How is GHS used for Hazard Communication?

First of all, the Globally Harmonized System or GHS is used to classify, label and communicate relevant information regarding chemical hazards in the workplace. It differs from the previous systems that it has since replaced in the following way: the GHS is internationally agreed upon, and put forward and developed by the United Nations. One of the main problems before GHS came into common use was that different countries had different systems of chemical hazard classification, and many countries, in fact, had more than one. Naturally, this led to a great deal of confusion.

We can divide the scope of the globally harmonized system into two areas, which we shall discuss separately: GHS hazard classification and GHS hazard communication.

GHS hazard communication

GHS Hazard Classification

Using practical experience in the field, years of collected research and literature, and test data, this global system is complex and covers every possible issue. First, the hazards are classified into health hazards, physical hazards and environmental hazards.

Physical Hazards

This area makes use of the United Nations Dangerous Goods System, easily found on the United Nations website. They include flammable gases and aerosols, explosives, pressurized gases, gases which cause oxidization, flammable solids and liquids, substances which are self-reactive, pyrophoric solids and liquids, substances which are self-heating, flammable gas-emitting substances (when in contact with water), oxidizing solids and liquids, organic peroxides and substances which are corrosive to metal.

GHS hazard communication

Health Hazards

Health hazards are further classified into acute toxicity, skin corrosion, skin irritation, eye irritation, serious eye damage, skin sensitizer, respiratory sensitizer, germ cell mutagenicity, reproductive toxicity, carcinogenicity, specific target organ toxicity or STOT and aspiration hazards.

Environmental Hazards

Environmental hazards are classified into two major subheadings, namely acute aquatic toxicity and chronic aquatic toxicity. The former refers to damage that is caused to the aquatic organisms in a short-term exposure. The latter refers to the potential that a material has due to its specific properties that may have negative effects on the organisms in relation to their lifecycles.

GHS Hazard Communication

Once hazards have been classified, they must be communicated to those who come into contact with the hazardous chemicals, including but not limited to workers and emergency personnel. The guiding principles behind communication regulations are as follows:

  • Trade secrets and other confidential information are not dealt with directly, but rather in general terms.
  • GHS states that communication should not be limited to one form (accepted forms include labels, placards and SDS (safety data sheets).
  • Hazard statements as well as precautionary statements should be made.
  • Any communication and information should be standardized, easy to follow and easy to understand.
  • Consistency is necessary to avoid any kind of confusion regarding communications.
  • New evidence should be swiftly incorporated into hazard information, and all existing research should be taken into account.

The problem with a global system, however, is that it must take many different cultures and sensibilities into account, including language differences, different nuances, and the comprehensibility of pictograms.

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Health Canada GHS Technical Guidance Released June 2016

GHS Labelling of Chemicals

Canada GHS holds importance for chemical manufacturers and exporters in the US since most of them are engaged in trade across the border. The deadline is June 2017 for implementation of the GHS in two phases. Phase one comprises on classification principles, confidential business information and hazard communication while passé 2 focuses on health and physical hazard classification. The Health Canada GHS implementation is just as important for Canada based chemical manufactures, importers and end users. Canada WHMIS 1988 now incorporates GHS for workplace chemicals. It more or less aligns with the systems now in place in the US. Almost all hazard classes are covered with the possible exception of explosives. The objective is to enhance safety of workers. At the same time the bio hazardous infectious materials hazard class that does not form part of GHS health hazard class is retained in Canadian HPR with the same objective while additionally introducing new health hazard classes but environmental hazard classes have not been included in the HPR.

This and other modifications necessitate a different approach to preparation of GHS SDS and GHS labelling of chemicals for conformity with Canadian guidelines. Pictures and statements do form a part of SDS and labels but it is necessary to use slightly different pictograms and texts. The good news is that despite variances in approach between the Canadian and US regulations, both governments are working to maintain uniformity and ensure that a single SDs and label for each hazardous product is acceptable. It does require expertise of both OSHA Hazcom 2012 and Canadian WHMIS to be able to pinpoint the differences and ensure compliance and this is where ICSDS GHS labelling and SDS expertise comes into play.

