What is GHS?
The Hazard Communication Standard (HCS) is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This update to the Hazard Communication Standard (HCS) will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. Once implemented, the revised standard will improve the quality and consistency of hazard information in the workplace, making it safer for workers by providing easily understandable information on appropriate handling and safe use of hazardous chemicals, as well as harmonizing U.S. hazard communication rules with those used internationally.
The three major areas of change are in hazard classification, labels and safety data sheets (SDS).
- Hazard Classification: The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a result.
- Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
- Safety Data Sheets: SDSs will now have a specified 16-section format.
The OSHA standard is moving from “Worker Right To Know” to “Worker Right To Understand.”
Why are we doing this?
The Hazard Communication Standard (HCS) is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This update to the Hazard Communication Standard (HCS) will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. Once implemented, the revised standard will improve the quality and consistency of hazard information in the workplace, making it safer for workers by providing easily understandable information on appropriate handling and safe use of hazardous chemicals.
What does GHS mean to me and my customers?
In order to ensure chemical safety in the workplace, information about the identities and hazards of the chemicals must be available and understandable to workers. OSHA’s Hazard Communication Standard (HCS) requires the development and dissemination of such information.
- Chemical manufacturers and importers are required to evaluate and classify the hazards of the chemicals they produce or import, and prepare labels and safety data sheets to convey the hazard information to their employees and their downstream customers.
- Distributors must transmit the required information to their customers (Employers).
- All employers with hazardous chemicals in their workplaces must provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, safety data sheets, and information and training on how to handle the chemicals appropriately. Employers who do not produce or import chemicals need only focus on those parts of the HCS that deal with establishing a workplace program and communicating information to their workers.
How are SDSs different than MSDSs?
The Hazard Communication Standard (HCS) (29 CFR 1910.1200(g)), revised in 2012, requires that the chemical manufacturer, distributor, or importer provide Safety Data Sheets (SDSs) (formerly MSDSs or Material Safety Data Sheets) for each hazardous chemical, to downstream users, to communicate information on these hazards. The information contained in the SDS is largely the same as the MSDS, except now the SDSs are required to be presented in a consistent user-friendly, 16-section format.
The new OSHA HCS GHS standard includes changes to the definitions of health and physical hazards, and the methods by which hazards are determined including bridging principles, cut-off values/concentration limits, and additivity formulas. Some ingredients and mixtures that were not previously classified as hazardous under the old OSHA standard definitions are now classified as hazardous under the new OSHA HCS GHS standard.
Another big change under the new OSHA HCS GHS standard is the use of pictograms in addition to precautionary statements to convey hazard information. For example, our product 470FX Problem Wax Stripper is classified as a corrosive mixture under the old and new OSHA standards. The MSDS lists precautionary statements about the corrosivity of the product. The SDS lists precautionary statements about the corrosivity of the product, as well as, a corrosive pictogram (see example below).
Keep in mind that the SDS may look different from the MSDS but the product itself has not changed. Essential will be supplying you with same great products that you have come to know and trust over the years.
- To see an example of a new GHS SDS, click here.
- To see examples of Section 2 (from a GHS SDS) with highlighted hazard information, click here.
How will I get new SDSs for all of my products?
The distribution of the HCS GHS compliant Safety Data Sheets must be coordinated with the launch of the HCS GHS compliant labeled products. HCS GHS compliant Safety Data Sheets for all of our EI brand, Superbase, and RTU products made from our Superbase products, will be available on our web site starting January 2015. We will supply all of our private brand customers with HCS GHS compliant Safety Data Sheets for their private brand products starting January 2015. We are also developing independent and confidential web pages for our private brand customers, where they can access their private brand product Safety Data Sheets at any time.
What is a pictogram?
As of June 1, 2015, the Hazard Communication Standard (HCS) will require pictograms on labels to alert users of the chemical hazards to which they may be exposed. Each pictogram consists of a symbol on a white background framed within a red border and represents a distinct hazard(s). The pictogram on the label is determined by the chemical hazard classification. The pictograms OSHA has adopted improve worker safety and health, conform with the GHS, and are used worldwide.
