Labeling and GHS compliance – What you need to know

Ten years after the United Nations agreed to institute a standardized system for hazardous chemical categorizing, sale documenting, and labeling, we are on the cusp of OSHA publishing the first official pronouncement about GHS.  Since pronouncement precedes enforcement, this is a good time to start getting up to speed on what is happening and how it can impact your business.

What is GHS and where did it come from?

In 2003 the United Nations Economic and Social Council adopted a globally harmonized system of classification and labeling of chemicals commonly known as GHS.  The actual documentation of GHS (i.e. the Purple Book) by UNECE can be found in the EBI Library.  The GHS seeks to standardize the way all countries in the world categorize, document, and label chemicals.  Since each country already has its own set of standards and regulations, it is up to each country to ‘harmonize’ their existing requirements with the GHS.

The GHS system covers all hazardous chemicals and can be applied to chemicals in the workplace, transport, consumer products, pesticides and pharmaceuticals. The target audiences for GHS include workers, transport workers, emergency responders and consumers.  The two major elements of GHS are:

  1. Classification of hazardous chemicals (e.g. classifying pure chemicals and mixtures according to GHS criteria or rules)
  2. Communication of the hazards and precautionary information using Safety Data Sheets (SDS) and product and carton labels

GHS and Labeling

When GHS is fully implemented by the local regulatory authorities (e.g. OSHA, DOT, FDA, etc.) it will require all product labels, including labels for shipping cartons and secondary packages as well as primary product labels to comply with new warning symbols, color codes, product identifiers, numbers, signal words, hazard statements, and precautionary statements. The three main required GHS label elements are:

  • Symbols
  • Signal Words
  • Hazard Statements

Symbols

GHS requires a set of symbols to convey health, physical and environmental hazard information.  Each is assigned to a GHS hazard class and category. Pictograms include the harmonized hazard symbols plus other graphic elements, such as borders, background patterns or colors that are intended to convey specific information.  A hazard symbol featuring a white sprawling mass within a bust of a human is used for carcinogens, mutagens, reproductive toxicity, aspiration hazards, respiratory sensitizers and substances which have target organ toxicity. Harmful chemicals and irritants are marked with an exclamation point. Pictograms will have a black symbol on a white background with a red diamond frame.

GHS uses a second set of symbols for transport.  Pictograms will have the background, symbol and colors currently used in the UN Recommendations on the Transport of Dangerous Goods. Where a transport pictogram appears, the GHS pictogram for the same hazard should not appear.  A downloaded and zipped a set of examples of all the pictograms and downloadable files from the UN website in the EBS Library.

Signal Words

“Danger” or “Warning” will be used to emphasize hazards and indicate the relative level of severity of the hazard, assigned to a GHS hazard class and category.  Some lower level hazard categories do not use signal words. Only one signal word corresponding to the class of the most severe hazard should be used on a label.

Hazard Statements

Standard phrases assigned to a hazard class and category that describe the nature of the hazard.  An appropriate statement for each GHS hazard should be included on the label for products possessing more than one hazard.

Additional required label elements include:

  • Precautionary Statements: Measures to minimize or prevent adverse effects. There are four types of precautionary statements covering: prevention, response in cases of accidental spillage or exposure, storage, and disposal.
  • Product Identifier (ingredient disclosure): Name or number used for a hazardous product on a label or in the MSDS. The GHS label for a substance should include the chemical identity of the substance. For mixtures, the label should include the chemical identities of all ingredients that contribute to acute toxicity, skin corrosion or serious eye damage, germ cell mutagenicity, carcinogenicity, reproductive toxicity, skin or respiratory sensitization, or Target Organ Systemic Toxicity (TOST), when these hazards appear on the label.
  • Supplier identification: The name, address and telephone number should be provided on the label.
  • Supplemental information: Non-harmonized information on the container of a hazardous product that is not required or specified under the GHS. Supplemental information may be used to provide further detail that does not contradict or cast doubt on the validity of the standardized hazard information.

GHS Label Format and Placement

The GHS includes directions for application of the hazard communication elements on the label. In particular, it specifies for each hazard, and for each class within the hazard, what signal word, pictogram, and hazard statement should be used. The GHS hazard pictograms, signal words, and hazard statements should be located together on the label. The actual label format or layout is not specified in the GHS. Annex 7 of the Purple Book explains how the GHS pictograms are expected to be proportional to the size of the label text. Generally the GHS pictograms are smaller than the transport pictograms.  Health, physical and environmental hazard information labels typically go on the primary product packaging.  The transportation label typically goes on the case.

 Who is affected by GHS?

As a worldwide initiative, every country is expected to ‘harmonize’ their systems with the GHS standard at some point.  The status of each country can be found on the UNECE website.

The United States is not fully in compliance.  Regulatory authority for chemical labeling standards is splintered amount different groups (OSHA, DOT, EPA, and CPSC).  The bulk of the compliance is expected to come from an initiative by OSHA to merge the GHS standard with the existing HAZCOM standards already in use.  Proposed amendments to the OSHA Hazard Communication Standard regulations to bring them into GHS compliance were published on September 30, 2009.  The new rules were submitted to OMB November last year and acceptance is expected in early 2012.

What you need to do

Until the new rules are approved by the OMB (very soon), there is nothing US manufacturers need to do.  Enforcement will not start until the rules are approved.  However, this is a good time to prepare.  At EBI, we recommend all of our clients get familiar with the GHS requirements and review their labeling systems for compliance.  Once the rules approved, we will provide more guidance on next steps.  EBI clients under support and maintenance agreement will get personalized assistance with a compliance plan from our support team.

References:

UNECE information about GHS:
http://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html

Bringing together different US regulatory bodies in one system: http://blog.msdsonline.com/2011/04/can-osha-nfpa-hmis-the-hazcom-standard-and-ghs-all-play-nicely-together/

OSHA Hazardous Communication Information:
http://www.osha.gov/dsg/hazcom/index2.html

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