GHS Labelling of Chemicals

ICSDS assists US and Canada based chemical manufacturers, importers and experts with the transitioning from CPR to GHS SDS under the new Hazardous Products Act. The deadline is fast approaching and quick action needs to be taken to ensure full compliance by June 2017 or latest by end of the year. ICSDS scientific experts are familiar with OSHA GHS SDS labelling requirements and also with Canadian guidelines in this regard.

Consider the inclusions and exclusions of the Canadian GHS requirements and updating existing materials to comply with the new guidelines can be an exacting task. It requires a detailed conversion plan to examine present safety data sheets and labels and match them against the new regulations before proceeding with revision. Employees also need to undergo training to know the changes in data sheets and labels and learn to implement them correctly at workplaces. ICSDS takes care of phase I and phase II of the new HMIS 2015 implementations to ensure a flawless transition.

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What are the important requirements of GHS implementation

GHS implementation

Chemicals are made by manufacturers for the different purpose. But, the transition period between its productions till the receipt of the end user is very critical. It is going to cause different types of damage to the human being as well as environment. Communication of the hazards from the very beginning is important. This should be conveyed by the manufacturer. Proper labeling and classification of each chemical are very important.  The communication and identification of risk at workplace is repeatedly updated. Some rules are different based on the geographical locations.

Classification of hazard

The previous standard is used while dealing with classification of hazards. GHS implementation is a wonderful attempt to keep the human being and the environment safe from the effect of chemicals exposed. What type of health hazard can take place after reaction of each chemical, is important to find out. The information about all the chemical ingredients and mixtures are duly present in the data sheet.

What are the requirements?

Labeling is an important requirement for each chemical. GHS implementation also speaks about labeling. Following are the facts included on the label:

  • The name or the identity of chemical or the mixture
  • Suitable pictogram
  • Signal word
  • Code for hazard identification
  • Identification codes for precautions

The manufacturer of the chemical also should indicate the symbol and sign with the size. It is done in such a way that the employer must be capable to define the dimension of all the pictograms. That too from a distance less than 7 meters.

GHS implementation

Inclusion of the Safety data sheet (SDS)

The safety data sheets have many points. You have to read each and every points before using each chemical. Skipping any one point from the list may mislead you. Normally, there are 16 points in the data sheet. Following are some important facts:

  • The written facts in the sheet must be concise. People should understand it clearly
  • It include the symbol for each chemical
  • The chemical name and the brand name is mentioned
  • It include the properties of each chemicals and mixtures
  • How hazardous is the product is also stated
  • People can know about its effect on the environment and people
  • The manufacturer should state the precautionary measures to prevent precautions
  • The manufacturer must not use any vague expression
  • The pages should be numbered for proper understanding.

Difference between GHS rules of different countries

The rules and regulations of GHS in each country is different. Thus, the implementation of precautionary measures will be dissimilar. But, all the terms should be accepted globally by the world Health organization (WHO). There will be a need for ecological toxicity classification and its disclosure. In both Canada and U.S, the classification criteria are different. The labeling outline with upper and lower threshold must be mentioned. The audiences of GHS are the international organization, regional institutes, and government etc.

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GHS SDS Solution by ICSDS Helps Produce Labels Quickly and Easily

Image may contain: 1 personTransitioning to the new HazCom 2012 is a difficult time for most manufacturers and dealers of chemicals in the US. Apart from routine business matters the additional concern is to update existing MSDS to SDS or get new ones prepared. This can be a simple or complex task depending on how the chemicals have been reclassified.

A company may choose to use its own staff to update the data sheets. What happens in that case is that quite a lot of time is wasted in trying to find out the precise classification code for products. GHS SDS solution by ICSDS takes care of safety data sheets preparation or updates and saves clients time besides getting them the benefit of knowledge and expertise.

