The U.S. OSHA (Occupational Health and Safety Administration) has committed itself to updating the way that all workplace chemicals manufactured in the U.S. get labeled so that they conform with the new Globally Harmonized System (GHS) standards. This could mean some big changes are on the way if your business manufacturers or exports chemicals or chemical mixtures. Read more about the upcoming changes here.
GHS is a United Nations-driven project that attempts to get every country to use the same system for labeling chemicals and writing safety data sheets (SDSs) in order to reduce workplace safety hazards and spills. The goal is to produce the most accurate data possible and to make it consistent across every country, as right now a chemical can be classified and labeled differently from country to country.
At the moment, the European Union has already switched over to GHS for chemical manufacturing, and is making moves to implement GHS standards for chemical mixtures in the next few years. Canada has made a similar commitment as the United States, meaning that the entire North American chemical industry is embracing the new system.
The 4 Essential Label Elements
While there will be a lot of overlap between the OSHA-style MSDS and the new GHS SDS, the GHS way of MSDS authoring introduces four key elements that are not universally found on OSHA-compliant MSDSs or labels.
Signal words are the phrases used to immediately identify the hazard level associated with the use of the chemical. There is only one signal word for per SDS or label, determined by the highest potential hazard level, and it always appears near the very top of the page – in many ways it is the first line of defense against accidents and health hazards. In addition, the signal word is written in all upper-case letters.
The two signal words proposed for implementation by OSHA are: DANGER and WARNING. DANGER is to be used for more hazardous chemicals and WARNING is to be used for less hazardous chemicals. The hazard level is dependent on the GHS hazard category and class that the chemical or mixture falls under.
Hazard statements provide a brief description that gives more details about the types of hazards the chemical presents. All GHS hazard statements are standardized and codified, meaning that when you are writing a GHS SDS or label you simply have to pick the appropriate entry from the GHS guidebook – known as the "GHS Purple Book". A complete list of hazard statements can be found in Annex 1 of the guide.
Hazard statements are not entirely foreign to the U.S., as most of them are terms we already apply to our chemicals. Here are a few examples:
- Flammable Gas
- Combustible liquid
- Contains gas under pressure; may explode if heated
- Fatal if swallowed
- Causes eye irritation
If a chemical or chemical mixture poses more than one hazard, it is up to the chemical manufacturer to include all of the related hazard statements.
Each hazard statement comes with an alphanumerical code, starting with “H”. However, these codes are not present on labels or SDSs as they do not provide the same instantaneous data about possible hazards.
Like most North American labels and MSDSs, the GHS safety data sheet and GHS labels use standardized pictograms to provide visual warnings about hazards related to use or spillage. The GHS in particular uses these pictograms to overcome the potential language barriers that could arise in a globalized system. Most North Americans will already recognize these pictograms.
The standard GHS pictogram always comes printed in black on a white background, framed by a red outline that is set on a point (for example, a red diamond). However, OSHA has decided to allow manufacturers to use a black diamond instead of red for any chemical that will not be exported.
Here are a few examples:
The GHS “Purple Book” provides all the classifications that go along with each pictogram. For example, the traditional skull and crossbones pictogram can indicate that a chemical is fatal if swallowed, toxic if swallowed, or has acute toxicity. The exclamation point pictogram can indicate one of 6 different health hazards.
There is also a set of pictograms related to transportation and shipping which need to be used. Each of these pictograms also comes specifically color coded. If you ship or manufacture chemicals, it is definitely worth reading through the GHS Purple Book to learn the new pictograms.
Finally, precautionary statements briefly describe preventative measures that should be adhered to when using the chemical in order to reduce hazardous risks. For example, a GHS SDS or label may state: “wear respiratory protection”.
There are 4 types of precautionary statements: prevention, response in cases of accidental spillage or exposure, storage, and disposal:
- Prevention tells the reader how best to prevent the potential hazards, response details the safest way to clean a spill or treat exposure (i.e. “do not induce vomiting”).
- Storage describes the safest way to store the chemical (“do not expose to heat or light”).
- Disposal outlines best practices for getting rid of the chemical and chemical-contaminated objects.
The GHS Purple Book contains a useful list of precautionary statements that you can use. However, these statements are not standardized, so you can write your own precautionary statements if need be. It is a good idea though to read through the GHS examples to get a feeling for the tone and style used by the GHS.
Putting it all Together
Here’s an example template image from the OSHA’s online guide to GHS Standards. It displays a label containing the four essential elements, as well as several other elements which are usually found on most chemical labels regardless of country of origin (for example, chemical name/identifier, or first aid statements).
The references and annexes it suggests for further reading can all be found in the GHS Purple Book (a UN online version can be found here if you don’t plan on ordering an official publication for your business).
An electronic SDS Management System is a powerful tool that will help you keep up with the influx of changes brought on by the GHS. The deadline for employee training was December 1st, 2013 and the next upcoming deadline for compliance with the majority of modified provision is June 15th, 2013. If you are thinking of implementing an SDS Management System, the guide below will carefully walk your through all the necessary steps.
Label Image Credit: https://www.osha.gov/Publications/HazComm_QuickCard_Pictogram.html
Pictogram Image Credit: http://en.wikipedia.org/wiki/GHS_hazard_pictograms
December 6, 2012