GLOBAL GHS ADOPTION: WHAT HAPPENED?

3

4

5

6

7 Submit every received SDS to your SDS management partner.

Ask questions about the SDSs you receive.

Engage a web-based SDS chemical data management system andimplement chemical approval processes.

Review EHS goals with software partners and chemical companies.

Contact manufacturers and suppliers to request SDSs.

1

2

Conduct annual check-ups.

Perform regular physical inventories.

HOW CAN COMPANIES MITIGATE THE CHALLENGES OF GHS?

3

4

5

6

7 Submit every received SDS to your SDS management partner.

Ask questions about the SDSs you receive.

Engage a web-based SDS chemical data management system and implement chemical approval processes.

Review EHS goals with software partners and chemical companies.

Contact manufacturers and suppliers to request SDSs.

1

2

Conduct annual check-ups.

Perform regular physical inventories.

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.

Your organization can implement best practices to navigate the challenges of the GHS transition and maintain compliance.

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.

MandatoryCompleteStaticHarmonized

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.

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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.

BUSINESS IMPACT OF GHS: WHAT REALLY HAPPENED?

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.

GHS is not

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5 AREAS AFFECTED BY GHS

Identification

01

Hazard(s) identification

02

Composition/information

on ingredients

03

First-aid measures

04

Fire-fighting measures

05

Accidental release measures

06

Handling &storage

07

Exposure controls/

personal protection

08

Physical and chemical properties

09

Stability and reactivity

10

Toxicological information

11

Ecological information

12

Disposal considerations

13

Transport information

14

Regulatory information

15

Other information

16

Classification Criteria

However, in GHS nomenclature, “category 1” is the worst.

This can cause confusion during training, which may draw the process out.

OLD NEW1

2

3

4

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2

3

4

In current NFPA or HMIS rating systems, “4” is the worst rating, and “1” is the best.

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2Label ratings are inverted

16-Section SDS 1 3There 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.

Standardized GHS Pictograms Shown with example hazard.

MSDS is now SDS (Safety Data Sheet)

Name

MSDS SDS

WARNING

DANGER

Classifications

Acute Toxicity

Skin Corrosion RESPIRATORYCATEGORY I

CATEGORY IICATEGORY III

CATEGORY IV

P&H phrases

Hazard

Precautionary Statements

Labels

Flammable Explosive Oxidizer Corrosive Irritant Carcinogen Environmental Toxicity

Gas Under Pressure

Acute Toxicity

4 Communication/Distribution

5 Training

ADOPTION IN THE U.S.

GHS

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 classi�cations.

OSHA 2012 includes the following unique classi�cation criteria: Hazards Not Otherwise Classi�ed (HNOC) Pyrophoric Gas Simple AsphyxiantCombustible Dust

OSHA 2012 did not adopt: Acute Toxicity Category 5Skin Corrosion / Irritation Category 3Aspiration Hazard Category 2Hazardous to the Aquatic Environment Hazardous to the Ozone Layer

What are the end goals of GHS? The basic goal of the GHS is to standardize the classification rules for hazards, as well as safety data sheets (SDS) and chemical labels.

Move toward global standardization

Provide programs where absent

Improve environmental

protection

Reduce chemical testing and evaluation

Facilitate international trade

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.

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.

GHS Implementation Around the Globe

Canada

United States

Mexico

Australia

China

Japan

Russia

Korea

Australia’s transition period ended Jan. 1, 2017. Although all Australian states have not officially adopted the GHS, it is still accepted throughout Australia.

The EU is fully implemented and has also had several modifications called Adaptations to Technical Progress (ATP) that include through UN GHS Revision 5.

European Union

Korea’s latest standard, fully effective in 2013, is based on GHS Revision 4.

Canada’s transition period is in effect through the end of 2018.

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.

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.

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.

China is fully implemented. China's adoption of GHS is currently based on UN GHS Revision 4.

New Zealand was one of the �rst country's to adopt a GHS. Since that time they have been working on fully incorporating GHS into their regulatory framework .

In 2014 Russia introduced voluntary regulations including the GHS criteria. A mandatory standard implementing the GHS has been published and will be e�ective July 2021. Both standards are based on Revision 4.

New ZealandGHS 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.

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.

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.

THE FACTS THE ADOPTION OF GHS

GLOBAL ADOPTION: WHAT HAPPENED?