What is GHS?
GHS stands for the Globally Harmonized System of Classification and Labelling of Chemicals. GHS was developed by
the United Nations as a way to bring into agreement the chemical regulations and standards of different countries. In
short, it is an international attempt to get all countries on the same page.
Born out of the United Nations ‘Earth Summit’ of 1992, over 65 countries have already adopted, or are in the process of
adopting, GHS, including the United States and Canada. GHS is primarily concerned with the classification of chemicals
and the communication of hazards related to those chemicals to users of the products downstream via warning labels and
safety data sheets.
GHS is not a law unto itself; rather it is a system with components countries can adopt into their own systems. In
other words, HCS remains the law in the U.S., and WHMIS will continue to be the law in Canada; however, alignment with
GHS changes both HCS and WHMIS in ways that have significant consequences for chemical manufacturers and employers in
both countries.
GHS adoption affects everyone in the chemical lifecycle, with special responsibilities for chemical manufacturers and
employers that handle, use and store hazardous materials. Chemical manufacturers must reclassify their chemicals using
GHSs standardized classification criteria as well as produce GHS compliant labels and safety data sheets (SDSs). Employers
must train employees on GHS (how to understand new labels and data sheets), manage the influx of new SDSs which will
include replacing their entire MSDS library, and be ready to produce GHS compliant workplace labels. Also, be sure to check out our GHS / HazCom 2012 Adoption Timeline Checklist. Print it out and hang it up to track compliance your progress.
Learn more at the GHS Answer Center.
Existing fines and penalties for non-compliance with HCS and WHMIS extend to GHS alignment with these same standards.
In the United States, that means that HCS violations, which already rank #3 on OSHA’s Top Ten Violations List, could
see even more action. And WHMIS penalties of up to $1 million in fines and two years in prison will remain a serious
consideration for anyone with obligations under Canada’s hazard communication standard.
Unfortunately, complying with GHS in both the United States and Canada is not a straightforward affair. For instance,
in the U.S., OSHA is allowing two years for employee training on GHS, and three years for full compliance, during
which the agency has signaled it will accept adherence to either the old HCS or the revised HCS. Yet, if circumstances
arise from GHS adoption in a particular workplace that affects employee safety, (e.g. trouble reading GHS labels or
understanding pictograms) the employer would be expected to deal with it in the moment, regardless of how much time
they had left to train and be in full compliance of GHS according to the standard.
Ultimately, employers have a responsibility to keep their employees safe. For that reason, and to ensure full
compliance, MSDSonline recommends companies stay in front of GHS adoption by aligning their policies and health and
safety management with GHS principles at the earliest opportunity.
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GHS Alignment with HCS
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GHS Compliant Labels
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GHS Compliant SDSs
Revision of the Hazard Communication Standard to align with GHS affects over 40 million workers in 5 million workplaces.
Interestingly, the impetus for developing and adopting GHS was written into the preamble of the original HCS in 1983.
It recommended seeking the creation of a global approach to hazard communication to reduce risks from confusing differences
in international standards as well as ease the cost and hassle of international trade.
Revisions to OSHA’s HCS to align with GHS result in two major changes. First, unlike HCS, which stops at simply classifying
hazards, GHS hazard classes are subdivided into “hazard categories” so that chemical manufacturers must identify both the
hazardous effects of their chemicals as well as their degrees of severity. The second key area of change under GHS is to
labels and safety data sheets.
GHS safety labels have six standardized elements:
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Product Identifier Must match product identifier on safety data sheet
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Manufacturer Contact Information Including name, phone number, and address
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Hazard Pictograms New label elements that may require color printers
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Signal Word Either DANGER or WARNING depending upon hazard severity
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Hazard Statements Standardized sentences that describes the level of the hazards
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Precautionary Statements Steps employees can take to protect themselves
MSDSs Get a New Look
Under GHS alignment, safety data sheets remain the backbone of HCS compliance. They do, however, get a name and
formatting change. GHS drops the M from MSDS and calls them SDSs. More importantly, SDSs have a standardized 16
section format with a required ordering of sections. It is essentially the ANSI Standard for MSDSs with a few
adjustments.
Learn more about GHS and OSHA’s revision of HCS to align with GHS by visiting the GHS Answer Center on
MSDSonline’s Environmental, Health and Safety Blog.
With GHS alignment, each container of a classified hazardous chemical is to be labeled, tagged, or marked with
the following elements:
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Product or chemical identifier clearly indicated on the label that matches the product or chemical identifier on the SDS.
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Contact information for the product supplier, including the company name, address and telephone number.
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Hazard Pictograms. Pictograms have a black symbol on a white background with a red diamond frame. (See examples below)
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.
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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.
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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.
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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.
Keep in mind these requirements are for classified hazards. For unclassified hazards, the shipping label should include the
product name, supplier contact information, and as supplemental information, a description of the hazards and appropriate
precautionary measures. WHMIS has additional label elements that may need to be included, such as an on label reference to
the corresponding SDS.
Workplace Labelling
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 will also 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.
Remember, labels must not be defaced or removed unless immediately replaced with new labels.
MSDSs, as was mentioned earlier, are redefined as SDSs under GHS and remain the backbone of HCS and WHMIS compliance. 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:
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Identification
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Hazard(s) Identification
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Composition/Ingredient Information
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First-Aid Measures
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Fire-Fighting Measures
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Accidental Release Measures
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Handling and Storage
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Exposure Control/Personal Protection
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Physical & Chemical Properties
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Stability & Reactivity
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Toxicological Information
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Ecological Information
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Disposal Considerations
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Transport Information
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Regulatory Information
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Other Information
To be GHS compliant, an SDS needs all 16 sections; however, OSHA will not be enforcing sections 12-15, which fall outside
their jurisdiction. With GHS alignment, employers should prepare for a large influx of new SDSs to occur within a short
time frame.