The document summarizes the key changes to the OSHA Hazard Communication Standard (HCS) to align it with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Some of the major changes include new criteria for classifying health and physical hazards, standardized label elements, a standardized format for safety data sheets, and updated training requirements for workers. The changes are intended to improve the quality and consistency of chemical hazard communication and worker understanding globally.

2. GHS
Jim Shelton, CAS, HNAO
Updated by Jorge Delucca,
OKCAO Version 2, June 2012

3. GHS
• On March 26, 2012 OSHA published
the final rule to align the OSHA
Hazard Communication Standard
(HCS) with the Globally Harmonized
System of Classification and
Labeling of Chemicals (GHS)
• The final rule becomes effective on
May 25, 2012

4. GHS
• The change will help ensure improved quality and more
consistency in the classification and labeling of all
chemicals
• AIHA summed up the support from commenters and
testifiers by declaring that the GHS modifications will
improve quality and consistency of hazard
communication information (Document ID #0496 Tr.
415). Source: Federal Register, March 26, 2012

5. GHS
• The benefits include enhanced worker comprehension
resulting in appropriate handling and use of chemicals.
The harmonized format of the safety data sheets will
enable workers to access the information more efficiently
• Also currently multiple labels and safety data sheets
must often be developed by chemical manufacturers for
the same product when shipped overseas. This creates
a major compliance burden increasing costs

6. GHS
• GHS provides a single set of harmonized criteria
for classifying chemicals according to their health
and physical hazards
• Specifies hazard communication elements for
labeling and safety data sheets.
• Labels will include signal words, pictograms, and
hazard and precautionary statements and safety
data sheets would have a standardized format

7. GHS
• The major proposed changes to the HCS:
– Hazard Classification (changed from hazard
determination)
– Labels
– Safety Data Sheets (changed from materials
safety data sheets)
– Information and Training
• Will affect nearly 40 million workers and 5 million
workplaces

8. TLVs, PELs, & other exposure llimits
• TLVs, PELs, and “any other exposure limit
recommended by the chemical
manufacturer, importer or employer are
required”

9. Carcinogenicity
• If a chemical is listed as carcinogen by
IARC or NTP, it must be noted on the SDS
• If OSHA finds a chemical to be a
carcinogen, it must be noted on the SDS

10. GHS
• The GHS may prevent 43
fatalities and 585 injuries and
illnesses annually
• DOT has already modified
their requirements for
classification and labeling to
be consistent with UN
transport requirements and
the GHS

11. Phase-In dates
Effective Completion Requirements Who
date
Dec 1, 2013 Train employees on new labels and Employers
Safety Data Sheet format
June 1, 2015 Compliance with modified provisions of Chemical
final rule except: manufacturers,
importers, distributors
December 1, 2015 Distributors shall not ship containers & employers
labeled unless it is a GHS label
Employers
June 1, 2016 Update workplace labeling and HAZCOM
program. Additional employee training on
newly found physical or health hazards
Transition period May comply with final HAZCOM std. or Chemical
current std., or both manufacturers,
importers, distributors
& employers

12. GHS Hazard Classification
• The list of chemicals presenting a ‘Health’
hazard was deleted from the current HCS and
the proposed HCS has identified a new listing
• A ‘Health Hazard’ means a chemical which is
classified as posing one of the following
hazardous effects:

13. GHS Hazard Classification
– Acute Toxicity (any route of exposure)
– Skin Corrosion or Irritation
– Serious Eye Damage or Eye Irritation
– Respiratory or Skin Sensitization
– Germ Cell Mutagenicity
– Carcinogenicity
– Reproductive Toxicity
– Specific Target Organ Toxicity (single or repeated
exposure)
– Aspiration Hazard

14. GHS Hazard Classification
• The list of chemicals presenting a ‘Physical’
hazard was deleted from the current HCS and
the proposed HCS has identified a new listing
• A ‘Physical Hazard’ means a chemical that is
classified as posing one of the following
hazardous effects:

15. GHS Hazard Classification
– Explosive
– Flammable (gases, aerosols, liquids, or solids)
– Oxidizer (liquid, solid, or gas)
– Self-Reactive
– Pyrophoric (liquid or solid)
– Self-Heating
– Organic Peroxide
– Corrosive To Metal
– Gas Under Pressure
– Contact With Water Emits Flammable Gas

16. GHS Hazard Classification
• The HCS does not address environmental
hazards and OSHA does not have jurisdiction
over that. There are environmental hazard
classifications:
– Hazardous to the Aquatic Environment
• Acute Aquatic Toxicity
• Chronic Aquatic Toxicity
– Bioaccumulation Potential
– Rapid Degradability

17. OSHA Hazard Classification
• In OSHA’s proposed rule there was a hazard
category called ‘Unclassified’ which is not in the
UN GHS system
– … a chemical for which there is scientific evidence
identified during the classification process that may
pose an adverse physical or health effect when present
in a workplace under normal conditions of use…
– Example: Combustible Dust

18. Hazards Not otherwise Classified
• OSHA changed “unclassified hazards” to
“hazards not otherwise classified” (HNOC)
• For issues that have not gone through a
rulemaking
• Combustible dust is considered
“hazardous chemical”