While the GHS uses a total of nine pictograms, OSHA will only enforce the use of eight. The environmental pictogram is not mandatory but may be used to provide additional information. Workers may see the ninth symbol on a label because label preparers may choose to add the environment pictogram as supplementary information. Click here for descriptions of the nine pictograms showing the symbol for each pictogram, the written name for each pictogram, and the hazards associated with each of the pictograms. Most of the symbols are already used for transportation and many chemical users may be familiar with them.
Have the products changed?
Our products have NOT changed. They are the same trusted products you have been purchasing from us and have been used domestically and internationally for years. The pictograms now included on labels and SDSs are just pictorial representations of the OSHA defined hazards of the products that had previously been conveyed using only caution statements.
For examples of typical pictograms you may see for various product categories, click here.
- Name, Address and Telephone Number
- Product Identifier
- Signal Word
- Hazard Statement(s)
- Precautionary Statement(s)
To develop labels under the revised HCS, manufacturers must first identify and classify the chemical hazard(s). After classifying the hazardous chemicals the manufacturer then determines the appropriate pictograms, signal words, and hazard and precautionary statement(s). This information is displayed in Section 2 of the Safety Data Sheet under Label Elements, as well as, on the product label.
Because OSHA has revised the criteria by which it defines health and physical hazards, some products may have hazard classifications that they did not have previously.
To see comparisons between old and new (GHS) product labels, click here.
When will I see/get new packaging?
We will be placing HCS GHS compliant labeled products into production starting January 2015. This will give our customers ample time to meet the HCS GHS requirements well within the deadline of June 1, 2015.
What should I tell my customers if they’re concerned?
Please feel free to share this document with your customers since they will probably have the same questions you do and we are addressing here. We also have a lot of good information on our web site that you can use to help your customers understand the new HCS GHS requirements. Another good place to get information is on the OSHA web site: www.osha.gov/dsg/hazcom. They have Briefs, Fact Sheets and Quick Cards with helpful information about the new HCS GHS requirements.
Why haven’t I seen this from my other suppliers?
The implementation deadline for OSHA 2012 is June 1, 2015, but anyone that wishes can comply with the new GHS requirements before that date. Some manufactures, like Essential Industries, are offering the new HCS GHS compliant product labeling and Safety Data Sheets sooner than required in order to help our customers in their transition to meet these requirements.
How long do I have to get rid of old inventory (non-compliant)?
Distributors may ship products labeled by manufacturers under the old system until December 1, 2015. After this date only products with labels that are compliant with the new OSHA 2012 GHS requirements may be shipped.
What do I do if I still have non-compliant inventory after December 1, 2015?
We strongly advise that you adjust your product ordering and inventory so that you can deplete all existing stock of product with OSHA 1994 compliant labeling. We will have product with HCS GHS compliant labeling available for purchase no later than June 1, 2015. This will give you ample time to deplete old/current stock in order to meet the December 1, 2015 deadline.
When does everyone have to comply with the new OSHA HCS GHS regulations?
Essential Industries started working on the transition to the new HCS GHS requirements the last quarter of 2013. We will ensure that all of the labeling and safety data sheets for all of our products and for our customers will be compliant with the new HCS GHS requirements well within the implementation date of June 1, 2015. The effective dates for the various components of the new OSHA HCS GHS are listed below.
Effective Completion Dates
December 1, 2013
Employers – Train employees on the new label elements and SDS format. Training Timeline
June 1, 2015*
Chemical manufacturers, importers, distributors and employers – Comply with all modified provisions of this final rule, except:
Distributors may ship products labeled by manufacturers under the old system until December 1, 2015.
*This date coincides with the European Union implementation date for classification of mixtures.
June 1, 2016
Employers – Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.
All chemical manufacturers, importers, distributors and employers – Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both.