Another matter of concern relating to compliance is that of safety labels. The new safety labels carry pictograms and warning text. The text must be written using the right set of words to convey information without any confusion. This is just one part of it. Labels need to be printed and displayed as well as affixed to containers. Users can use templates and ready to use labels but the better solution provided by ICSDS is printable labels and cards used in conjunction with cloud based software. This allows for printing of customized primary and secondary container labels. Labels printed this way are more precise and accurate in conveying hazard information. ICSDS label printing solutions make it easy for manufacturers or traders of chemicals to print the type and size of labels as may be required using their in-house inkjet or laser printers.

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The computerized solution allows users to resize and move hazard pictograms as well as warning texts within the label area. The operator need not enter data. He calls up the relevant safety data sheet and links it to the printing software. This means there is no chance of error. Labels are as near perfect as they can be as regards information, compliance and size that makes for easy reading even from a distance. Labels on containers come in for rough treatment. As such these labels need to be tough and durable. ICSDS offers users a variety of options in label materials.

The GHS SDS solution goes beyond compiling data sheets and making them accessible for use in label printing. Clients have the option of a complete software that helps them create and maintain databases, access databases online and also track containers. The software can be used on desktops as well as mobile devices allowing more flexibility and freedom for users at any level. The documents and labels need to be translated to other languages should a company get into the export business and deal with organizations in Europe or Asia. ICSDS solutions also include training and translation.

By retaining ICSDS clients gain immense benefits such as accuracy in SDS and continuing support which is vital since UN GHS is always subject to revision as new information on hazard level of chemicals continues to be uncovered.

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Room for Improvement in HazCom 2012 Safety Data Sheets

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OSHA adopted UN GHS recommendations and implemented one of its many revisions for the HazCom 2012 standards. However, no system is perfect as can be seen by the fact that UN GHS itself has been revised so many times. OSHA too has recognized that while its adoption of GHS has been a tremendous leap in providing greater safety for employees at workplaces, there may be room for improvement. To this end it has decided to obtain feedback on its Guidance on Data Evaluation For Weight of Evidence Determination Application to the 2012 Hazard Communication Standard. The aim, ultimately, is to help in preparation of accurate SDS and labels that contribute to greater safety and health of workers.

Why this need? The HazCom 2012 makes it incumbent on manufacturers/importers to specify precise nature of health and physical hazards of chemicals based on consulting of full range of scientific evidence as available. This is interpretative and puts manufacturers in a quandary. How much should they search from available scientific literature to arrive at a point that is satisfactory? This may be taken to mean that it is better to err on the side of maximizing risks of any chemical. This exercise of scanning scientific literature is beyond most manufacturers who lack resources but it is a task handled with ease by experts at ICSDS.com who specialize in preparation of HazCom 2012 Safety Data Sheets with absolute precision and without any ambiguity.

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OSHA’s new document, still in a draft stage, helps authoring professionals get clarity in the case of conflicting data. Still, since this is in the evolutionary stage, professional authoring companies must use their own knowledge and expertise in arriving at the right conclusion that remains valid today and stands the test of any information that may be uncovered in the near future. OSHA may take its time to perfect the guidelines based on feedbacks from users but ICSDS professionals use their knowledge and experience to create SDS and labels that are as precise as is possible. Employers retaining ICSDS are reasonably assured that their workplaces are as safe as can be for their employees through the development of meticulously crafted SDS and training programs.

Change eventually may come about. In the meantime, ICSDS works in close coordination with employers and their managers to ensure implementation of an effective communication system that keeps employees fully updated about safety information of chemicals.

It is important to build a safety culture at work, an area on which ICSDS focuses and that safety culture is one that is open to changes that may come about in time. For the present and for the near future, ICSDS involvement helps managers keep current and inform their employees accordingly. Safety can always be improved and the HazCom2012 safety data sheet is the starting point. Preparation, followed by support and ongoing updates is the surest way to improve safety, regardless of when and how OSHA brings about improvements.

