Now that the June 1 deadline for compliance with OSHA’s revised “GHS” Hazard Communication Standard (HCS) has arrived, it’s critical that EHS managers and safety personnel understand how to comply with a “global” rule. Industry in the US is used to ensuring compliance with a variety of domestic agency regulations from EPA, US DOT, OSHA, and others, and even international rules like the IATA or IMDG hazmat shipping standards. But for businesses that offer or receive international chemical shipments, the “G” in GHS holds important implications.
This blog has covered many facets of GHS compliance since OSHA adopted the standards in 2012. The deadline for compliance is today, June 1.
GHS and the Law
GHS stands for Globally Harmonized System (of Chemical Classification and Labeling). The “System” is an international model regulation created by the United Nations. GHS is not, in-and-of-itself, an international law.
Unlike an international law, which sets a uniform rule or rules for all countries to follow, the GHS model regulation allows each nation to adopt parts of the system and modify the rules to fit their country’s own needs. In the US, OSHA is the lead GHS agency and has adopted most GHS definitions and standards into its Hazard Communication Standard (HCS), found at 29 CFR 1910.1200. What It Means for “Global” Shipments
Because GHS is not a set of mandatory standards, compliance in one country does not necessarily translate to compliance in another country. If you ship globally, it is critical to know what parts of the GHS, if any, the destination country has adopted and what changes they may have made to these rules.
For instance, OSHA requires product labels on containers in US workplaces to be written in English. An accurate translation into one or more languages is not forbidden. [29 CFR 1910.1200(f)(2)]
If you ship to a country that requires a different language on containers, it is your responsibility to know this before signing off on the shipment. If your product labels do not comply with the destination country’s standards, you may incur shipping delays or even civil penalties.
To help shippers manage the ongoing worldwide implementation of these GHS standards, the UN committee in charge of GHS provides an international schedule and key contacts here
. GHS Training for Managers and Employees
Make sure your employees are prepared to protect themselves under OSHA’s HCS with the Hazard Communication Online Course
, updated to reflect the new GHS standards in effect as of June 1, 2015. For EHS managers who oversee their site’s HazCom program, Lion offers the Managing Hazard Communication Online Course