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GHS Labels May Delay Your Air Shipments

Posted on 12/2/2014 by Joel Gregier

It's been nearly three years since the Occupational Safety and Health Administration (OSHA) updated its Hazard Communication Standard to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) requirements. Officially published on March 26, 2012, the revised Hazard Communication Standard updates the way employees are protected in the workplace with new requirements for hazard warning labels, a standardized format for Safety Data Sheets in the workplace, and more.

For most employers, implementation of these new rules and compliance with the standard is mandatory by June 1, 2015. As this date approaches, many of your incoming hazardous chemicals may already show the new GHS labels and contain updated Safety Data Sheets.
 
OSHA's Workplace Labeling May Overlap With DOT's Hazardous Materials Rules

When shipped in commerce, many workplace hazardous chemicals are regulated as hazardous materials under US Department of Transportation (DOT) rules. When a DOT-regulated package is shipped, the package requires the appropriate GHS labels (and other warnings) in addition to DOT hazmat markings and labels.

In other cases, OSHA may regulate a chemical substance that DOT does not. When shipping these substances, the package requires the necessary GHS labels (and other warnings) only, not any type of DOT communication.

The difference has to do, in part, with the concerns of each agency. OSHA's Hazard Communication Standard covers chemicals stored and used in the workplace that pose short- and long-term physical and health hazards (e.g., chemicals that possess explosive, corrosive, or carcinogenic properties). DOT, on the other hand, focuses on the safe movement of hazardous materials in trade and, as such, regulates materials that exhibit more immediate hazards.

New Air Shipment Rule for Containers With GHS Labels

As more GHS labels enter the hazmat supply chain, shippers and carriers must be prepared to use the new labels, recognize them, and know what they mean. This is especially true for air shipments regulated by the International Air Transportation Association (IATA) Dangerous Goods Regulations. Because GHS pictograms resemble DOT hazmat labels, airline operators should be extra diligent in obeying all markings and warning labels on the outside of packages to avoid potential mishaps on the runway or in the air. A package with a GHS label on it does not necessarily contain IATA dangerous goods. If an operator sees a GHS label on a package, but no DOT markings, he/she should take extra steps and confirm with the shipper that the contents are not regulated as dangerous goods under IATA. [IATA DGR 2.2 and 9.1.1.2]

DOT and GHS hazmat and hazcom Labels

To prevent delays when shipping OSHA-only hazards by air, IATA suggests that shippers write the words "not restricted" on the air waybill to indicate that the materials are not IATA dangerous goods. [IATA DGR 8.2.6.2]

To help shippers and hazmat employees avoid confusion as GHS labels enter the supply chain, Lion will present the GHS Compliance for Hazmat Shippers Webinar on January 27, 2015. The live, instructor-led webinar covers how new GHS labeling criteria will affect hazmat shipments sent by ground, air, and ocean. Gain clarity on what labels to use, when, and on what packages and containers. Understanding how the new HazCom Standard relates to your shipping responsibilities is critical to prevent confusion among carrier personnel, delayed shipments, and DOT fines as high as $75,000 per day, per violation.

Tags: GHS, HazCom, hazmat shipping, IATA, osha

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