacturers.

The required order is as follows: Identification, Hazard’s identification, Composition/information on ingredients, First Aid measures, Fire-fighting measures, Handling and Storage, Exposure controls/personal protection, Physical and chemical properties, Stability and reactivity, Toxicological information, Ecological information, Disposal considerations, Transport information, Regulatory information, and Other information, including date of preparation or last revision.

Casavant says he expects the changes to SDSs and chemical labels to present an ongoing challenge to custodial managers over the next few years, as they attempt to bring their inventory into compliance.

“I think it’s safe to say that folks are stressed,” says Casavant. “People are quite concerned about the workload this new standard will bring. [Employers] suspect some chemical manufacturers will take their time in complying and that will create issues for end users downstream.”

Stephanie S. Beecher is the associate editor of Contracting Profits magazine, a sister publication to Facility Cleaning Decisions.