The Globally Harmonized System of Classification and labeling of Chemicals (GHS) is exactly what it sounds like – an internationally recognized labeling system for dangerous chemicals. The images that comprise it are present on products we all buy and use every day.
The GHS was created by the United Nations as an internationally applicable set of labels and indicators for classifying hazardous materials and the risks associated with their use.
Initially begun in 1992, the GHS has been fully developed and implemented by an increasing number of countries, most notably in the United States, where it was introduced as the mandatory standard in 2015. Importantly, adaption of GHS in the US has led to the replacement of the venerable Material Safety Data Sheet (MSDS) with the newer Safety Data Sheets (SDS).
Now, it’s Canada’s turn. The deadline for phase one adoption is set for June, 2017.
Why the Move towards GHS and Why Now?
Given that Canada and the US represent each other’s largest trading partner, and with the correct labeling of dangerous goods being pushed by both the US Occupational Safety and Health Administration (OSHA) and Health Canada respectively; harmonization on labeling makes perfect sense.
This aligns both countries with the ultimate goal of the GHS – a genuinely global set of standards governing hazardous chemicals. Clarity through labeling will ultimately :
• Save lives and prevent injuries (saving 43 lives and preventing 585 injuries annually in the US)
• Ease regulatory burdens and spur productivity (saving over $266 million annually in the US).
• Facilitate cross-border trade.
• Encourage better handling and application of chemicals.
Uniformity across all labeled goods produced by both countries will cement this transnational standard of easily-understood warnings – a real plus from an EH&S point-of-view. This means a drum of chemicals, whether produced in Ohio or Ontario, should have the same easily-understood symbols displayed on each.However, there are factors that complicate this harmonization, not least the ‘non-binding’ nature of the legislation, and dealing with the host of pre-existing legislation that governs labeling of dangerous goods in Canada - prior to this year’s harmonization.
What Are the Implications – Especially for US Companies?
What’s clear is that in Canada, GHS will become the new norm. Therefore, it makes sense for companies that carry out exports to any degree to Canada to ensure that their products are in compliance going forward.
Here’s the crux of the matter - GHS isn’t monolithic. It is still classed as a ‘non-binding’ system, meaning that only those particular GHS guidelines that are adopted by law in Canada will apply.
This means that a US company that has happily aligned themselves with GHS at home may still find their labeling lacking or non-compliant when their products are retailed in Canada. The risk of fines or penalties is obviously something companies in this situation will wish to avoid. These companies will need to address these concerns and build the confidence that their labels and SDSs are meeting the demands of both countries’ GHS implementations.
Complicating this is the tangled nature of Canadian provincial laws and requirements, and how these interact with overarching federal adaption. It’s not entirely clear exactly what’s required, but similar to the State / Federal interaction in the US, this can be a sticky issue.
Similarly, there are other issues, such as the practical issue of language legislation that could arise. With French being an official and much-used language throughout Canada, all US-produced products will need to take into account any practical requirements and make sure their GHS set-up complies with both official languages. For US companies, this means the tools you used for GHS compliance back in 2015 may not make the cut if they lack some vital translation features.
These issues, hovering over the transition, are of particular concern to US companies that carried out a ‘once-off’ alignment of their GHS labeling to satisfy US legislation. In the case of SDSs, these will need updating. With Canada permanently adopting GHS, it’s clear that there will be aspects to the adaption that will need to be assessed. That’s why it is preferable to have a flexible SDS authoring system that takes a more global approach to GHS.
The Challenge and the Solution
Indeed, with GHS ever-expanding to more and more of the US’s trading partners, the need for more robust authoring, keeping you in compliance despite ever-shifting regulations is ever more pressing.
This is in addition to the actual data challenges associated with GHS – making sure your business is measuring and labeling these complex chemicals correctly, with the ability to produce them rapidly.
SDS Authoring software can represent a more water-tight solution to these issues – by automatically compiling SDSs that take into account GHS legislation per specific country. The Return on Investment (ROI) on this type of service is compelling.
GHS is likely to become more and more of an issue as adaption legislation galvanizes across North America. Here at ERA, we’ll strive to keep you fully informed, and to explore the real issues that will confront businesses.
Right now is the time for both Canadian businesses and US businesses to start examining how they’ll approach their GHS compliance for the Canadian interpretation of the regulations.
• US companies, does your current SDS system enable you to comply internationally?
• Canadian manufacturers, have you begun seeking out a system that secures your spot distributing to US trade partners?
Learn more about a solution that can help you achieve GHS compliance no matter where in the world you do business. Get a free customized demo of ERA SDS Software today.
August 31, 2016