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Flexo Sustainable : Earth Day 2013
Hazardous Communications Standards Modified Global Labeling Classification for Chemicals Deployed By Doreen Monteleone The Globally Harmonized System (GHS) is an interna- tional approach to hazard communication providing criteria for classification of chemical hazards and a standardized approach to label elements and safety data sheets (SDSs). The GHS was negotiated in a multi-year process by hazard communication experts from many differ- ent countries, international organizations and stakeholder groups. It is based on major existing systems around the world, including the Occupational Safety & Health Admin- istration's (OSHA) Hazard Communication Standard (HCS) and the chemical classification and labeling systems of other agencies in the United States. OSHA has modified its HCS to adopt the GHS to improve safety and health of workers through more effective commu- nications on chemical hazards. Since 1983, the HCS has pro- vided employers and employees extensive information about the chemicals in their workplaces. The original standard is performance-oriented, allowing chemical manufacturers and importers to convey information on labels and material safety data sheets (MSDSs) in whatever format they choose. Available information has been helpful in improving em- ployee safety and health, a more standardized approach to classifying the hazards and conveying the information will be more effective and provide further improvements in Ameri- can workplaces. The GHS provides such a standardized approach, including detailed criteria for determining what hazardous effects a chemical poses, as well as standardized label elements assigned by hazard class and category. In addition, the MSDS is replaced with the SDS, which re- quires a standardized order of information. The harmonized format of the SDS will enable employers, workers, health pro- fessionals, and emergency responders to access the informa- tion more efficiently and effectively, thus increasing their utility. Adoption of the GHS around the world will also help to im- prove information received from other countries, as chemicals crossing borders will have consistent information, thus improv- ing communication globally. PHASE-IN PERIOD The table at right summarizes the phase-in dates required under the revised HCS. During the phase-in period, employers will be required to be in compliance with either the existing HCS or the revised HCS, or both. OSHA recognizes that hazard communication programs will go through a period of time where labels and SDSs, under both standards, will be present in the workplace. This will be considered acceptable and employers are not required to maintain two sets of labels and SDSs. Effective Completion Date Requirement(s) Who Dec. 1, 2013 Train employees on the new label elements and SDS format. Employers June 1, 2015* Dec. 1, 2015 Compliance with all modified provisions of this final rule, except: The distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label. Chemical manufacturers, importers, distributors and employers June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary and provide additional employee training for newly identified physical or health hazards. Employers Transition Period to the effective completion dates noted above May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both. Chemical manufacturers, importers, distributors and employers *This date coincides with the European Union's implementation date for classification of mixtures EMPLOYEE TRAINING OSHA is requiring that employees are trained on the new label elements (e.g., pictograms and signal words) and SDS format by Dec. 2013, while full compliance with the final rule will begin in 2015. OSHA believes that it is possible that American workplaces may begin to receive labels and SDSs that are consistent with the GHS shortly after publication. Thus, making it important to ensure that when employees begin to see the new labels and SDSs in their workplaces, they will be familiar with them, understand how to use them, and access the information effectively. The three major areas of change in the HCS are in hazard classification, labels and SDSs. • Hazard Classification: The definitions of hazard have been changed to provide specific criteria for classifica- tion of health and physical hazards, as well as classifica- tion of mixtures. These specific criteria will help to ensure www.flexomag.com EARTH DAY 2013 Sustainable FLEXO 7