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HazCom 2012 Safety Sheets by ICSDS—A Seamless Transition

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Deadlines for compliance with OSHA HazCom 2012 requirements have passed. Still, there are many manufacturers/importers who have not upgraded existing MSDS to GHS SDS as specified by OSHA for a variety of reasons such as not having received SDS from upstream suppliers or confusions about classification and categorization of chemicals. Strict penalties are mooted and the sooner one becomes compliant the better it is.

Getting it wrong is also not desirable. In effect the SDS is more or less similar to the earlier MSDS conveying similar information but in a more structured way. The MSDS has 8 sections to the 16 of SDS. Upgrading an existing to HazCom 2012 GHS should pose no problem except where a product needs to be reclassified. Manufacturers/employers handling only a couple of products may find it a simple task to do so either on their own or with the assistance of experts in preparation and upgradation of SDS to the new regulations. Where manufacturers or importers handle hundreds of different chemicals, the task may be significantly more complex. Where such manufacturers export to other countries such as Canada, Australia or China or the EU, it becomes necessary to not only have SDS updated to conform to OSHA HazCom 2012 but also to be compliant with existing norms in specific countries that have adopted GHS SDS in their own way. This is where HazCom 2012 Safety Data Sheets by ICSDS services prove invaluable.

Time is of the essence especially in cross border trade. Lack of an acceptable SDS in the country of import may see the consignment withheld. For instance, many American manufacturers supply basic, raw or intermediate chemicals to buyers in Canada where HPA and WHMIS requirements must be met. ICSDS not only helps such manufacturers prepare updated SDS to conform to OSHA but also to modify such SDS for Canadian or other country’s jurisdictions.

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Expertise in knowledge about OSHA and regulations of importing countries plays a key role in ICSDS expertise in providing fast and efficient services. Professionals examine the existing MSDS if there is one and update it to SDS taking care to consider whether the product needs reclassification. They examine whether the SDS issued by a supplier is sufficient or whether the importer/user needs to develop the SDS on his own. The assistance includes preparation of SDS GHS labels in addition to electronic conversion for easy access online or on portable devices. Training to employees in interpreting new SDS and labels goes hand in hand with providing expert consultations on how to manage the transition to current standards and documentation in a painless manner.  With ICSDS to help there is no need to worry about timely compliances. Also, there is no need for manufacturers or importers to try to figure out the complex regulations on their own. ICSDS helps. This help even extends to providing guidance on maintaining and managing the library of SDS and updating it in future if and when required.

One cannot escape compliance with HazCom 2012 and SDS must be prepared. Getting them done by experts offers innumerable advantages in the short and long term.

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GHS For Hazard Communication By ICSDS.Com Assures Uniformity

The UN introduced the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) with the objective of standardizing hazard communications for chemicals. It was introduced in 1983 and, since then, quite a few countries have adopted GHS in one of its many iterations besides introducing their own specific terms.

OSHA updated the Hazard Communication standard in 2012 and it is mandatory for all manufacturers/dealers/distributors/exporters/importers of chemicals in the USA to update their existing MSDS to GHS SDS. In some cases this is a straightforward task of filling in the 16 sections of the SDS with appropriate data. In some cases, the task is not that simple because GHS may have put the chemical in an altogether different hazard category. GHS for hazard communication by icsds proves to be of immense help in such cases where updating existing MSDS to SDS becomes a chore. OSHA terminology is also not precisely clear and it is open to interpretation leading a number of manufacturers to ask for clarifications about SDS and more specifically about labeling requirements. Link this with the fact that competent authorities in various countries define their set of regulations and that the SDS and labels must be translated to the native language, the task of updating MSDS or creating new ones becomes even more complicated.

