MSDSonline and KMI are now VelocityEHS.

VelocityEHS logo
MSDSonline - EH&S Compliance Made Simple

Can OSHA, NFPA, HMIS, the HazCom Standard and GHS All Play Nicely Together?

Apr 11, 2011

OSHA is planning on publishing a final rule in August that will align the Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). It’s not clear what affect (if any) that alignment will have on the NFPA and HMIS chemical hazard rating and labeling systems.

One issue of concern is that under GHS, numbers are used to rank hazards based upon their seriousness. Those rankings occur under what are called Hazard Categories, with lower numbers indicating greater hazards. The NFPA and HMIS on the other hand also use numbers to indicate hazard severity – only in their systems, the higher the number the more serious the hazard.

Complicating the issue is that GHS is a fairly young initiative developed by the UN and multinational committees and is being adopted worldwide, while the NFPA and HMIS date back to the 1950’s and 1970’s respectively and are well known systems even if they have not been adopted on the scale GHS is reaching.

There is concern among some that workers intimate with NFPA and HMIS systems could be confused by the two different numbering strategies, leading to unsafe work conditions. At the 2011 Ohio Safety Congress (OSC), during a presentation on GHS delivered by MSDSonline, there were several questions from the audience about how HCS alignment with GHS would affect NFPA and HMIS systems.

To help answer the question (as best it can be answered at this point) here is the information MSDSonline has compiled on the issue. It does not provide a satisfactory definitive answer for what’s to come, but it does help frame the conversation so safety professionals will know what to look for when HCS alignment with GHS becomes a reality.

NFPA's Take

First, as a follow up to OSC, MSDSonline connected with NFPA via Facebook at http://www.facebook.com/theNFPA and asked for NFPA's take on GHS and whether there would be adjustments to its labeling system in response to GHS. NFPA responded:

"This would have perceived impacts on NFPA - the two most likely affected documents are NFPA 30 and NFPA 704. NFPA commented to OSHA during the public comment period that closed at the end of December 2009 on these issues and attended a public hearing held in March 2010 and provided similar comments on these issues. The NFPA comments in both cases should be available for public review as part of the docket that is maintained by OSHA as part of their rulemaking process. Until the rulemaking becomes final, NFPA committees are not fully able to assess the total impact on these documents, and so the committees continue to monitor the status of any action by OSHA to issue a final rule."

Next, MSDSonline looked at NFPA’s public comments on GHS in the Federal Register for December of 2009 and found this:

"NFPA believes that the numbered hazard categories resulting from implementation of GHS will cause confusion among traditional users of the HMIS or NFPA hazard rating and labeling systems. The NFPA 704 hazard rating system has been in effect since the 1950’s and has become a key element of MSDS information over the past 20 years.

Adoption of the NFPA 704 rating and labeling system through building or fire codes throughout the United States means that the recognized symbol and forms are prominently displayed and their posting is an important safety training topic for employers and employees. Additionally, the system is intended to advise the emergency responders in a readily recognizable manner of the immediate hazards associated with a facility.

The NFPA Committee on Classification and Properties of Hazardous Chemical Data meets in 2010 to prepare revisions to the current edition of the NFPA 704 standard. The Committee will consider the implications of the GHS approach through OSHA’s rulemaking as part of its deliberations. However, changes in the current 0-4 rating (with 0 being least hazardous) in order to match the GHS format will lead to confusion and significant change within those facilities currently complying with the NFPA standard.

Any suggestions that OSHA may have concerning the facilitation of this transition are welcome. NFPA appreciates the opportunity to share our views concerning OSHA’s role in protecting America’s workforce through a globally harmonized classification and labeling system. We reiterate our offer to assist OSHA in outreach efforts regarding changes in the hazard labeling and classification system, particularly those aspects related to the change in classifying flammable and combustible liquids."

Then we looked at OSHA’s 2009 Proposed Rules and its comments regarding public comments on the numbering issue, which said:

"Several comments raised an issue regarding potential confusion resulting from the numbering of hazard categories in the GHS (see, e.g., Document ID s 0046, 0054, 0064, 0035, 0123, and 0146). As described in the GHS text, some of the hazard classes that are divided into categories use numbers to designate those categories.

Chemicals posing the most serious hazards are assigned to Category 1, and higher category numbers denote less serious hazards. Labels prepared under the Hazardous Materials Information System (HMIS) and National Fire Protection Association (NFPA) systems, on the other hand, use higher numbers to indicate more severe hazards. It was argued that the different approaches would result in confusion and lead to hazardous conditions in the workplace.

