GHS Frequently Asked Questions
A. GHS stands for Globally Harmonized System. The GHS is an international regulation that the United Nations (UN) has created for the Classification and Labeling of Hazardous Chemicals.
A. Without the GHS, countries around the world are left to determine their own standards for what chemicals are hazardous – and how to properly communicate those hazards. Each country handles this differently, which creates confusion and complexity for international manufacturers. The GHS is intended to create a single, universal format for hazard communication across the globe.
A. OSHA published an updated Hazard Communication standard in March, 2012. There is a three year transactional period to allow companies to fully implement the new HazCom standard in their facilities.
A. The full GHS compliance deadline is June 1, 2016. After that date, hazard communication and workplace labeling programs, processes and documents must be updated. For chemical distributors, the next deadline is December 1, 2015, when products must be shipped with updated Safety Data Sheets (SDS) and chemical labels.
To see all GHS labels, visit bradyid.com/ghs
A. Shipped or primary container labels are used on any container leaving the workplace. These labels must have the six required elements of a GHS chemical label.
A workplace or secondary label container does not always fall under the same requirement. Best practice is to match this label to the primary container label for consistency. However, other labeling options can be used as long as they contain chemical words, pictures, symbols or any combination of these to convey all the physical and health hazards
of the chemical.
A. When a container is small, you must use pull-out labels, fold-back labels, tags and other methods for identification. If this is still not feasible, OSHA has issued a practical accommodation for the information on the label. This includes, at a minimum, the product identifier, pictograms, the manufacturer’s name and phone number, signal word and a statement that full information is provided on the outside package.
A. A general rule of thumb is to order pre-printed labels if you only need a low volume (up to a few hundred labels), find it difficult to justify the cost of a printer investment and can handle a 2-4 day lead time. Pre-printed labels could also be used for very high volumes (e.g. thousands of labels) using the same text, the need for high print speeds and when you can accommodate a 1-2 week lead time.
A printing system and print-it-yourself method is ideal for medium volume printing (e.g. several hundred to a few thousand), when a medium print speed is needed. This gives you the flexibility to print other safety labels and customize workplace messaging. There is no lead time as labels can be made right when you need them. In addition, templates and data can be stored for later use. To see all pre-printed GHS labels, visit bradyid.com/ghs
A. The European Union has already begun implementing many parts of the GHS regulation. Countries and regions around the world are beginning to implement it, each with their own individual timeline.
Although it is an international standard, there is not one specific international implementation schedule. The GHS is a voluntary regulation set forth by the UN; each nation’s government is responsible for overseeing the regulatory changes and compliance.
A. The GHS is applied within the current framework of OSHA’s existing hazard communication regulations. The GHS is not intended to replace OSHA’s standards, but instead update and add internationally harmonized compliance to its schematics. For example, OSHA is expected to require hazard pictograms/symbols to all of the chemical labeling.
A. The GHS will affect chemical suppliers, manufacturers, end users, and testing laboratories. Any workplace that is currently subject to the Hazard Communication regulations is affected.
A. There are 3 key changes that will be made during the implementation of the GHS:
Download The Streamlined Guide to GHS to learn how to prepare for the upcoming deadlines.
A. All of the elements of the GHS labeling system can be found and accessed in Annex 1-3 of the UN’s 3rd revised edition of the Globally Harmonized Standard for Classification and Labeling of Chemicals, found on their website.
A. Yes, employees will need to be trained in order to recognize and understand the new labels, pictograms and SDS information. Employees need to learn how to interpret the pictograms and new hazard statements, and know what precautions must be taken for chemical products. The GHS is a bit more complex than the previous standards, and training is very important to ensure that the GHS is an added safety measure in the workplace. Check out the GHS Training Kit for more information.
A. The standardized elements required for GHS labels are:
To see all GHS labels, check out bradyid.com/ghs
A. The GHS makes it easier for employers, employees and the public to understand the hazards of chemicals, and take the necessary preventive and protective measures for their safety and health. It also offers a number of benefits for our government, companies and general public.
