On October 25, 2011, OSHA sent the Office of Management and Budget (OMB) its final rule to adopt the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) as its hazard communication standard (HCS). OMB now has up to 90 days to review and finalize the rule before it is published in the Federal Register.

GHS introduces a set of criteria for categorizing the human health, physical and environmental hazards of hazardous substances. Prior to GHS, a substance could have been classified as toxic, non-hazardous or harmful to health depending on which country/tracking block the classification has been made (Canadian WHMIS, EU DPD, etc.). GHS harmonizes these different systems, and new classification criteria could create a higher, lower, identical or new classification for a product compared to the previous system. The new standard also has far-reaching implications for the format of, and data contained within, material safety data sheets (MSDS) and product labels.

In addition, the promulgation of the final rule will affect millions of workplaces and have a profound effect on the supply chain.

Upstream Requirements

Manufacturers and distributors will be required to re-classify all substances and mixtures and conform to a new safety data sheet (SDS) and label format and content requirements.

Downstream Requirements

Producers, importers and distributors will need to be prepared to evaluate the new SDS, utilize and capture the information and distribute and train employees on all new requirements.

The proposed rule includes a 3 year transition period for full compliance and a provision that requires employers to train all employees on the new label elements and the standardized safety data sheet format within 2 years after the publication of the HCS final rule.

Preparing for Success

With these significant changes looming on the horizon, how does one prepare? For some, transitioning to GHS has been coined as an “avalanche” or a “tidal wave.” However, if the appropriate tools are in place to handle the transition, the volume and scope of change ahead does not need to be daunting.

This guidance webinar will describe best practice methods to guide your company through the transition to GHS. These methods will ensure many positive outcomes are easily and naturally achieved, in addition to GHS compliance.

To learn more, please join us for our Global Harmonization webinar on January 31.

Erin McVeigh is a Product Manager with 3E Company, a global provider of chemical, regulatory, and compliance information services. In her current role, she is responsible for the development of MSDS rules and templates and managing the regulatory requirements related to safety data sheets and labels for both SAP and MSDgen.

Louise Bernstein is a Product Manager with 3E Company. Bernstein has many years of collected international Environmental, Health and Safety knowledge, beginning with Communications Officer for the Department for Food and Rural Affairs (DEFRA) in the UK, then in Canada as Product Marketing Manager for MSDS Solutions.