Jennifer Silk has been a proponent of the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals since the very beginning. With OSHA tentatively looking at 2008 as the start of implementation in the United States, she’s about to see all that hard work pay off.
We‚Äôve been hearing about it for years, and now the time appears to finally have arrived for GHS, a worldwide system for standardizing and harmonizing the classification and labeling of chemicals. Developed by the United Nations, GHS, to me, seems like a logical way to approach:
- Defining health, physical and environmental hazards of chemicals.
- Creating classification processes that use available data on chemicals for comparison with the defined hazard criteria.
- Communicating hazard information, as well as protective measures, on labels and material safety data sheets (MSDSs).
I never have met a safety manager who deals with chemicals who has not complained about seemingly warring federal regulations from OSHA, EPA and the Department of Transportation ‚Äď let alone regulations governing chemicals produced or sold in other countries ‚Äď regarding the storage, transportation and identification of chemicals. Service providers have sprung up that do nothing but help companies manage and standardize their inventories of MSDSs and labels for chemicals coming from different suppliers.
Silk, now a senior special fellow for the United Nations Institute for Training and Research on issues related to GHS, and the retired deputy director of OSHA‚Äôs Directorate of Standards and Guidance, helped shepherd the United States‚Äô conversion to GHS. GHS, she claims, will make workplaces safer and have trade benefits for U.S. companies.
‚ÄúThe hazcom standard made [safety] jobs easier because industrial hygienists used to have to go on scavenger hunts to determine what chemicals were in use in the workplace. Now, they know,‚ÄĚ says Silk. The next logical step, with the globalization of so many businesses, is to create a global system of classification, she adds.
OSHA‚Äôs Hazard Communication standard is designed to ensure that information about chemical hazards and associated protective measures is communicated to all who might handle the chemicals.
Implemented in 1983 and revised in 1987, the challenge of the Hazard Communication standard, says Silk, is standardization. ‚ÄúMSDSs come in different formats [and] there are various labels for chemicals,‚ÄĚ reports Silk. ‚ÄúGHS will provide workers and employers with consistent messages. GHS will facilitate standardized training and communication to workers about chemicals in the workplace.‚ÄĚ
GHS will place the biggest burden on chemical manufacturers, which will have to re-evaluate hazard determinations to include multiple categories in each class of health hazards, rather than noting ‚Äď as now is the case with the hazcom standard ‚Äď that a chemical simply meets the definition of a health hazard.
According to an OSHA spokesperson, surprisingly, having a hazcom standard in place makes the GHS implementation process more difficult in the United States in some ways than it is in countries that do not have hazard communication and management standards in place. ‚ÄúIt‚Äôs difficult to go back and retool what‚Äôs already there,‚ÄĚ the OSHA spokesperson notes. ‚ÄúOne of the benefits of GHS for countries that don‚Äôt have the resources to go through that process [of creating a system to manage hazardous chemicals] is that it gives them a system they can adopt.‚ÄĚ
Difficulties aside, after years of research and discussion, GHS has been fast-tracked at OSHA, and the agency is doing what it can to meet the international phase-in start date of 2008. Phase-in is expected to take several years. For starters, the agency has put together information materials that compare GHS and the hazcom standard point-by-point, and a guide to GHS. According to the spokesperson at OSHA, the agency faces three major challenges with GHS:
- How to phase-in GHS so that it will have minimal impact on industry.
- How to handle ‚Äúdueling‚ÄĚ systems ‚Äď hazcom and GHS ‚Äď during the phase-in period.
- The timing of training and compliance assistance such as e-tools.
Despite resistance from some quarters, opting out of GHS is not an option.
‚ÄúThis is the direction we‚Äôre going in,‚ÄĚ says the OSHA spokesperson. ‚ÄúThis is the direction the world is going in. The United States would be at a disadvantage if we did not adopt the GHS.‚ÄĚ
And the world would be at a disadvantage, admits Silk, if the United States dragged its feet on implementation.
‚ÄúNobody wants to be the first one in the room to say that the United States and Europe are the two 800-pound gorillas in the room,‚ÄĚ says Silk. ‚ÄúBut what the United States and Europe do will effect everyone else. The message in some countries seems to be, ‚ÄėYou don‚Äôt want to be out in front of the United States.‚Äô‚ÄĚ
An effective, hassle-free phase-in of GHS could have an even greater impact for EHS around the world than just the system itself. ‚ÄúThis could lead to the harmonization of a lot of occupational safety and health issues,‚ÄĚ says Silk. ‚ÄúStandardization of control banding ... permissible exposure limits ... The fact that GHS has gotten this far opens up possibilities for other things as well.‚ÄĚ