Plastic manufacturers should pay attention to these developments and plan accordingly since HCS violations rank among the top five most cited OSHA standards for the plastics industry, and GHS alignment will result in additional compliance responsibilities under HCS.

What is GHS?
GHS stands for the Globally Harmonized System of Classification and Labeling of Chemicals. It was born out of the 1992 United Nations Conference on Environment and Development, a.k.a. the Earth Summit, and is intended to create a global approach to the hazard classifications of chemicals and the communication of chemical hazards via labels and safety data sheets. (Under GHS, material safety data sheets (MSDS) are called safety data sheets (SDS), in addition to more substantial changes we’ll discuss later in this article.)

GHS is not a global law; it’s a system for classifying chemical hazards and communicating those hazards to the people who may be exposed to those chemicals. It uses a building block approach, which means countries adopting GHS may select only those aspects of the system it wishes to incorporate into its own standards. Furthermore, countries that adopt GHS also are responsible for its enforcement.

The United States played a key role in the development of GHS, and OSHA’s HCS was one of four major chemical hazard standards that served as the basis for the global system. To date, 67 countries have adopted or are in the process of adopting GHS, and adoption on a wide scale is expected to enhance protection of workers and the environment while reducing costs and regulatory burdens related to international chemical trade.

What Will Happen to HCS?
To understand how HCS will be modified, let’s quickly review HCS in its current form. Adopted in 1983 for the manufacturing industry, HCS was expanded in 1987 to cover all industries. Today, it covers 40 million workers in over 5 million workplaces. Its stated purpose is “to ensure that the hazards of all chemicals produced or imported are evaluated and details regarding their hazards are transmitted to employers and employees.”

OSHA estimates that there are over 880,000 hazardous chemicals covered under HCS and everyone in the lifecycle of those chemicals probably has at least some responsibilities. Chemical manufacturers are required to evaluate the chemicals and products they produce to identify potential hazards, and then provide information about those hazards via warning labels and MSDSs to the importers, distributors and end-users that receive their products. Similarly, importers and distributors must supply labels and MSDSs to their customers.

End-users and employers must take measures to keep employees who are exposed to hazardous chemicals safe by preparing a written hazard communication program, maintaining a hazardous chemical inventory, ensuring that on-site containers are properly labeled, providing employees access to MSDSs for all hazardous chemicals and training employees on the safe handling of chemicals and how to properly read MSDSs and warning labels.

Again, employer responsibility under HCS has five key components.

• Written plan
• Chemical inventory
• Labels and warnings
• Employee training
• MSDS management

Major Changes to HCS
The two biggest changes GHS brings to HCS are to the hazard classification criteria and hazard communication. GHS hazard definitions are criteria-based and each type of hazard covered is considered a “hazard class” – such as acute toxicity and carcinogenicity – and unlike in the HCS, most of these hazard classes also are subdivided into “hazard categories” to reflect the degree of severity of the effect. This is the concept of “classification.”

With GHS alignment, chemical manufacturers must identify both the hazardous effect (e.g., carcinogenicity) and how severe that effect might be (e.g., Category 1 or 2).

GHS breaks hazards down into three classes: 1) health hazards; 2) physical hazards and 3) environmental hazards. However, the GHS-modified HCS will only cover the first two classes, as environmental hazards are outside of OSHA’s regulatory domain. The EPA will cover environmental hazards when it aligns with the GHS.

Thanks to the reclassification of chemicals and changes to the SDS format, chemical manufacturers and some importers/distributers will likely need to produce new labels and SDSs that incorporate those changes.

Biggest Impact on Plastic Manufacturers
The second key area of change under GHS is to labels and SDSs, and these changes will have the biggest effect on plastic manufacturers.

To start, while HCS takes a simple performance-oriented approach to labels (meaning OSHA explains the results it wants, but not how to achieve it), GHS takes a more detailed explanatory approach, providing specific how-to provisions for labels. With GHS alignment, each container of a classified hazardous chemical is to be labeled, tagged or marked with the following elements:

1. Product or chemical identifier clearly indicated at the top of the label that matches the SDS.

2. Contact information for the product supplier, including the company name, address and telephone number.

3. Hazard Pictograms. Transport pictograms will have the same background and symbol colors currently used (since DOT has already aligned with GHS). For all other sectors, pictograms will have a black symbol on a white background with a red diamond frame. It’s a far simpler system compared to the current 38 shapes, colors and symbols being used in just North America today.

