When it comes to hazards and compliance, it can often seem that each agency involved has its own terms, definitions, jurisdictions, and regulations.
There’s the Globally Harmonized System (or GHS), as incorporated into OSHA’s 2012 revised HazCom Standard (or HCS), and the EU’s Registration, Evaluation, Authorization, and Restriction of Chemical Substances (or REACH) and Classification, Labeling and Packaging of Substances and Mixtures (or CLP) regulations.
Clear as mud, right?
So here, we hope to demystify and clearly define each governing body so you can feel confident that you know which is – and which is not – responsible, and for what.
In the United States, the Occupational Safety and Health Administration assures safe and healthful working conditions for employees by setting and enforcing standards and by providing training, outreach, education, and assistance.
Under the OSHA law, employers are responsible for providing a safe and healthful workplace for their workers for most private sector employers and their workers, in addition to some public sector employers and workers in the 50 states and certain territories and jurisdictions under federal authority.
In the European Union, REACH serves the same regulatory function as OSHA – to improve the protection of human health and the environment from the risks that can be posed by chemicals. Further, REACH applies to all chemical substances – not only those used in industrial processes but also in our day-to-day lives, such as cleaning products and paints, as well as in clothes, furniture, and electrical appliances.
And similarly to OSHA, REACH places the burden of proof on companies so, in order to comply with the regulation, companies must identify and manage the risks linked to the substances they manufacture and market in the EU.
In 2003, the United Nations adopted the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), with the idea being that ‘harmonized’ would imply a more universal means of classifying and labeling chemicals to streamline international trade.
Officially adopted by OSHA in 2009, it states that the manufacturer, importer or distributor must communicate all hazardous characteristics of the chemical product as defined by OSHA – in essence, whoever formulates, imports or owns the brand.
Similarly, CLP Regulation – or Classification, Labelling and Packaging – is a European Union regulation which aligns the European Union system of classification, labeling, and packaging of chemical substances and mixtures with GHS.
Such classification and labeling identify hazardous chemicals and inform users about their hazards through standard, harmonized symbols, and phrases in accordance with GHS.
Updates Expected This Year
OSHA is expected to revise its HazCom Standard this year to better align it with the current GHS and formalize various enforcement policies that have been issued since the last major update to HazCom in 2012.
As GHS is considered a ‘living document’ that is revised approximately every two years, the United Nations just completed its seventh edition.
Some seventh-edition changes include:
- Revised criteria for categorization of flammable gases within Category 1
- Miscellaneous amendments intended to clarify the definitions of some health hazard classes
- Additional guidance to extend the coverage of section 14 of the Safety Data Sheets to all bulk cargoes transported under instruments of the International Maritime Organization (IMO), regardless of their physical state
- Revised and further rationalized precautionary statements in Annex 3
- A new example in Annex 7 addressing labeling of small packages with fold-out labels
While it may seem impossible to stay current on all the ever-changing GHS regulations governing the chemicals in your workplace, it can be done with the right tools and processes in place.
Global Safety Management can help you ensure that your safety data sheets (SDSs) are readily available, up-to-date and easily accessible from computers, tablets, and mobile devices so that implementing and maintaining an effective hazard communication program in minutes.
Contact us to help you simplify your process and ensure compliance today!