US DOT and OSHA Prep for UN Meetings on Hazmat Regulations and GHS

Posted on 10/31/2022 by Roger Marks

US DOT PHMSA and OSHA will host virtual public meetings on November 16 in preparation for a “hybrid meeting” of two United Nation sub-committees:

  • The UN Subcommittee of Experts on the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), and
  • ​The UN Subcommittee of Experts on the Transport of Dangerous Goods.

The UN subcommittees will meet in December in Geneva Switzerland. More information, including links to join the virtual meetings, is available on OSHA’s website.

When available, advanced registration information will be posted to PHMSA’s website.

What Happens at These Meetings?

During these UN subcommittee meetings, delegations from around the world present and discuss working papers to revise the Globally Harmonized System for Classifying and Labeling Chemicals (GHS) and the UN Model Regulations for the transportation of hazardous materials, respectively.

The GHS is relevant to US employers because OSHA has incorporated it into its Hazard Communication Standard (HCS) at 29 CFR 1910.1200. When OSHA adopted elements of the GHS in 2012, they adopted the 3rd edition. The GHS has continued to evolve on the international stage in the ten years since. 

In 2021, OSHA proposed a rulemaking to update the HCS, incorporating the 7th edition of the GHS. A Final Rule is planned for December 2022.

For hazardous materials shippers, changes to the UN Model Regulations often make their way into the US Hazardous Materials Regulations (HMR) via harmonization rulemakings promulgated by US DOT PHMSA. The most recent harmonization rule, HM 215-P, was finalized in July 2022.

HM 215-P added new and revised regulatory provisions for lithium batteries, adopted a new Special Provision (441) for marine pollutants, authorized new packagings for certain materials, introduced a new Hazmat Table entry for specific types of medical waste, and made many other revisions to the 49 CFR regulations.

The GHS requirements for labeling chemical containers impact hazmat shippers as well. OSHA's HCS requires chemical manufacturers, importers, and distributors to classify chemicals according to GHS criteria and include specific information on container labels and Safety Data Sheets. 

What’s On the Agenda for December?

Topics on the provisional agenda for the Transport of Dangerous Goods meeting include:

  • Various issues related to explosives,
  • Testing and transport provisions for lithium batteries,
  • Transportation of gases,
  • Proposals on marking & labeling, packagings, and portable tanks, and
  • GHS-related issues (e.g., testing of oxidizing substances).  

Topics on the agenda for the GHS meeting include:

  • Simultaneous classification in physical hazard classes and precedence of hazards
  • Use of non-animal testing for classification of health hazards
  • Development of guidance for classification and labeling issues,
  • Nanomaterials, and
  • Classification criteria for germ cell mutagenicity.
US DOT and OSHA Prep for UN Meetings on Hazmat Regulations and GHS

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Tags: dangerous goods, GHS, hazardous communication, hazmat shipping, UN Model Regulations

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