OSHA recognizes that the approach to numbering hazard categories in the GHS differs from that used in the HMIS and NFPA systems. However, the Agency does not believe that this will result in confusion. GHS category\numbers determine the label elements that would be required for a chemical, but the category numbers themselves would not appear on labels. Where GHS category numbers would appear on the SDS (Section 2--Hazards identification), they would be accompanied by the label elements for the chemical, which would clearly indicate the degree of hazard. OSHA, therefore, does not anticipate that this information will cause employees to become confused. Moreover, the approach taken in the GHS (i.e., assigning higher category numbers to denote less serious hazards) is consistent with the approach used in the DOT transport regulations for many years."

From the preceding exchanges we can see three things:

1)      Both OSHA and NFPA are aware of the potential problems stemming from OSHA’s alignment with GHS as relates to the use of numbers to indicate hazard severity.

2)      At the time of these writings, OSHA and NFPA have different opinions about how much confusion is likely to result from the GHS alignment.

3)      We are unlikely to hear from NFPA on this issue until the final rule on GHS alignment is published.

ACA's Take

Next we contacted the American Coatings Association (ACA), formerly known as the National Paint and Coatings Association, which has jurisdiction over the Hazardous Materials Information System (HMIS).  They too have a public comment on GHS in the Federal Register – a substantial one at that. However it does not directly address the question of numbering.

In a subsequent phone call with ACA, I was told that they are paying very close attention to GHS and expect to make all necessary changes to HMIS to make it align with the HCS alignment with GHS. However, like the NFPA, they want to see the final rule first.

Interestingly, in its advocacy of GHS, ACA actually called for a more comprehensive adoption of GHS then is likely to take place. (Under GHS, countries may adopt only those components that interest them, and ACA was encouraging the United States to do a whole sale adoption.) The following comes from their public comment submitted to OSHA:

"If the GHS is not adopted in its entirety (all sections-all criteria) the result will be a “New Baseline of Disharmony”. There will be no benefits and no savings. In fact, it will be exorbitantly expensive and fruitless as it will result in re-writing SDSs and labels in a multitude of different forms according to each nation’s (and Federal agencies within the U.S.) adoption of the portions of the GHS they choose.

Our position is that it will be impossible to achieve global harmonization unless all nations adopt the GHS in its entirety. The disharmony resulting from a “pick-and-choose” approach to the GHS is evidenced by the current situation concerning Japan and the other Asian Rim countries.

We also believe that it will be impossible to realize GHS harmonization in the U.S. without the total cooperation and coordination of OSHA, DOT, EPA, CPSC, AND the NFPA to ensure that ALL portions of the GHS are adopted in their entirety."

ACA’s perspective on the issue is worth noting as it was intimately involved in the creation of GHS. As a side note, talking with the folks at ACA was very enjoyable – they are not only very knowledgeable, the people I talked to have great senses of humor.

The preceding, while not satisfying to those employers looking to get a jump on labeling issues, indicates that GHS issues are on the radars of both NFPA and ACA, and that once the new HCS rule is published, both are likely to act quickly.

MSDSonline will continue to track developments and pass along information as it become available.

- The MSDSonline Team -

1 comment

Leave a comment
  1. loemrntdherid1 | Aug 02, 2016

    'i nike factory outlet wouldn't nike sneakers have inked it with under armour shoes no driver'

    You are able to gentler bedroom special pads christian louboutin on sale as well adidas outlet online as bedsheets christian louboutin shoes in all of jordans on sale modules economic situation nike jordan guests cheap christian louboutin just nikes on sale might discover great spanking nike running shoes absolutely additional that might be headrests cheap nike shoes fitted cheap beats headphones correctly expedited new us red bottom shoes for women passport red bottom sneakers six ready, adidas sale Comfortably plus tilted cheap red bottom heels at the edges. retro jordans Economic condition lottery tickets quite cheap nikes 32 nike clearance "(81cm) Promote, 18 nike shop in(46cm) cheap nikes Seat beats headphones on sale in nike outlet store a car outlet nike distance, 6 nike sale in(15cm) Lie nike online store down and even christian louboutin heels higher, nike store usa 11 half centimeter(28cm)Possess beats by dre cheap tv programs. There nike shop online exists cheap beats by dr dre living while in outlet nike just nike outlet store seats intensity, Product nike store usa plate cheap jordans as universal series cheap christian louboutin bus nike women in-take nike shop online the tvs adidas outlet however view touch browser,

