What is GHS?
GHS stands for the Globally Harmonized System of Classification and Labelling of Chemicals. GHS was developed by the United Nations 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 when it comes to defining and communicating chemical hazards.
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, Mexico 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, their 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, and includes special responsibilities for chemical manufacturers and employers that handle, use and store hazardous materials. GHS adoption requires chemical manufacturers to reclassify their chemicals using standardized GHS classification criteria, as well as to produce GHS-aligned labels and safety data sheets (SDSs). Employers must train employees on GHS (how to understand new labels and safety data sheets); must manage new SDSs, replacing their old library of MSDSs; and must be able to produce compliant GHS-aligned workplace labels as needed. For additional information, be sure to check out our sample SDS and GHS Label Guide.
Learn more at the GHS Answer Center.
Compliance is key.
There's good evidence to suggest that OSHA and other enforcement bodies are serious about enforcing chemical-related regulations and standards. Since 2009, OSHA has cited over 47,000 instances of HazCom violations in workplaces across the United States. In 2012, HazCom moved up from the #3 spot to #2 on OSHA's most frequently cited standards list (behind only fall protection). And in Canada, 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.
Ultimately, employers have a responsibility to keep their employees safe. For that reason, and to ensure full compliance, VelocityEHS recommends companies get in front and stay in front of all GHS-affected rules and regulations as soon as possible. If you are looking for a GHS-formatted SDS, try our MSDS Search tool.
GHS Alignment with HCS
The revision of the Hazard Communication Standard to align with GHS has impacted 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.
Essentially, the revisions of OSHA’s HCS to align with GHS resulted in two major changes. First, unlike HCS 1994 (pre-GHS HazCom Standard), which stops at simply classifying hazards, under HCS 2012 (post-GHS HazCom Standard) hazard classes are subdivided into "hazard categories," requiring chemical manufacturers to identify both the hazardous effects of their chemicals as well as their degrees of severity.
GHS safety labels have six standardized elements:
- Product Identifier – Must match product identifier on safety data sheet
- Manufacturer Contact Information – Including name, phone number, and address
- Hazard Pictograms – New label elements that may require color printers
- Signal Word – Either DANGER or WARNING depending upon hazard severity
- Hazard Statements – Standardized sentences that describes the level of the hazards
- 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 now 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 the MSDSonline Environmental, Health and Safety Blog.
GHS Compliant Labels
With GHS alignment, each container of a classified hazardous chemical must be labeled, tagged, or marked with the following elements:
- Product or chemical identifier clearly indicated on the label that matches the product or chemical identifier on the SDS.
- Contact information for the product supplier, including the company name, address and telephone number.
- Hazard Pictograms. Pictograms have a black symbol on a white background with a red diamond frame. (See examples below)
- Flame Explosive Health Hazard Corrosion Skull and Crossbones Exclamation Mark. Note: The UN GHS allows for a black frame to be used for shipments within a single country. OSHA's GHS-aligned HazCom, however, requires that a red frame be used regardless of whether the shipment is traveling inside or outside of the country.
- 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.
- 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.
- Lastly, the label should include the appropriate precautionary information. Since HazCom 1994 didn't require precautionary statements, this is a key change to the standard, resulting from GHS adoption.
Keep in mind these requirements are for classified hazards. For Hazards Not Otherwise Classified (HNOCs), OSHA doesn't have any label requirements, but their hazard information must be provided in Section 2 of the SDS. OSHA allows supplemental information related to HNOCs to be included on the label so long as it doesn't cast doubt or conflict with the required information on the label. Under, WHMIS additional label elements may need to be included, such as an on-label reference to a chemical's corresponding SDS.
GHS allows authorities like OSHA to determine what types of workplace labels will be required. OSHA continues 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 also gives 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, GHS / HazCom 2012 compliant shipped and workplace labels must be in English (at a minimum), and must not be defaced or removed unless immediately replaced with new labels.
GHS Compliant SDSs
As was mentioned earlier, MSDSs 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. The sections, in order, are as follows:
- Hazard(s) Identification
- Composition / Ingredient Information
- First-Aid Measures
- Fire-Fighting Measures
- Accidental Release Measures
- Handling and Storage
- Exposure Control / Personal Protection
- Physical & Chemical Properties
- Stability & Reactivity
- Toxicological Information
- Ecological Information
- Disposal Considerations
- Transport Information
- Regulatory Information
- Other Information
To be compliant, SDSs must have all 16 sections; however, OSHA is not enforcing information contained in sections 12-15, which falls outside the Agency's jurisdiction. Since GHS adoption went into effect in 2012, HazCom-covered employers have been faced with managing varying influxes of new SDSs from manufacturers.