Foundation of Workplace Chemical Safety Programs
The Globally Harmonized System for Hazard Communication
In 2003, the United Nations (UN) adopted the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS includes criteria for the classification of health, physical and environmental hazards, as well as specifying what information should be included on labels of hazardous chemicals as well as safety data sheets. The United States was an active participant in the development of the GHS, and is a member of the UN bodies established to maintain and coordinate implementation of the system. The official text of the GHS can be found on the UN web page.
OSHA GHS Proposal
OSHA published a proposed rulemaking on September 30, 2009 to align OSHA's Hazard Communication standard (HCS) with the GHS. [Also available as an 11 MB PDF, 271 pages] This is a significant step in the rulemaking process. OSHA has provided a 90-day comment period ending on December 29, 2009. Informal public hearings will follow. OSHA will publish a hearing notice in the Federal Register with details on dates and location(s).
To aide in the understanding of the HCS proposal OSHA is providing additional information:
- Proposed HCS regulatory text
- Proposed Appendix A: Health Hazard Criteria (Mandatory)
- Proposed Appendix B: Physical Hazard Criteria (Mandatory)
- Proposed Appendix C: Allocation of Label Elements (Mandatory)
- Proposed Appendix D: Safety Data Sheets (Mandatory)
- Proposed Appendix E (Existing Appendix D): Definition of Trade Secret (Mandatory)
- Proposed Appendix F: Guidance for Hazard Classifications Regarding Carcinogenicity (Non-Mandatory)
- Proposed HCS regulatory text (redline strikeout)
- Side-by-side comparison of the current HCS to the Proposed Rule
- Facts on Aligning the Hazard Communication Standard to the GHS
OSHA GHS Advance Notice of Proposed Rulemaking
In May 2005, The Agency added to its regulatory agenda consideration of rulemaking to revise the HCS to align its requirements with the GHS. As the first step in that rulemaking process, OSHA published an advance notice of proposed rulemaking (ANPR) on September 12, 2006. [Also available as a 3 MB PDF, 11 pages.]
The ANPR explains the history of the development of the GHS, including OSHA's involvement in the process. It also indicates how alignment with the GHS would affect the requirements of the HCS, and asks a series of questions to allow the public an opportunity to provide input. The comment period closed on November 13, 2006. Comments submitted are available on OSHA's web page under the e-docket section. The Docket Number is H022K. This October 2006 Powerpoint presentation, provides more information about the ANPR, the impact of the GHS on the HCS, and other implementation issues.
OSHA has also completed a detailed comparison of the provisions of the GHS to the requirements of the HCS. This document indicates the changes that would have to be made to be consistent with the GHS., 153 pages.
Other Federal Agency Activities
- Globally Harmonized System (GHS) for Classification and Labeling of Chemicals. Environmental Protection Agency (EPA).
- Policy of the U.S. Consumer Product Safety Commission on the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Consumer Product Safety Commission (CPSC).
Implementation in Other Countries
- GHS: Status of Implementation. UN Economic Commission. Tracks international implementation.
- Workplace Hazardous Chemicals Public Comment. Australian Safety and Compensation Council (ASCC).
- Proposed revisions to the workplace chemicals regulatory framework. Australian Safety and Compensation Council (ASCC).