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Introduction to Labeling Challenges: OSHA’s Revised Hazard Communication Standard

As an industry, manufacturing has multiple ways of defining hazards and even more ways of communicating about those hazards. Designed to create a worldwide standard, the Globally Harmonized System for Classification and Labeling of Chemicals (GHS) has evolved in ways that create challenges for chemical producers and shippers.

What is the GHS?
The United Nations adopted the GHS in 2003. OSHA’s revised Hazard Communication Standard has presented manufacturers, formulators, and distributors with the challenge of revising their Safety Data Sheets (SDSs) and the product labels by June 1, 2015. These changes are based on the third revision of the GHS.

The evolution of the GHS has created some challenges, including the mandatory use of red color, the potential need for multiple languages if shipping to other countries, various US state issues like New Jersey's “Right to Know” that go beyond OSHA's requirements, and many other regional regulatory requirements for compliance in the global marketplace. The reality is that virtually every label for a hazardous chemical product is subject to change and in many cases will require changes on an ongoing basis into the unforeseeable future.

Complicating the environment in which these regulations will go into effect, the chemicals industry faces a major challenge due to the fact that many large companies have decentralized their hazard communication work processes. In addition, many medium and small companies don't have the internal resources to create their own Safety Data Sheets and must use outside resources. Because of the additional requirements in the 2012 OSHA and GHS regulations to be implemented starting June 1, 2015, regardless of how or where a Safety Data Sheet is created, automated systems will need to be capable of pulling the information from Section 2 of the SDS on to labels. In addition, the current complex nuances of labeling include having many different products of various shapes and sizes, the need to respond to customer requirements, the need to access transactional data, languages, branding information, and more.

Why the GHS?
Before adoption of the GHS, multiple systems and definitions of hazard were the rule. Even here in the United States, there have been — and to some extent still are — different definitions of various physical and health hazards presented by chemical substances. Looking at just two hazards such as flammability and oral toxicity, charts 1-3 on the next page show the disparity in definitions and how the GHS has created a common basis for these two frequently encountered hazards. These hazards were compared based upon 2009 regulations because many countries have already adopted or are adopting GHS definitions.

For instance, the European Union (EU) adopted the GHS for substances in 2010, and the classification and labeling of mixtures is scheduled to become mandatory by June 1, 2015, the same day as OSHA's mandatory implementation date. Canada is actively working on instituting the GHS but will not be able to complete implementation for industrial products by 2015. Accordingly, it is trying for mandatory implementation by manufacturers by June 1, 2016, and a complete implementation by June 1, 2017, when stock on shelves can no longer be shipped with older formatted labels. Therefore, between June 1, 2015, and June 1, 2016, shippers in the US may need to create a separate label for Canadian shipments.

As an industry, manufacturing has multiple ways of defining hazards and even more ways of communicating about those hazards. Designed to create a worldwide standard, the Globally Harmonized System for Classification and Labeling of Chemicals (GHS) has evolved in ways that create challenges for chemical producers and shippers.

What is the GHS?
The United Nations adopted the GHS in 2003. OSHA’s revised Hazard Communication Standard has presented manufacturers, formulators, and distributors with the challenge of revising their Safety Data Sheets (SDSs) and the product labels by June 1, 2015. These changes are based on the third revision of the GHS.

The evolution of the GHS has created some challenges, including the mandatory use of red color, the potential need for multiple languages if shipping to other countries, various US state issues like New Jersey's “Right to Know” that go beyond OSHA's requirements, and many other regional regulatory requirements for compliance in the global marketplace. The reality is that virtually every label for a hazardous chemical product is subject to change and in many cases will require changes on an ongoing basis into the unforeseeable future.

Complicating the environment in which these regulations will go into effect, the chemicals industry faces a major challenge due to the fact that many large companies have decentralized their hazard communication work processes. In addition, many medium and small companies don't have the internal resources to create their own Safety Data Sheets and must use outside resources. Because of the additional requirements in the 2012 OSHA and GHS regulations to be implemented starting June 1, 2015, regardless of how or where a Safety Data Sheet is created, automated systems will need to be capable of pulling the information from Section 2 of the SDS on to labels. In addition, the current complex nuances of labeling include having many different products of various shapes and sizes, the need to respond to customer requirements, the need to access transactional data, languages, branding information, and more.

Why the GHS?
Before adoption of the GHS, multiple systems and definitions of hazard were the rule. Even here in the United States, there have been — and to some extent still are — different definitions of various physical and health hazards presented by chemical substances. Looking at just two hazards such as flammability and oral toxicity, charts 1-3 on the next page show the disparity in definitions and how the GHS has created a common basis for these two frequently encountered hazards. These hazards were compared based upon 2009 regulations because many countries have already adopted or are adopting GHS definitions.

For instance, the European Union (EU) adopted the GHS for substances in 2010, and the classification and labeling of mixtures is scheduled to become mandatory by June 1, 2015, the same day as OSHA's mandatory implementation date. Canada is actively working on instituting the GHS but will not be able to complete implementation for industrial products by 2015. Accordingly, it is trying for mandatory implementation by manufacturers by June 1, 2016, and a complete implementation by June 1, 2017, when stock on shelves can no longer be shipped with older formatted labels. Therefore, between June 1, 2015, and June 1, 2016, shippers in the US may need to create a separate label for Canadian shipments.

1 comment on “Introduction to Labeling Challenges: OSHA’s Revised Hazard Communication Standard

  1. Ariella
    January 9, 2015

    It makes sense that a global economy would require companies to set up their lables to be meaningful for each country their products reach.

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