OSHA Holds Public Meeting to Discuss Changes to GHS, HazCom

On June 12, 2018 OSHA hosted a public meeting to accept stakeholder comments concerning potential changes to the United Nations Globally Harmonized System of Classification and Labeling of Chemicals, or GHS. OSHA intends to represent these stakeholder comments before the international community during the forthcoming 35th Session of UN Subcommittee on the GHS that is currently scheduled for July 4-6, 2018 in Geneva, Switzerland.

A number of important and emerging hazard communication topics were discussed during the meeting, and VelocityEHS was on hand to provide you with an overview of the meeting’s activities, as well as insights into what lies ahead for U.S. businesses affected by OSHA’s HazCom Standard.

The following is a brief summary of topics discussed during yesterday’s meeting:

Explosives

Several proposed revisions to the GHS regarding explosive materials were addressed, including:

  • Amendments to Sections 1 and 10 of the 6th revised edition of the Manual of Tests and Criteria containing changes to the criteria for classification of explosive hazards
  • Amendments to the existing explosive hazard classification criteria which add a layer of differentiation that is independent of the substance’s transport packaging or configuration

Chemicals under Pressure (Aerosols, Gasses & Liquids)

OSHA also addressed the differentiation of hazards for chemicals under pressure, including aerosols, gasses and liquids. Potential changes include:

  • A proposal to rename and amend chapter 2.3 of the GHS as “Aerosols and Chemicals Under Pressure,” and to further distinguish the requirements for aerosols and chemicals under pressure in separate sections.
  • The creation of new, separate hazard categories and label elements for aerosols, gasses under pressure and liquids under pressure.

Precautionary Pictograms

For some time, the UN has been considering the addition of a new precautionary GHS pictogram to represent the precautionary statement, “Keep out of Reach of Children.” The UN working group has identified two existing pictograms as viable models for the proposed GHS precautionary pictogram. The full working paper can be viewed here.

Hazard Categories

Several working papers discussed during the OSHA public meeting proposed changes to GHS hazard categories under the current revision of GHS (Revision 7). These included:

  • Revised allocation of precautionary statements for serious eye damage/eye irritation hazards
  • Revised allocation of precautionary statements for skin corrosion

Precautionary Statements

For the 2017-2018 biennium, the UN working group on improving annexes 1, 2 and 3 of the GHS has been given the mandate “to develop proposals to rationalize and improve the comprehensibility of hazard and precautionary statements for users, while taking into account usability for labelling practitioners.” Under this mandate, the working group has prepared two working papers which were addressed during the OSHA public meeting:

  • Clarification of precautionary statements P201 for safer handling of chemicals classified as carcinogenic, mutagenic and toxic to reproduction (CMR), as well as precautionary statement P202 to improve safety when handling chemically unstable gasses.
  • Simplification of medical response precautionary statements (reducing the number of available statements from 6 to 4) and clarifying language to ensure appropriate medical response in the event of exposure

Labeling of Sets or Kits

Significant confusion still surrounds the best method(s) for communicating hazard information to users of small sets or kits containing hazardous chemicals, while also accommodating the concerns of chemical manufacturers and suppliers. The current working paper incorporates feedback received during the previous 34th Session of the UN Subcommittee on the GHS, and proposes slightly revised requirements. Despite incorporating feedback received during the previous session, the proposed requirements were still met with skepticism from meeting attendees.

Upcoming OSHA Regulatory Actions

During the public meeting, OSHA re-affirmed its intention to align its HazCom Standard with Revision 7 of the GHS, with Proposed Rulemaking tentatively scheduled for February, 2019. However, GHS Revision 8 is currently in development, and should be published sometime in June, 2019. While we can currently assume that OSHA will proceed with alignment to Revision 7 as planned, it’s important to consider the possibility of a delay in Proposed Rulemaking in order to incorporate elements of Revision 8 in any future update to the HazCom Standard.

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