Where employees of a company may come up against questions and doubts should they take on the task, such matters are routine for specialists who are aware of the intricacies of categorization and classification under GHS applicable to a specific country like the US or for other countries like EU where REACH and CLP are in force, for example. Expertise and knowledge are key factors that are responsible for right categorization, creation of perfect SDS that are fully compliant and labels without any ambiguity.

Even more important, from the manufacturer/seller perspective is the matte of safeguarding business confidentiality of chemical formulations. This is where expertise of icsds professionals shows. They can manage this aspect of expertly covering confidentiality while drawing up the SDS to deliver as much hazard information as is necessary. When it comes to exports, a manufacturer/exporter need not find a suitable professional to compile SDS for a specific country. As an international organization, icsds.com handles GHS-SDS for various jurisdictions. This extends to reconsidering classification according to the country of destination and appropriate labeling to go along with the SDS.

As a one stop solution, icsds.com has been delivering invaluable services to meet regulatory challenges and to help manufacturers/exporters stay fully compliant. Their professional SDS authoring expertise helps manufacturers trade effortlessly in international markets knowing that their SDS are fully up to date and their business confidentiality is also retained. Clients can receive advice on testing for hazard assessment, help for translations into regional languages, consultation on meeting regulations and a host of related services. With icsds by their side, chemical manufacturers and exporters benefit by expert advice and guidance at each stage and also have peace of mind knowing they are future-proofed.

 

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Easy Implementation of GHS for Classification Across Countries

GHS implementation is relatively simple when only one country is involved. American manufacturers and dealers of chemicals deemed hazardous in any degree must have a safety data sheet that complies with OSHA guidelines. For those companies involved in cross border trade, it becomes much more difficult unless they have professional help in compilation of SDS to various standards.

The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) aims to ensure greater safety during production, storage, transport, handling and use of chemicals. Further, countries are free to implement any set of recommendations using the building block approach and they are responsible for implementation within their jurisdiction. This freedom also creates issues of standardization and uniformity.

The situation is complicated by implementation of various GHS Editions by various countries. First released in 2005 the GHS has undergone five revisions with the last, 6th edition of 2015 yet to be implemented anywhere. East and West European block, Sweden, UK, Uruguay, Zambia and Abu Dhabi among other countries have adopted GHS Edition 4. Argentina, Canada and Mexica have opted for GHS edition 5. Australia, Korea, Malaysia, New Zealand, Thailand, Vietnam, Turkey, Serbia, Switzerland and the US have opted for edition 3 while Ecuador and South Africa still follow the 2nd edition. The EU has REACH and CLP and is likely to adopt the 6th revision. Each country may incorporate its own set of rules as well. As can be seen, this situation complicates matters for manufacturers, dealers and exporters of chemicals. Apart from complying with local GHS for classification, they must also comply with the country they deal with.

As an example, USA and Canada have clarified how matters stand as regards GHS classification and compliances. It has been agreed that only one safety data sheet and label would be acceptable in both countries as a way to keep workers protected. There are minor changes. One is that the SDS and labels must be in English and French. The supplier identifier must appear on the label and the SDS for Canadian markets and the label must also disclose HNOC hazard element. What is superfluous for one country will be acceptable in the other provided their basic requirements are met. This does simplify matters but American exporters do need to have bilingual documents that do not lose anything in the translation while keeping in mind specific idiosyncrasies of local laws of Canada. It is likely there will be more such bilateral collaborations between countries to truly harmonize GHS classification and documentation.

The current situation for American chemical companies engaged in cross border trade is that they must have OSHA compliant GHS SDS and must also have a different SDS complying with the country with which they trade. Translation is just one aspect; the company entrusted with the GHS compliance documentation must also understand the GHS edition in force and the specifics of each country’s laws. Expertise and experience of a company engaged in this field come into play and greatly help manufacturers. The consignment moves rapidly from source to destination with safety for everyone in the chain and no delays due to any compliance discrepancy.

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