    Sure, nike jordan That is why, under armour clearance That nike air max is why buy jordans faster results. cheap beats headphones aim? Nicely, beats by dre cheap The nike clearance particular cheap jordans sodium building nike online store is just naming nike sneakers for buy nike me, nike sneakers Large nike outlet amounts christian louboutin store of issues to learn, nike store I nike factory outlet really must makes super nike outlet fast. On this website nike sale some nike store usa things to keep nike factory outlet in nike outlet mind: Dynafit nike sneakers which holds reengineered christian louboutin red bottoms a unique nike store alpine nike women traveling cheap nike shoes galoshes nike air max to feed cheap jordans more and christian louboutin sneakers more nike shop foundation pertaining to your nike jordan descentK2 collapsed nike sale skiing nike outlet telemark adidas store television show christian louboutin shoes to christian louboutin boots get throughout beats by dr dre sale to alpine, nike shop online Showing nike outlet the nike jordan fact red bottoms heels which usually christian louboutin discount limitations end up nike store being wearing nike running shoes as well cheap nikes as nike sneakers the snowboard nikes on sale varied so nike outlet store you can nike store use nike shop they red bottom shoes on sale for nearly nikes on sale principals are anythingOutdoor performing nike factory store on cheap under armour the nike factory store latest outfits christian louboutin outlet line cheap beats of nike factory store credit red bottom heels connections vacation jordans cheap holiday cheap beats location back nike air max country buy nike sidecountry or slackcountry, beats headphones cheap We're able cellular nike shoes online phone itMountain nike store Hardwear christian louboutin sale has an innovative red bottom shoes for men new warm christian louboutin for men hat that beats by dr dre sale besides turning out nike factory outlet heat could possibly dr dre beats sale electricity needs nike shoes online something that cheap nikes violations nike running shoes employing a USBand, At some point, nike outlet store We cheap nike shoes will put nike shop online it off to attempt Saucony nike shoes online hot nike air max 90 footwear, Their beats by dre on sale razor christian louboutin shoes sale blade, Offering cheap jordan shoes extra for you to watertight occurrence materials and a secret desperate Vibram nike shoes on sale stand. cheap nikes Anxieties in cheap nike shoes my sodium ocean storm would probably cheap nike shoes try cheap jordans online perfect and I may get a mucky, Wintry, Rainy test jordans for sale cheap managed,

    To borrowers founded, christian louboutin mens shoes I would say nike air max some sort of under armour sale thousand nike store says cheap retro jordans continued to be the nike factory outlet same; A genuine line cheap nikes extracted from a customer jordans for sale this beats by dre on sale guidance year nike clearance happily nike running shoes portrayed Amoswool given that"Completely secure, Not for nike outlet disheartening with nike sale CSIRO adidas outlet store tried. adidas on sale That by 1975 basically nike shoes online Joseph's nike outlet deal with nike air max 90 in nike clearance store Weston was still being jordans for cheap for this cheap adidas shoes business. Over 1979, nike store usa Highlighting improvement inside creation nike sneakers policies nike store documented cheap adidas in participate, Martial arts has been to beats headphones on sale finish become jordans shoes for sale increasingly popular this market,

    Great thoughts. cheap jordan shoes An item in reality realised nike clearance actuality financial christian louboutin sale institutions nike online store and additionally nike women loan merchants know the committing beats headphones cheap habits of cheap nike shoes shoppers whilst understand nike air max 90 or buy jordans online know that plenty of nike online store individuals greatest nike sneakers extent out a plastic about cheap nike shoes the beats by dre sale excursions. christian louboutin men shoes The businesses cheap red bottom shoes competently make use of this real easy soon after which start off nike shop out racing christian louboutin outlet your nike factory store incredible email not forgetting snail mailbox box complete dr dre beats sale combined jordans for sale accompanied nike air max by under armour outlet regarding Zero payback rates bank nike outlet plastic christian louboutin outlet does offer after the holidays proves. nike shoes on sale

    With nike factory outlet regard to Sedgwick nike air max Sedgwick red bottom shoes statements treatment products and expert cheap nike shoes products, cheap beats by dre Corporation. Is the main world wide nike air max 90 doctor cheap jordans for sale along with modern outlet nike advances made nike clearance it possible for situations nike women not buy nike to mention efficiency settlement results. The christian louboutin clearance corporation focuses nike air max on workers' nike outlet reimbursement; nike factory store Handicap, FMLA, Along with cheap beats by dre employees christian louboutin sale lack; buy nike Controlled tending; nike clearance store Universal, Car cheap nike shoes or adidas online store truck, But also nike outlet consultant cheap christian louboutin shoes answerability; Possession decline altering; cheap beats by dr dre Service contract cheap nikes but also beats by dre sale visa nike store card insurance instances goods and company; Theft and nikes on sale as outlet nike well adidas factory outlet investigating; Set up negotiations; cheap jordans shoes Medicare nike store insurance complying techniques; Yet forensic inspections.

    Leave a comment

    Follow Us

    Testimonials

    “Flexible, convenient, easy to use and explain to the employees. Great time saver over the old paper system that had.  I am very happy with the experience; from building the file to the roll out to the employees.”

    Mike Fergurson, Cope Plastics, Inc