   Note: GHS allows for a black frame to be used for shipments within a single country. OSHA, however, is proposing that a red frame be used regardless of whether the shipment is traveling inside or outside of the country.

4. The signal word should be clearly marked at the top of the label beneath the product identifier. GHS permits the use of only two signal words (and only one at a time) – DANGER or WARNING – to emphasize the hazard and distinguish between hazard levels.

5. A hazard statement that describes the level of hazard should appear under the signal word.

   Signal words, hazard statements and pictograms have all been harmonized and assigned to each hazard class and category in GHS. Once a chemical has been classified, the relevant harmonized information can be found in HCS under the new Appendix C.

6. Lastly, the label should include the appropriate precautionary information. Since OSHA does not currently require precautionary statements, this is a key change to HCS. As of now, precautionary statements in the GHS are not harmonized. The intent is to harmonize precautionary statements in the future; until that time, OSHA is expected to mandate the use of the GHS examples, which it anticipates will end up being the harmonized statements.

Workplace Labeling
GHS allows authorities like OSHA to determine what types of workplace labels will be required, and OSHA has signaled it will continue to give employers flexibility in this area by allowing them to choose “to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule, or with label alternatives that meet the requirements for the standard.”

OSHA also will continue to give employers alternatives to affixing labels to stationary containers and portable containers used to transfer materials from other labeled containers, so long as the portable containers remain under the control of the employee who performs the transfer and are used within a workshift.

Also not changing are the requirements that labels be presented in English – though additional languages are permitted as needed – and that labels must not be defaced or removed unless immediately replaced with new labels.

Safety Data Sheets
MSDSs, as was mentioned earlier, are redefined as SDSs under GHS and remain the backbone of HCS compliance. The alignment standardizes the format and quality of information provided on the SDS. Under GHS, SDSs are presented in a 16-section format with a required ordering of sections. It is essentially the ANSI Standard for SDSs, with a few minor tweaks. The sections, in order, are as follows:

1. Identification
2. Hazard(s) Identification
3. Composition/Ingredient Information
4. First-Aid Measures
5. Fire-Fighting Measures
6. Accidental Release Measures
7. Handling and Storage
8. Exposure Control/Personal Protection
9. Physical and Chemical Properties
10. Stability and Reactivity
11. Toxicological Information
12. Ecological Information
13. Disposal Considerations
14. Transport Information
15. Regulatory Information
16. Other Information

Training
Under OSHA’s HCS revision, employers will have two years from the effective date of the final rule to train employees on the new rules. Training should address changes to a company’s written hazard communication plan, changes to labels and changes to SDSs.

How to Prepare for GHS
Chemical manufacturers are responsible for much of the work that needs to be done in order to make the entire system GHS- compliant and many (if not most) have already begun the work of transitioning to the new standard. Many employers, on the other hand, have only a vague notion of what it is coming and how to prepare. For that reason, we will focus on the steps employers can take to make the transition to a revised HCS a smooth one.

• Have an HCS plan, maintain a checklist of key plan components and review it regularly.
• Inventory your on-site chemicals.
• Make sure you have a complete and up-to-date library of SDSs.
• Stay current with OSHA on the federal, state and local levels.
• Keep an eye on GHS key dates and how they impact your plan.
• Prepare yourself for the eventual SDS churn, keeping your archiving needs a priority.
• If you’re still using paper, consider transitioning to an electronic system.
• Make sure your secondary labeling system is GHS-compliant.
• Start developing a training plan for your employees. Conclusion
  OSHA has targeted August 2011 for the publishing of the final rule to align HCS with GHS. At that time, OSHA also will announce the effective date for the final rule. Employers will have to train all employees on GHS (reading labels and SDSs, etc.,) within two years of the effective date and will have to be in full compliance within three years.

  OSHA understands that during the transition, some employers will be following the old HCS and some the revised HCS; to that end, the agency will continue to enforce compliance, but will accept adherence to either the new or the old standard.

  To learn more, visit our GHS Answer Center at http://blog.msdsonline.com and check out OSHA’s website at http://www.osha.gov/dsg/hazcom/global.html. August is right around the corner; by acting now, you should have plenty of time to prepare for the coming changes.

  Glenn D. Trout is the president of MSDSonline, a provider of on-demand compliance solutions for tracking and managing hazardous chemicals and material safety data sheets (MSDSs) and other critical environmental, health and safety (EH&S) information. Find MSDSOnline at www.MSDSonline.com or call 888.362.2007.