Are You Ready for the GHS Revision 7 Changes?
OSHA recently indicated its intent to update the current HazCom 2012 Standard – which is aligned with GHS Revision 3 – to align it with the United Nation’s most recent edition, GHS Revision 7.
The UN allows nations and agencies the flexibility to pick and choose which elements of the GHS to adopt. While specifics around the updates won’t be known until the agency publishes a notice of proposed rulemaking (NPRM) in February 2019, we can expect its alignment with Revision 7 will happen in a way that continues to address its specific needs and interests, and works within the scope of its regulatory oversight for hazardous chemicals in the U.S.
A number of noteworthy modifications appear in Revision 7 as compared to its preceding edition – Revision 6 – that safety professionals should be aware of, since OSHA may choose to adopt some or all of these changes when they align the HazCom Standard with the newest version of the GHS.
Following, we take a look at what’s new and provide advice on how to prepare.
GHS Revision 7: What’s New?
- Clarified definitions for some health hazard classes. The definitions of skin corrosion, skin irritation, serious eye damage, eye irritation, dermal corrosion, dermal irritation, respiratory sensitizer, specific target organ toxicity, reproductive toxicity, and carcinogenicity are all slightly updated for additional clarity.
- Revised criteria for that categorization of flammable gases. Prior to Revision 7, there was ambiguity regarding how to apply categories provided in the flammable gas chapter. To eradicate some of this confusion, both pyrophoric gases and chemically unstable gases now meet the classification criteria of flammable gases category 1A. Also, two hazard statements are now assigned to pyrophoric gases and chemically unstable gases category 1A/1B.
- More rationalized precautionary statements in Annex 3. A new precautionary statement P503 now exists for some explosives, instructing users to refer to the chemical manufacturer/supplier for information on its disposal, recovery, or recycling. Also, Section 3.2 now reads, “Flexibility in the use of precautionary statements with the first heading under that being Omission of precautionary statements where the advices is not relevant.”
Other Important GHS Revision Changes
Every two years, the UN releases an updated version of the GHS. This means that there are currently three editions published following the version OSHA aligned the HazCom Standard to (GHS Revision 3) and this latest version (GHS Revision 7) that each have had their own notable modifications as part of the overall GHS evolution. Most importantly, they provide perspective on the types of changes the UN makes on its two year update intervals, as well as insight into the cumulative updates incorporated into the latest edition — GHS Revision 7. You should be familiar with these changes, since they are parts of the evolving standard that OSHA may consider incorporating when they revise the HazCom Standard next.
A sampling of updates from Revisions 4 through 6, include:
- New hazard categories for chemically unstable gases and non-flammable aerosols (Rev. 4)
- Further clarification of criteria to avoid differences in the interpretation of precautionary statements (Rev. 4)
- Addition of a new test method for oxidizing solids (Rev. 5)
- Clarification of hazard classification criteria for skin corrosion/irritation, severe eye damage/irritation, and aerosols (Rev. 5)
- Revised/simplified classification & labelling summary tables (Rev. 5)
- New codification system for hazard pictograms (Rev. 5)
- New hazard class for desensitized explosives (Rev. 6)
- New hazard category for pyrophoric gases (Rev. 6)
- Provisions intended to clarify the criteria for the hazard classes of explosives, specific target organ toxicity following single exposure, aspiration hazard and hazardous to the aquatic environment (Rev. 6)
- Additional information to be included in Section 9 of safety data sheets (SDSs) (Rev. 6)
- Revised and further rationalized precautionary statements (Revs. 4, 5 & 6)
- New example in Annex 7 addressing labelling of small packages (Rev. 6)
How You Can Prepare
So what does all this mean for you? HazCom covered businesses? While it’s important that you’re aware of OSHA’s Revision 7 alignment plans, all covered businesses must continue to adhere to the current HazCom 2012, GHS Revision 3 aligned requirements.
For businesses covered by HazCom, now is a good time to take note of what could change based on the evolution of GHS and refocus your understanding of current obligations under the GHS-aligned HazCom 2012 Standard. A main issue uncovered during the initial GHS rollout was that many employers were not compliant with the pre-GHS HazCom requirements, which made it harder for them to adopt the changes. Taking steps now that help ensure your facility is fully HazCom compliant will make introducing the next round of changes easier.
Chemical manufacturers, importers, distributors and employers of facilities where hazardous materials are used and stored should review their SDS libraries now to ensure they have the most updated information available for employees to access, verify shipped labels and workplace container labels comply with GHS, update Written HazCom Plans, and make sure that all employees have been trained to comprehend the current GHS changes. Employers, in particular, should be prepared to manage against another phased-in deadline and the consequential SDS library churn resulting from updated documents arriving with any initial shipments from suppliers or with first shipments following significant changes made to the documents.
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