GHS 101: U.S. Adoption (HazCom 2012)

HazCom 2012 Meets GHS = The Right to Understand

On March 20, 2012, after a decades long effort, then OSHA Director Dr. David Michaels announced that the Hazard Communication Standard (HCS) had been revised to align with the Globally Harmonized System of Classification and Labelling of Chemicals, commonly known as GHS.

Published in the Federal Register on March 26, 2012, the adoption of GHS ushered in a new era of Hazard Communication for the United States. In his announcement, Dr. Michaels referred to the revised HazCom Standard as HazCom 2012. He said the first incarnation of HazCom gave employees the "Right to Know" what chemical hazards they were exposed to. With HazCom 2012, Dr. Michaels said employees now have the "Right to Understand."

Four years and four deadlines later, alignment of the HCS with GHS has been achieved. According to OSHA, the changes to the HCS impacted over 43 million workers in over 5 million workplaces. The biggest changes centered on:

• Hazard Classification
• Labels
• Safety Data Sheets
• Training

The greatest costs to businesses were around:

• Reclassifying of Chemicals
• Re-authoring of Safety Data Sheets
• Training of Workers on New Hazards and Formats
• Color Printing of Labels

In all, OSHA expected annualized costs connected to the transition (spread out over 4 years) to be over $200 million. Annualized savings were estimated to be between $700 and $800 million, for a new savings of $500 million annually. Additionally, OSHA expects the revised standard will prevent 43 fatalities and 585 injuries annually, which is calculated at 1% of the expected outcomes from the 1983 promulgation of the HCS.

There were 4 key compliance dates related to OSHA's adoption of GHS:

• December 1, 2013
  Employers were required to train employees on how to read GHS formatted labels and safety data sheets.
• June 1, 2015
  Chemical manufacturers and distributors had to complete hazard reclassification and produce GHS styled labels and safety data sheets. Distributors got an additional six months to complete shipments of old inventory.
• December 1, 2015
  Distributors had to comply fully with HCS requirements. (Grace period for shipments of old inventory ends).
• June 1, 2016
  Full GHS-alignment. Employers were now required to be in full compliance with revised HCS, including complete training of employees on new hazards and/or revisions to workplace hazard communication program.

If you've been thinking about implementing an electronic SDS Management solution and/or an on-demand Chemical Inventory Management solution, the time is now. Take action to save money, get and stay compliant, and — most importantly — keep your workforce safe from hazardous chemicals.

Access the UN’s GHS Third Revision by Clicking the Links Below:

• Foreword and table of contents
• Part 1: Introduction
• Part 2: Physical hazards
• Part 3: Health hazards
• Part 4: Environmental hazards
• Annex 1: Allocation of label elements
• Annex 2: Classification and labelling summary tables
• Annex 3: Codification of hazard statements, codification and use of precautionary statements and examples of precautionary pictograms
• Annex 4: Guidance on the preparation of Safety Data Sheets
• Annex 5: Consumer product labelling based on the likelihood of injury
• Annex 6: Comprehensibility testing methodology
• Annex 7: Examples of arrangements of the GHS label elements
• Annex 8: An example of classification in the Globally Harmonized Systems
• Annex 9: Guidance on hazards to the aquatic environment
• Annex 10: Guidance on transformation/dissolution of metals and metal compounds