GHS Deadline Is Less Than 30 Days Away

In 2012, the United States Department of Labor's Occupational Safety and Health Administration (OSHA) promulgated final amendments to the Hazard Communication Standard (HCS), to harmonize it with the United Nations Globally Harmonized System of Classification & Labeling of Chemicals (GHS).

These amendments, the first significant changes to the HCS in almost 20 years, made many changes to different parts of the Standard (and related parts of other Standards) but did not alter the underlying thrust of the program.

While criteria for classifying chemicals as occupational hazards have been modified, the rules governing who classifies chemicals as hazardous, authors Safety Data Sheets, affixes labels, and prepares written workplace Hazard Communication Programs have not changed. But for the first time, OSHA has provided us with explicit criteria for the full content of Safety Data Sheets and container labels. Since its publication more than three years ago, the final GHS rule has brought with it much discussion about many of its elements, including:

• Confusion over package labels regulated by the US DOT and workplace container labels regulated by OSHA;
• Amended criteria for the physical and/or health hazards posed by chemicals (i.e., revised definitions, newly added terminology, updated test methods, etc.); and
• Compliance with the new content-laden labels and how to fit them onto small sized containers.

Due to the expansive scope of these rule changes, OSHA allowed for an extended phase-in period:

• December 1, 2013—Employers must train employees on the new label elements and Safety Data Sheet format
• June 1, 2015—Chemical manufacturers, importers, distributors, and employers must comply with all modified provisions of the rule (e.g., new labels, new Safety Data Sheets, etc.)
• December 1, 2015—Distributors of hazardous chemicals have until this date before all containers they ship must bear a GHS label
• June 1, 2016—All employers must update their workplace hazard communication program and provide additional employee training for new chemical hazards, as applicable

In the lead-up to the transition date this summer, some manufacturers and distributors of complex chemical formulations have found it difficult to obtain information from their upstream suppliers. As a result, this has unfavorably impacted their ability to complete new labels and Safety Data Sheets. In response, OSHA recently issued guidance to provide relief for temporary data gaps caused by insufficient upstream information.

Here's a list of letters of interpretation and other guidance from OSHA since the publication of the GHS final rule:

• Comparison of HAZCOM 2012 and NFPA 704 (i.e., Fire Diamond) labels
• Letter: Classification of Combustible Dusts
• Letter: Classifying Petroleum Streams
• Letter: Classification Criteria for Single Target Organ Toxicity
• Letter: Classification of Hazards Not Otherwise Classified
• Letter: Application of HCS to Combustible Dust
• Letter: Effectively Extending Transitional Period for Downstream Users
• OSHA Brief: Label and Pictograms Under the Hazard Communication Standard

Lion Technology has maintained up-to-date information on the transition dates, training requirements, and rule interpretations since OSHA adopted GHS standards in 2012.

Further GHS Reading:

Labeling

• GHS Labels May Delay Your Air Shipments
• OSHA Lifts Prohibition on HCS & DOT Labels on Same Package
• New GHS Labels vs. DOT Labels
• Small Containers a GHS Challenge for Chemical Industry

Classification

• How GHS Affects OSHA's Flammable Liquid Standard
• OSHA Memo: New Combustible Dust Hazard Classification
• GHS: Hazards Not Otherwise Classified

Safety Data Sheets

• One Year Left to Update Safety Data Sheets
• GHS Labeling: More Than Just a Picture
• Updating Safety Data Sheets

Less Than 30 Days Left to Comply

For hazmat shippers, Lion will present the live, instructor-led GHS Compliance for Hazmat Shippers Webinar on May 12. The webinar will help you get ready to conquer the challenges hazmat shippers face now that OSHA's new GHS rules are imminent. Don't let hazard labeling delay your shipments, confuse your supply—chain partners, or subject you to DOT or OSHA civil penalties—sign up now.

 

Tags: GHS, HazCom, hazmat shipping, marks and labels, osha