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The Future of GHS HazCom in the US

Posted on 10/26/2020 by Joel Gregier, CDGP

In 2012, OSHA made one if the most impactful regulatory changes in its history when it adopted the Globally Harmonized System for Classification and Labeling of Chemicals (GHS) into the Hazard Communication (HazCom) Standard at 29 CFR 1910.1200. 

With the adoption of GHS requirements, OSHA drastically changed how chemical safety labels and Safety Data Sheets (SDSs) must convey hazard information.

But the GHS rules OSHA adopted in 2012 are outdated now. OSHA adopted the 3rd Revised Edition of GHS in 2012. Since then, GHS has undergone several revisions, and are now up to the 8th Revised Edition.   

To keep pace with the evolving international requirements, OSHA will update its HazCom Standard again soon.

The Future of GHS HazCom in the US

Why Does GHS Change?

The UN describes the GHS as a “living document.” What that suggests is that our understanding of hazards can change over time.  When new scientific data about hazards emerges, regulators update GHS to take those into account. Also, if the current rules are found to be lacking or unsafe, adjustments need to be made. Thus, the need for ongoing revisions.

Changes in new GHS editions can include newly identified hazards (e.g., desensitized explosives), or may introduce new statements/phrases for use on GHS labels and SDSs.

Which GHS Edition Will OSHA Incorporate Next?

We don’t know for sure which edition of the GHS OSHA will incorporate into 1910.1200 next. The Spring Agenda states that “OSHA is conducting rulemaking to harmonize the HCS to the latest edition of the GHS and to codify a number of enforcement policies that have been issued since the 2012 standard.” 

Based on this statement, it sounds like OSHA will incorporate the most current edition—the 8th.

However, OSHA started the process to incorporate a newer GHS edition in 2016. At that time, the “latest edition” was the 6th Revised Edition GHS.

Unless OSHA has been adjusting their proposed-rule-in-progress to keep up with ongoing revisions, it’s possible that OSHA adopts a “newer” edition of the GHS (i.e., the 6th) but not the newest one (i.e. the 8th).

How Soon Will OSHA Adopt New GHS Rules?

OSHA’s effort to incorporate a newer edition of the GHS into its HazCom Standard (29 CFR 1910.1200) is ongoing. The latest rulemaking on the topic is currently stalled in the “Proposed Rule Stage” of development.  

In the most recent Spring Agenda of Regulatory and De-regulatory Actions, OSHA indicated that a Notice of Proposed Rulemaking (NPRM) to revise the HazCom regulations could appear in 2020. No proposal has surfaced as of this writing in mid-October 2020.  

Lion Members can login to see our full summary of the Spring 2020 Agenda.

Lion tracks the status of all forthcoming hazardous materials, hazardous waste, and HazCom regulations, and will provide an update via Lion News when a proposal to adopt a newer GHS edition appears in the Federal Register. You can also track the rulemaking yourself here.  
 
While we don't know exactly when the next round of GHS harmonization will happen, we do know that it is OSHA's agenda and should be out "soon." But that could mean in a few weeks, a few months, or few years depending on OSHA’s progress.

We do know this: Once OSHA has agreed upon the amended regulation, it will be subject to the rulemaking process, including a 90-day public comment period before it takes effect.

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Tags: 29 CFR 1910.1200, GHS, hazard communication, HazCom, OSHA compliance

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