How to Transition to the Globally Harmonized System

Transitioning to the Globally Harmonized SystemGHS Seminar Outline• GHS Overview • GHS and OSHA HazCom Compared• MSDS Authoring Considerations• Timeline for Adoption• 7 Tips to Transition• GHS Resources2Connecting the Chemical World• Globally Harmonized System of Classification and Labeling of Chemicals– Standardized approach to: – define health, physical and environmental hazards– classify hazards– communicate hazards in the workplace & beyond– Guide for national chemical safety programs3GHS Benefits• Unified Communication• Enhanced Protection• Improved International Trade• Reduced cost4GHS TimelineInternational mandate issued by UNCED to develop Hazard classification and labeling system to ANPR published by EU sets 3 year transition assist with international OSHAfor pure substance, 5 year communicationtransition for mixturesfirst edition approved, Nov - public comment published in 2003period closedUN recommends Expected draft of final international ruling and adoption in implementation goalthe U.S1992200020032005200620072008200920102011+R u l e m a k i n g a n d I m p l e m e n t a t i o nSubcommittee of OSHA indicates that GHS 2nd revision is experts created by HCS will align with publishedUNGHSOSHA releases Anticipated 3 year Europe adopted the NPRM in United transition period proposed act to Statesstarting in 2011align the current EU system with GHS5International UpdatesRegionStatusEUAdopted its regulation to align with the GHS in December 2008. Is in the process of implementation of substances first then mixtures – 3yr transition for pure substances, 5 yr for mixtures.ChinaGHS implementation effective as of July 1, 2009KoreaRevised their Industrial Safety and Health Act for GHS alignment June 30, 2010 for substances and June 30, 2014 for mixtures.Japanthe first country to publish classification of 1500 chemicals according to GHS standards. The GHS was introduced to their Industrial Safety and Health Law (ISHL) with 640 listed chemicals in which SDSs were required as of May 31, 2007.Newto adopt by July 1 2008ZealandCanadaStill working on GHS preparation. Consultation with stakeholders is ongoing. Economic analysis is required. GHS implementation will be at least two years once the legislative process starts. Planning on a transition period.6OSHA PerspectiveP O S I T I O NT I M E TA B L EE N F O R C E M E N T• Revise HCS to align • Notice of Proposed • Training within 2 with the GHSRulemaking in reviewyears of final rule and full compliance within • Maintain framework, • Possible 2011 for 3 yearsenhance protectionadoption• During transition, compliance with either current or new rule is sufficient7Primary HCS ChangesMSDSLabelsMSDSs will need to be updated Labels will need to be or re-authored to meet GHS reprocessed during transition. guidelinesStandardized pictograms, signal words, hazard statements will be required.Communication TrainingUpdated safety data sheets and Employees must be trained on labels will need to be circulated the new content and format of and distributed to stakeholdersSDSs and chemical labels8How Will the MSDS Change?• Safety Data Sheets• GHS Format: 16 sections required, in specified order• Reclassification based on GHS Criteria – Health & Environmental– Physical– Building Block Approach 9Health, Environmental, & Physical HazardsHealth & PhysicalPhysical (cont)EnvironmentalAcute toxicityExplosivesPyrophoric liquidsSkin corrosion/irritationFlammable gasesPyrophoric solidsSerious eye damage/eye Flammable aerosolsSelf-heating substances irritationand mixturesRespiratory or skin Oxidizing gasesSubstances and mixtures sensitizationwhich, in contact with water, emit flammable gasesGerm cell mutagenicityOxidizing gasesOxidizing liquidsCarcinogenicityGases under pressureOxidizing solidsReproductive toxicityFlammable liquidsOrganic peroxidesSpecific target organ Flammable solidsCorrosive to metalstoxicityAspiration hazardSelf-reactive substances and mixturesHazardous to the aquatic environmentHazardous to the ozone layer10