THE ADOPTION OF GHS
THE FACTS
The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is a standard system for labeling and classifying the hazards in chemicals and
for conveying that information in health/data sheets for common global use. Prior to the GHS, every country had a different system for communicating information on
the hazards of chemicals. GHS intends to provide standardized classification criteria and hazard communication elements for international regulatory agencies.
GHS Implementation Around the Globe
Move toward global
standardization
Canada’s transition period is in
effect through the end of 2018.
Improve
environmental
protection
Russia
European Union
Canada
Provide programs
where absent
In 2014 Russia introduced voluntary regulations
including the GHS criteria. A mandatory standard
implementing the GHS has been published and
will be effective July 2021. Both standards are
based on Revision 4.
The EU is fully implemented and
has also had several modifications
called Adaptations to Technical
Progress (ATP) that include
through UN GHS Revision 5.
Facilitate international
trade
What are the end goals of GHS?
The aim is to create a system that
can be utilized as needed by
countries using a building- block
approach, or a la carte style.
The basic goal of the GHS is to standardize the
classification rules for hazards, as well as safety
data sheets (SDS) and chemical labels.
Japan
Japan's adoption of GHS is currenlty
based on UN GHS Revision 4 but
does not include all hazard classes
and categories included in GHS.
United States
The United States’ transition period for initial
GHS implementation (based on Revision 3) has
ended; OSHA has signaled the start of the rule
making process to update the Hazard
Communication standard. The updates being
considered include all changes to UN GHS
through revisions 6 and 7.
Reduce chemical
testing and
evaluation
Korea
Korea’s latest standard, fully effective
in 2013, is based on GHS Revision 4.
New Zealand
China
Mexico
Mexico's implementation of GHS is based on the 5th
revision of the UN GHS Purple Book. A 3-year
transition period is currently underway and is set to
end in October 2018.
China is fully implemented.
China's adoption of GHS is
currently based on UN GHS
Revision 4.
Australia
GHS has been implemented around the world, starting with early adopters
in Europe, Japan and New Zealand. Depending on the time of adoption,
countries have implemented different versions of GHS spanning from the
original version to Revision 6. The United Nations releases a new version
of GHS every 2 years.
New Zealand was one of the first
country's to adopt a GHS. Since that
time they have been working on fully
incorporating
GHS
into
their
regulatory framework .
Australia’s transition period ended Jan. 1,
2017. Although all Australian states have not
officially adopted the GHS, it is still accepted
throughout Australia.
5 AREAS AFFECTED BY GHS
1
3
16-Section SDS
01
03
02
Identification
Hazard(s)
identification
09
10
2
Composition/
information
on ingredients
First-aid
measures
12
11
Physical and
Stability and
chemical properties reactivity
05
04
Toxicological
information
06
07
08
Handling &
Fire-fighting
Accidental
measures release measures storage
13
14
Ecological
Disposal
information considerations
Transport
information
Exposure
controls/
personal protection
16
15
Regulatory
information
Other
information
Classification Criteria
1
2
3
4
In current NFPA
or HMIS rating
systems, “4” is
the worst rating,
and “1” is the
best.
There are two signal words in the
GHS system: danger and warning.
These signal words are used to
communicate the level of hazard on
both the label and the SDS.
Name
SDS
NEW
1
2
3
4
However, in
GHS
nomenclature,
“category 1” is
the worst.
Shown with example hazard.
Communication/Distribution
5
Training
Hazard
Classifications
MSDS
4
Precautionary
Statements
WARNING
Standardized GHS Pictograms
?
P&H
phrases
DANGER
MSDS is now SDS (Safety Data Sheet)
Label ratings are inverted
OLD
Labels
CATEGORY II
ORY III
CATEG
Skin Corrosion
Acute Toxicity
RESPIRATORY
CATEGORY IV CATEGORY I
This can cause
confusion during
training, which
may draw the
process out.
Flammable
Explosive
ADOPTION IN THE U.S.
Oxidizer
Corrosive
Gas Under
Pressure
Acute Toxicity
GLOBAL GHS ADOPTION: WHAT HAPPENED?
The United States adopted Revision 3 of UN GHS. Under the
building block approach, OSHA adopted most GHS hazard classes
and categories. The changes to the HazCom standard also
included a standardized 16-section SDS format and mandatory
label elements (signal words, pictograms and hazard statements)
based on classifications.
OSHA 2012 includes the following unique
classification criteria:
GHS
GHS
Hazards Not Otherwise Classified (HNOC)
Pyrophoric Gas
Simple Asphyxiant
Dust
isCombustible
not
Irritant
Carcinogen
Environmental
Toxicity
OSHA 2012 did not adopt:
Acute Toxicity Category 5
Skin Corrosion / Irritation Category 3
Aspiration Hazard Category 2
Hazardous to the Aquatic Environment
Hazardous to the Ozone Layer
GLOBAL ADOPTION: WHAT HAPPENED?
Although the building block approach supports flexibility and provides an
avenue for competent authorities to integrate GHS within existing systems,
internationally, various competent authorities adopted different revisions of
GHS and/or the hazard classes, hazard categories and criteria included in
the system.
Mandatory
Complete
Static
Harmonized
The flexible global adoption of GHS has fractured the forecasted harmonization,
creating unexpected outcomes. Disharmony can be found in hazard statements,
classification criteria and pictograms.
Often, employers are not aware of the decisions made by authoring teams. This
resuls in challenges for employers and SDS Management systems when acquiring
new SDSs and aligning old and new versions of documents.
In the MSDS to SDS conversion (to GHS) companies often had
to make business decisions to get documents authored within the
confines of the multi-year transition period. These business
decisions have consequences for SDS management
downstream.
Your organization can implement best practices to navigate the
challenges of the GHS transition and maintain compliance.
BUSINESS IMPACT OF GHS: WHAT REALLY HAPPENED?
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To save time and money, Manufacturers, Distributors and Suppliers consolidated
products in one SDS. This created challenges for employers and SDS management
systems to match and track associated SDSs and products.
Manufacturers, Distributors and Suppliers separated products into different SDSs. For
employers and SDS management systems, complexity increases when matching products
and documents. For instance, an MSDS for paint may now have four SDSs for different
colors of paint.
If SDS and authoring teams are not integrated, labels and product packaging could be
different--leading to differences in product identification, labeling and packaging. Gaps in label
generation and practical application require additional attention to match the correct SDS and
label to the product and its packaging on site.
Regulatory changes in material identification and how product information
related to the new SDS yielded difficulty in associating documents with
materials on site.
HOW CAN COMPANIES MITIGATE THE CHALLENGES OF GHS?
11
Conduct annual check-ups.
22
Perform
regular
physical
inventories.
Perform regular
physical
inventories.
33
Contact
manufacturers
and suppliers
to request SDSs.
Contact manufacturers
and suppliers
to request SDSs.
44
Review
EHS
goals
with software
partners
Review EHS
goals
with software
partners and
chemicaland
companies.
chemical companies.
55
Engage a a
web-based
SDS chemical
data management
system and
Engage
web-based
SDS chemical
data management
implement chemical approval processes.
system and implement chemical approval processes.
66
7
7
Conduct annual check-ups.
Ask questions about the SDSs you receive.
Ask questions about the SDSs you receive.
Submit every received SDS to your SDS management partner.
Submit
every received SDS to your SDS management
partner.
As companies scrambled to author new SDSs, the implementation of authoring systems
impacted how SDSs are managed at all levels. In some cases, authoring software is missing
product codes or data was not migrated in time, resulting in incompletely authored documents
and SDSs that do not clearly align with the MSDSs they replace.
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