19. Hazardous Chemical
• OSHA classified as Hazardous Chemicals:
– Pyrophoric gases, signal word “danger”,
“catches fire spontaneously if exposed to air”*
– Simple asphyxiants, signal word “warning”,
“may displace oxygen and cause rapid
suffocation”*
– Combustible dust, signal word “warning”,
“May form combustible dust concentrations in
the air”*
*Hazard Statements

20. Other Standards Affected
• Flammable and combustible liquids in
general industry & construction (1910.106
and 1926.152)
– Align with GHS hazard categories for
flammable liquids

21. Other Standards Affected
• Process Safety management of Highly
Hazardous Chemicals (1910.119)
– Modified to ensure scope is not changed
• Modifications made to most OSHA’s
substance-specific health standards to
ensure signs and labels are consistent
with modified HCS

22. Change to warnings for carcinogens
• All warnings for carcinogens will be
standardized to read:
“May Cause Cancer”

23. GHS Labels
• Three standardized GHS label elements:
– Symbols (Hazard Pictograms) that convey health,
physical, and environmental hazard information
assigned to a GHS hazard class and category
– Signal Words “Danger” or “Warning” used to
emphasize hazards and relative level of severity
of the hazard and assigned to a GHS hazard
class and category
– Hazard Statements which are standard phrases
assigned to a hazard class and category that
describe the nature of the hazard

24. GHS Labels
• Key Elements
– Product Identifier
– Supplier Identifier
– Chemical Identity
– Hazard Pictograms*
– Signal Words*
– Hazard Statements*
– Precautionary
Information
* Standardized

25. GHS Labels
Red
border
GHS
------
Black
border
Transport

26. GHS Labels
Hazard Classes may have ‘Categories’

27. GHS Labels

28. GHS Labels
Example of a Transportation and GHS label combined

29. Safety Data Sheets (SDS)
• The OSHA ‘Material Safety Data Sheet’ (MSDS)
will be called a ‘Safety Data Sheet’ (SDS)
• The MSDS has 8 non-mandatory sections
• The SDS would have 12 mandatory and 4 non-
mandatory sections and is essentially the ANSI
Z400.1-2004 format
– Sections 12-15 are not mandatory and cover
Ecological, Disposal, Transport, and Regulatory
information

30. Safety Data Sheets (SDS)

31. HCS Appendices
• Appendix A: Health Hazard Criteria
• Appendix B: Physical Hazard Criteria
• Appendix C: Allocation of Label Elements
• Appendix D: Safety Data Sheets
• Appendix E: Definition of ‘Trade Secret’
• Appendix F: Guidance for Hazard Classification
Regarding Carcinogenicity

32. GHS Changes in the Future
• The GHS is updated as needed to reflect new
technology and scientific developments, or
provide explanatory text. Changes to the HCS is
anticipated through:
– Technical Updates for minor terminology changes
– Direct Final Rules for text clarification
– Notice and Comment Rulemaking for more
substantive or controversial updates such as
additional or changes in health or safety hazard
classes or categories

33. Industry Groups Challenge HAZCOM Aligned
with GHS—Source: Bloomberg BNA
Industry groups petitioned a federal appeals court
the week of May 21:
3.CropLife America: possible conflicts between
HAZCOM and EPA’s Federal Insecticide
Fungicide and Rodenticide Act (FIFRA)
requirements for pesticide labeling

34. Industry Groups Challenge HAZCOM Aligned
with GHS—Source: Bloomberg BNA
2. American Chemistry Council and 4
industry groups: OSHA should not address
combustible dust in final rule; doing so
would transform it into a de facto dust
standard

35. Industry Groups Challenge HAZCOM Aligned
with GHS—Source: Bloomberg BNA
3. American Petroleum Institute: criticized
mandatory “arbitrary” 20 percent concentration
threshold for the classification of chemical mixtures
containing target organ toxicity hazards
OSHA should require categories “be based
upon science and hazard determination”

36. Industry Groups Challenge HAZCOM Aligned
with GHS—Source: Bloomberg BNA
• We need to wait until these challenges are
settled to find out what changes, if any,
will be done to the HAZCOM standard

37. Resources
• On the OSHA website
under ‘Safety and
Health Topics’ there
is a Hazard
Communication
webpage with many
resources and
documents including
a link to a GHS page

38. Resources
• The GHS webpage
has lots of documents
including side by side
comparisons of the
HCS and the new
proposed HCS

39. Resources
• OSHA published ‘A
Guide to The Globally
Harmonized System
of Classification and
Labeling of Chemicals
(GHS)
• It can be downloaded
from the OSHA
website

40. Disclaimer
• This information has been developed by an OSHA Compliance Assistance
Specialist and is intended to assist employers, workers, and others as they
strive to improve workplace health and safety. While we attempt to
thoroughly address specific topics [or hazards], it is not possible to include
discussion of everything necessary to ensure a healthy and safe working
environment in a presentation of this nature. Thus, this information must be
understood as a tool for addressing workplace hazards, rather than an
exhaustive statement of an employer’s legal obligations, which are defined
by statute, regulations, and standards. Likewise, to the extent that this
information references practices or procedures that may enhance health or
safety, but which are not required by a statute, regulation, or standard, it
cannot, and does not, create additional legal obligations. Finally, over time,
OSHA may modify rules and interpretations in light of new technology,
information, or circumstances; to keep apprised of such developments, or to
review information on a wide range of occupational safety and health topics,
you can visit OSHA’s website at www.osha.gov.