Spring 2011

Globally Harmonized System for Hazard Communication

traingleNot familiar with the Globally Harmonized System for Hazard Communication (GHS)?  You’re certainly not alone!  At a recent meeting of environmental and hazardous materials professionals, only two in a group of 25 individuals were even familiar with the system.  It is something, however, that will increasingly become familiar to those who handle hazardous materials throughout the United States. 

The Globally Harmonized System for Hazard Communication is a hazard communication system intended to provide a uniform and consistent hazard communication across the international trade community.  The diverse and sometimes conflicting national and international requirements have created significant confusion for those seeking to obtain hazard information.  The GHS is intended to replace all the various, country-based classification, labeling and communication systems in use. 

The GHS was first conceptualized in 1992 as a United Nations effort to address inconsistencies that existed between the various hazard communication systems in place at that time.  The United Nations formally adopted the system in 2003. The GHS has since been adopted into European Union law. 

The Occupational Safety and Health Administration (OSHA) first indicated a desire to revise the existing Hazard Communication System (HCS) by adopting the GHS in May of 2005.  On September 30, 2009, the agency published a proposed rule to begin the formal process of alignment.  While OSHA has consistently expressed a commitment to conform to the GHS, the rule making process has been slow and has at times stalled.  There are indications that OSHA will publish a Final Rule in August of this year.  The final rule will establish implementation timetables.  Aspects of the rule could be implemented as early as 2012.

The GHS has significant differences over the existing OSHA HCS.  The GHS uses a series of pictograms, hazard statements and signal words to communicate hazard information – many not commonly used in the HCS.  Another notable difference is the fact that the scoring system used to indicate overall health, fire and reactivity hazards are opposite.  While a one (1) may indicate a low hazard in the HCS, a one (1) will indicate a high hazard in the GHS.   In addition to labeling differences, users will also see changes to the Materials Safety Data Sheet system.  The Office of Environmental Health and Safety will provide additional information on the GHS as it moves towards formal adoption and implementation within the United States. 

Chemical suppliers in the United States which also supply chemicals throughout the European Union have begun to produce labels for their products containing both OSHA HCS and the GHS information.  It is possible that labs on campus may begin to receive chemical containers with both the dual communication information in the near future.  In the event you receive a container with this dual-labeling system, it is generally recommended that you ignore the GHS information and continue to use the OSHA HCS until you have a full understanding of the GHS. 

Integration of the GHS within the United States will make the most significant refinement of the OSHA Hazard Communication Program since it was adopted in 1985.  It further refines the hazard communication process and provides employees with a wealth of hazard information.  Look for additional information on the GHS in future editions of Lab Notes.