GHS 101: History of GHS
GHS (as an idea) predates OSHA’s Hazard Communication Standard (HCS), which was first issued in 1983. Today, GHS is more than an idea, having been implemented or partially implemented in some 67 countries.
Much ground still needs to be covered for GHS to be fully realized as conceived back in 1992; nevertheless, as the following timeline demonstrates, the strength of the original idea has sustained the development of GHS through decades and with some recent successes, it appears to be gaining momentum.
- OSHA issues Hazard Communication Standard (HCS) covering the manufacturing industry.
- First HCS preamble recommends an internationally harmonized system: “The development of internationally agreed standards would make possible the broadest recognition of the identified hazards while avoiding the creation of technical barriers to trade and reducing the costs of dissemination of hazard information by elimination of duplicative requirements which could otherwise apply to a chemical in commerce.”
- HCS is expanded to include all industries where employees are potentially exposed to hazard chemicals.
- OSHA issues Request for Information (RFI) on international harmonization efforts and the work being done by International Labor Organization (ILO) on chemical safety at work.
- OSHA issues RFI on HCS, including the idea of standard SDS format. Majority of respondents support standardized SDSs and labels.
- United Nations holds U.N. Conference on Environment and Development (UNCED) in Rio de Janeiro, also known as the “Earth Summit.” UNCED issues mandate (supported by U.S.) calling for the development of a globally harmonized chemical classification and labeling system.
- The 1992 UNCED mandate reads: “A globally harmonized hazard classification and compatible labeling system, including material safety data sheets and easily understandable symbols, should be available, if feasible, by the year 2000.”
- Multinational coordinating group is established called the Inter-Organization Programme for the Sound Management of Chemicals Coordinating Group for the Harmonization of Chemical Classification Systems. OSHA serves as chair of this group.
Work is divided into three parts:
- Classification criteria for physical hazards – Developed by the United Nations Subcommittee of Experts on the Transport of Dangerous Goods/ International Labour Organization working group
- Classification criteria for health and environmental hazards – Developed by the Organization for Economic Cooperation and Development
- Hazard communication elements (including SDSs and labels) – Developed by the International Labour Organization
Four major existing programs serve as basis for GHS:
- 1. U.S. requirements for the workplace, consumers and pesticides.
- Canadian requirements for workplace, consumers and pesticides
- European Union directives for classification and labeling of substances and preparations
- United Nations recommendations on the Transport of Dangerous Goods
Key guiding principle of the harmonization work:
- Protections of the existing systems would not be reduced as a result of GHS
- Will be based on intrinsic properties (hazards) of chemicals
- All types of chemicals will be covered
- All systems will have to be changed
- Involvement of all stakeholders should be ensured
- Comprehensibility must be addressed
- OSHA, DOT, CPSC and EPA form Interagency Working Group on Harmonization to work in concert with the State Department to represent the United State’s interest in the GHS process.
- United Nations renames the UNCEDTG to the Committee of Experts on the Transport of Dangerous Goods and on the Globally Harmonized System of Classification and Labeling of Chemicals (UNCETDG/GHS).
- Two subcommittees are created for UNCETDG/GHS; one on transport, and one called the Sub-Committee on the Globally Harmonized System of Classification (UNSCEGHS).
- The UNSCEGHS is responsible for maintaining the GHS and promoting its implementation.
- At the World Summit on Sustainable Development (WSSD), countries are encouraged to adopt GHS by 2008.
- GHS formally adopted by the UNCETDG/GHS.
- GHS adoption is endorsed by the Economic and Social Council of the United Nations.
- First edition of the GHS is published.
- EPA’s Office of Pesticide Programs drafts White Paper on EPA’s initial thinking on GHS and how it might be applied to pesticide labels.
- OSHA adds the adoption of GHS and the modification of the HCS to its regulatory agenda.
- First revised edition of GHS is published and includes amendments adopted by Committee of Experts.
- OSHA publishes Advanced Notices of Proposed Rulemaking (ANPR) on GHS.
- Second revised edition of GHS is published.
- DOT adopts many aspects of GHS that directly deal with the transport sector, such as changes to the hazard classification criteria for toxic materials and flammable liquids.
- DOT holds off on rulemaking for regulations concerning environmentally hazardous substances, awaiting further consideration on the topic by the EPA.
- Third revised edition of GHS is published. [Currently the most recent.]
- OSHA proposes modifications to the HCS to conform to GHS.
- U.S. hosts public hearings on GHS and OSHA’s proposed rulemaking.
- GHS currently implemented or in various stages of implementation in 67 countries.
- OSHA delivers final rule to the Office of Management and Budget (OMB) – October 25
- OSHA meets with OMB and a series of stakeholders to discuss several issues such as combustible dust and compliance time frame. November – January.
- OMB passes final rule on GHS in February with the designation: “Consistent with Change.”
- OSHA announces final rule. Dr. Michaels calls it HazCom 2012 and says it gives workers the “Right to Understand.” Revised HazCom published in Federal Register. March 26. Effective date set 60 days after publishing.
- December 1 – Employers must complete training of employees on how to read GHS formatted safety data sheets and labels.
- June 1 – Manufacturers and Distributors must comply with revised HCS. This includes reclassifying chemicals and producing GHS formatted labels and SDSs. Distributors get an additional 6 months to distribute old inventory already labeled.
- December 1 – Distributors must fully comply with revised HCS. (Grace period ends.)
- June 1 – Employers must fully comply with revised HCS and complete training of employees on newly identified hazards and/or any updates to workplace hazard program.