According to OSHA, here are the key benefits of GHS implementation:
A. The GHS requires proper labeling when shipping or storing chemicals. The labels should be on the individual chemicals, as well as on the outside of the larger boxes or drums that are used to ship or store the chemicals. Proper DOT labeling must also be present that corresponds correctly with the GHS labeled chemicals.
A. A blank diamond red frame set on point is not a pictogram and is not permissible under HCS2012. Black-out option is compliant but then red frame of the blank diamond must be fully covered.
A. Manufacturers, importers, and distributors should have started providing SDSs on June 1, 2015. All employers must have, maintain, and make available to employees the most recent MSDS or SDS received.
A. Pictogram labels with adhesive backing on a label that are sufficiently wide to be clearly visible are acceptable.
A. From OSHA Brief 3696 Steps to Effective Hazard Communication, electronic copies are permitted, however you must have a back-up system in event of power failure and/or equipment failure of the primary system. Employees must be trained on how to use system and obtain hard copies if needed. In medical emergency, hard copy SDS's must be immediately available to emergency personnel.
A. OSHA would not issue citations for maintenance of MSDSs when SDSs have not been received. As OSHA explained in a January 2013 letter, employers may, but are not required to, contact manufacturers or distributors of products they have previously ordered to request new SDS's.
A. The non-official response from the Dept. of Labor states that All containers moved from one facility to another (unless its immediately used by the person performing the transfer) must be labeled in accordance with (f)(1) – full 6 label elements.
A. Hazardous Waste labeling is not covered by HCS2012. It’s covered by the EPA under the RCRA Act (Resource Conservation and Recovery Act).
A. From the July, 2014 OSHA Letter of Interpretation, clarified on May 29, 2015, OSHA is not changing the timeline but will use discretion in enforcing the standard if reasonable diligence and good faith efforts have been pursued.
This includes: Documenting efforts to obtain information from upstream suppliers, providing a written account of continued correspondence, using alternative sources (e.g. chem databases) to find information, and attempting to classify the chemical yourself.
A. From OSHA’s clarification memo May 29, 2015, HCS2012 permits distributors to ship with HCS1994 labels until Dec 1, 2015 and if distributor cannot comply, a compliance officer must determine whether distributor has evidence it exercised reasonable diligence and good faith to comply.
This is handled on a case-by-case basis and distributors must present documentation of any and all communications with the manufacturer or importer regarding its reasons for noncompliance with HCS2012.
A. No, GHS is a voluntary international system that implements the framework for standardizing compliance regulations, such as converting MSDS’s to SDS’s. Countries like the US have the option to adopt and implement it freely. Only competent authorities such as EPA, OSHA and Health Canada, have the authority to decide which GHS building blocks to incorporate.
A. For secondary containers, if it does not leave your facility, you can use a workplace label with the current HazCom 1994 labels, or use the chemical identifier (words, pictures, symbols) in combination with the other identification.
A. Products falling within the scope of the GHS will carry the GHS label at the point where they are supplied to the workplace, and that label should be maintained on the supplied container in the workplace. The GHS label or label elements can also be used for workplace containers (e.g., storage tanks). However, OSHA allows a system of labeling that meets the requirements of HazCom 1994. The employer may continue to use this system in the workplace as long as this system, in conjunction with other information immediately available to the employees, provides the employees with the information on all of the health and physical hazards of the hazardous chemical.
A. Yes, this has not changed. No labeling requirements if the material will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred.
A. No. The following regulations pertain to GHS labeling requirements.
1910.1200(b)(3)(i): Employers shall ensure that labels on incoming containers of hazardous chemicals are not removed or defaced.
1910.1200(b)(3)(iii): Employers shall ensure that laboratory employees are provided information and training in accordance with paragraph (h) of this section, except for the location and availability of the written hazard communication program under paragraph (h)(2)(iii) of this section.
1910.1200(b)(3)(iv): Laboratory employers that ship hazardous chemicals are considered to be either a chemical manufacturer or a distributor under this rule, and thus must ensure that any containers of hazardous chemicals leaving the laboratory are labeled in accordance with paragraph (f) of this section, and that a safety data sheet is provided to distributors and other employers in accordance with paragraphs (g)(6) and (g)(7) of this section.